ML093020275

NUREG-1929, Vol. 1, (2:2) Chpt 3 - End, Safety Evaluation Report, Related to the License Renewal of Beaver Valley Power Station, Units 1 and 2, Firstenergy Nuclear Operating Company

ML093020275
Person / Time
Site:	Beaver Valley
Issue date:	10/31/2009
From:	Office of Nuclear Reactor Regulation
To:
References
NUREG-1929, Vol. 1
Download: ML093020275 (630)

Text

SECTION 3 AGING MANAGEMENT AGING MANAGEMENT REVIEW RESULTS RESULTS This Section of the safety safety evaluation report (SER) evaluates evaluates aging management management programs programs (AMPs) and aging management management reviews (AMRs) (AMRs) for Beaver Beaver Valley Power Station (BVPS) (BVPS)

Units 1 and 2, by the staff of the United States Nuclear Regulatory Commission (NRC or the the staff). In Appendix B B of its license license renewal application (LRA), FirstEnergy application (LRA), FirstEnergy Nuclear Operating Operating Company (FENOC Company (FENOC or the applicant) described described the 42 AMPs AMPs that itit relies on to managemanage or monitor monitor the aging aging of passive, long-lived structures structures and components (SCs). (SCs).

In LRA Section 3, the applicant provided the results of the AMRs for those SCs applicant provided SOs identified in LRA Section 2, as within the scope of license renewal renewal and subject subject to an AMR.

BVPS Units 1 and 2 are constructed of similar materials with similar environments. Therefore, mechanical system and component the mechanical information presented component information presented in the LRA typically typically applies applies to both units, and no unit-specific identifier is listed. However, design differences unit-specific identifier differences exist between Units 1 and 2. Those design differences differences are identified identified by using a designator (Le., (i.e., Unit 1 only or Unit 2 only). Further, BVPS assigned a different designator (i.e., (Le., common) for those cases in where the system, structure, or component component (SSC) is used used and/or shared shared by both units.

3.0 Applicant's Use of the Generic Aging Aging- Lessons Learned Report Learned Report In preparing its LRA, the applicant applicant credited NUREG-1801, NUREG-1 801, Revision 1, "Generic Aging Lessons Lessons Learned (GALL)

(GALL) Report," dated September dated September 2005. The GALL GALL Report contains the staff's generic generic evaluation of the existing plant programs evaluation programs and documents documents the technical basis for determining determining where existing programs are adequate existing programs adequate without modification, modification, and where existing programs programs augmented for the period of extended operation.

should be augmented operation. The evaluation results documented in the GALL Report indicate that many of the existing programs GALL Report programs are adequate to manage manage the the aging effects effects for particular license license renewal SCs. The GALL Report Report also contains contains recommendations on specific areas for which existing programs recommendations programs should be augmentedaugmented for for license license renewal. An applicant may reference reference the GALL Report Report in its LRA to demonstrate demonstrate that its programs correspond programs correspond to those reviewed and approved approved in the report.

The purpose of the GALL Report is to provide a summary of staff-approved staff-approved AMPs to manage manage or monitor the aging aging of SCs SOs subject to an AMR. If If an applicant commits commits to implementing implementing these these staff-approved staff-approved AMPs, the time, effort, and resources for LRA review will be greatly reduced, improving the efficiency efficiency and effectiveness effectiveness of the license renewal review process. The GALL Report also serves serves as a quick reference for applicants reference applicants and staff reviewers reviewers to AMPs and determined will adequately manage activities that the staff has determined manage or monitor aging during the the period of extended extended operation.

operation.

GALL Report identifies:

The GALL identifies: (1) SSCs, (2) (2) SC materials, materials, (3) environments environments to which the SCs SOs are exposed, (4) the aging aging effects of the materials materials and environments, (5) (5) the AMPs credited with managing or monitoring monitoring the aging effects, and (6) recommendations recommendations for further applicant applicant evaluations evaluations of aging management management for certain component types.

component 3-1

To determine whether use of the GALL Report would improve improve the efficiency of LRA review, review, the the conducted a demonstration staff conducted demonstration of of the the GALL Report Report process process in order to to model the format and evaluations based on content of safety evaluations on it.

it. The results results of the demonstration demonstration project confirmed GALL Report process will improve the efficiency that the GALL efficiency and effectiveness effectiveness of LRA review review while while maintaining the staff's focus on public health and safety. NUREG-1800, maintaining NUREG-1800, Revision 1, "Standard"Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" Review Plants" (SRP-LR),

dated September 2005, was prepared based on both the GALL Report model and lessons lessons learned from the demonstration learned demonstration project.

staff 's review was in The staff's in accordance accordance with Title 10, Part 54, of the Code of Federal FederalRegulations Regulations (10 CFR Part 54), "Requirements for Renewal of Operating Licenses for Nuclear Power Plants,"

(10 and the guidance guidance of the SRP-LR and the GALL Report.

In addition to its review of the LRA, the staff conducted an onsite audit of associated associated AMPs, during the week of March March 3-7, 2008. The onsite audits and reviews are designed for maximum maximum efficiency staff s LRA review. The applicant can respond to questions, the staff can readily efficiency of the staff's evaluate evaluate the applicant's responses, the need for formal correspondence correspondence between the staff and the applicant is reduced, and the result is an improvement in review efficiency.

3.0.1 Format of the License Renewal Renewal Application The applicant applicant submitted an application that follows the standard LRAformat LRA format agreed to by the the staff and the Nuclear Energy Institute (NEI) (NEI) by letter dated April 7, 2003. This revised LRA format incorporates incorporates lessons learned from the staff's reviews of the previous five LRAs, which used aa format developed developed from information gained staff-NEI demonstration gained during a staff-NEI demonstration project conducted conducted to evaluate the use of the GALL Report in the LRA review LRA review process.

The organization organization of LRA Section 3 parallels parallels that of SRP-LR SRP-LR Chapter Chapter 3. LRA Section Section 3 presents presents AMR results information in the followingfollowing two table types:

(1) Table 1s: ls: Table 3.x.1 -where

-where "3" indicates the LRA Section number, "x" indicates the the subsection subsection number from the GALL Report, and "1" "1" indicates indicates that this table type is thethe first in LRA Section 3.

(2)

(2) Table Table 2s: Table 3.x.2-y - where "3" indicates indicates the LRA Section Section number, "x" indicates indicates the the subsection subsection number from the GALL Report, "2" indicates that this table type is the second in LRA LRA Section 3, and "y" indicates indicates the system table number.

The content content of the previous previous LRAs LRAs and application is essentially and of the BVPS application essentially the same. TheThe intent intent of the revised format of the LRA for BVPS was to modify the tables in LRA Section 3 to provide additional provide additional information that would assist in the staff's review. In its Table Table 1s, 1s, the applicant applicant summarized summarized the portions of the application application that it considered to be consistent with the GALL Report. In In its Table Table 2s, the applicant identified identified the linkage between between the scoping scoping and screening results results in LRA LRA Section 2 and the the AMRs in LRA Section Section 3.

3.0.1.1 3.0.1.1 Overview of Table 1s Is Each Each Table 1 compares compares in summary summary how how the facility aligns aligns with the corresponding corresponding tables tables in the the GALL GALL Report. The tables tables are are essentially essentially thethe same same as Tables Tables 1 through through 66 in the GALL GALL Report, 3-2 3-2

"Type" column has been replaced by except that the "Type" by an "Item Number" column and and the "Item"Item Number Number in GALL" column has been replaced replaced by a "Discussion" "Discussion" column. The "Item Number" Number" column is is aa means for the staff reviewer reviewer to cross-reference cross-reference Table 2s with Table Table 1is.

s. In thethe "Discussion" column the applicant provided clarifying information.

"Discussion" information. The following are examples of information that might be contained within this column:

" evaluation recommended further evaluation recommended - information or reference reference to where that information is located

• plant-specific program The name of a plant-specific

• • exceptions to GALL Report assumptions exceptions assumptions

• discussion of how the line is is consistent with the corresponding corresponding line item in the GALL Report when the consistency consistency may not not be obvious obvious

• discussion of how the item is different different from the corresponding line item in the GALL Report (e.g., when an exception exception is taken to a GALL Report AMP)

The format of each Table 1 allows the staff to align a specific row in the table with the the corresponding corresponding GALL Report table row so that the consistency can be checked checked easily.

Overview of Table 3.0.1.2 Overview Table 2s Each Table 2 provides the detailed results of the AMRs for components identified identified in LRA Section 2 as subject to an AMR. The LRA has a Table 2 for each of the systems or structures structures within a specific system grouping (e.g., (e.g., reactor coolant coolant system system (RCS), engineered engineered safety features (ESF), auxiliary auxiliary systems, etc.). For example, the ESF group group has tables specific to the the containment spray system, containment isolation system, and emergency emergency core cooling system. system.

Each Table 2 consists of nine columns:

Component Type - The first column lists LRA Section 2 component types subject to an Component Type - The first column lists LRA Section 2 component types subject to an AMR in alphabetical order.

• • Intended Function - The second column identifies the license renewal intended functions, including including abbreviations, abbreviations, where applicable, applicable, for the listed component component types.

Definitions and and abbreviations abbreviations of intended functions are in LRA Table 2.0-1. 2.0-1.

" Material - The third column lists the particular construction Material- construction material(s) material(s) for the component component type.

• Environment - The fourth column lists Environment lists the environments environments to which the component component types types are are exposed. Internal and external service service environments environments are indicated indicated with a listlist of these these environments environments in LRA Tables 3.0-1, Tables 3.0-1,3.0-2,3.0-2, and 3.0-3.

"

• Aging Effect Requiring Aging Effect Requiring Management Management - The fifth column column lists aging aging effects requiring effects requiring management management (AERMs). As part of the AMR AMR process, the applicant determined determined any AERMs AERMs for each each combination combination of material material and and environment.

" Aging Management Management Programs Programs - The sixth sixth column column lists lists the AMPs AMPs that the applicant applicant uses uses to manage manage the identified identified aging effects.

NUREG-1 NUREG-1801 801 Volume Volume 22 Item Item - The The seventh seventh column column lists the GALL GALL Report Report item(s) item(s) identified in identified the the LRA as similar to the AMR results.

AMR results. The applicant applicant compared each compared each 3-3 3-3

combination of component type, material, combination material, environment, environment, AERM, and AMP in LRA Table 2 with the GALL ReportReport items. If If there are no corresponding corresponding items items in the GALL Report, the the applicant leaves leaves the column column blank in order to identifyidentify the AMR results in the LRA tables tables corresponding to the items in the GALL Report corresponding Report tables.

Table 1 Item Item - The eighth column column lists the corresponding corresponding summary item number number from LRA Table 1. If If the applicant identifies identifies in each LRA Table 2 AMR results consistent with the GALL GALL Report, the Table 1 line item summary number number should be listed in LRA Table 2. IfIf there is no corresponding item in the GALL Report, column eight is left blank.

In this In manner, the this manner, the information information fromfrom the the two two tables can be correlated.

Notes - The ninth column lists the corresponding corresponding notes used to identify how the the information information in each Table 2 aligns with the information information in the GALL GALL Report.

Report. The notes, identified identified by letters, were developed developed by an NEI work group group and will be used in future future LRAs. Any plant-specific identified by numbers plant-specific notes identified numbers provide additional information information about about the consistency consistency of the line item with the GALL Report.

3.0.2 Staff's 3.0.2 Staffs Review ProcessProcess The staff conducted evaluations of the AMRs and AMPs:

conducted three types of evaluations (1) For items that the applicant has stated were consistent with the GALL Report, the staff staff conducted conducted either an audit or a technical review to determine determine consistency.

(2) For items that the applicant has stated were consistent with the GALL Report with with exceptions, enhancements, or both, the staff conducted exceptions, enhancements, conducted either an audit or aa technical review of the item to determine consistency. In addition, the staff conducted either an audit or a technical review of the applicant's applicant's technical justifications for the exceptions technical justifications exceptions or the adequacy of the enhancements.

enhancements.

The SRP-LR SRP-LR states that an applicant applicant may take one or more more exceptions to specific GALL AMP elements; however, any deviation from or exception exception to the GALL AMP should be be described described and justified. Therefore, the staff considers considers exceptions exceptions as being portions of the the GALL AMP that the applicantapplicant does not intend to implement.

In some cases, an applicant applicant may choose an existing plant program program that does not meet all the program elements defined elements defined in the GALL AMP. However, the applicant applicant may make a commitment commitment to augmentaugment the existing program to satisfy the GALL AMP prior to the the period extended operation.

period of extended operation. Therefore, Therefore, the staff considers these augmentations augmentations or additions to be enhancements. Enhancements include, but are not limited to, activities enhancements. Enhancements activities needed needed to ensure consistency with the GALL Report recommendations. Enhancements Report recommendations. Enhancements may expand, but not reduce, the scope of an AMP.

(3) For other items, the staff conducted conducted aa technical technical review review to verify conformance conformance with 10 CFR 54.21(a)(3) 54.21(a)(3) requirements.

Staff audits and technical technical reviews of the applicant's applicant's AMPs and AMRs determine determine whether the the aging effects on SCs can be adequately adequately managed managed to maintain maintain their intended function(s) consistent with the plant's CLB for the period of extended consistent extended operation, as required by 10 CFR Part 54.

3-4 3-4

3.0.2.1 Review of AMPs 3.0.2.1 For AMPs for which the applicant applicant claimed consistency with the GALL GALL AMPs, the staff conducted conducted either an audit audit or a technical review to verify the claim.

claim. For each AMP with one or more more deviations, evaluated each deviation to determine deviations, the staff evaluated determine whether the deviation deviation was was acceptable and whether the modified AMP would adequately acceptable adequately manage effect(s) for manage the aging effect(s) which it was credited.

credited. For AMPs not evaluated evaluated in the GALL GALL Report, the staff performed a full review to determine determine their adequacy. The staff evaluated the AMPs against the following following 10 program program elements elements defined in SRP-LR Appendix Appendix A.

(1) Scope of the Program - Scope Scope of the program should include the specific SCs subject subject to an AMR for license renewal.

(2)

(2) Preventive Actions Preventive actions should prevent or mitigate aging Actions - Preventive degradation.

aging degradation.

(3)

(3) Parameters Monitored or Inspected Parameters Monitored Parameters monitored Inspected - Parameters monitored or inspected inspected should be be linked to the degradation degradation of the particular particular structure or component component intended intended function(s).

function( s).

(4) Detection of Aging Aging Effects Effects - Detection Detection of aging aging effects should occur beforebefore there is a loss of structure structure or component component intended intended function(s). This includes includes aspects such as method method or technique technique (i.e.,

(Le., visual, volumetric, surface surface inspection), frequency, samplesample size, data collection, and timing of new/one-time new/one-time inspections to ensureensure timely detection detection of aging effects.

(5) Monitoring Monitoring and trending should provide Monitoring and Trending - Monitoring provide predictability of the the extent degradation, as well as timely corrective or mitigative actions.

extent of degradation, (6)

(6) Acceptance Criteria - Acceptance Acceptance Acceptance criteria, against against which the need for corrective action action evaluated, should ensure that the structure will be evaluated, structure or component intended function(s) are maintained under maintained under all CLB design conditions during the period of extended extended operation.

operation.

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

(8)

(8) Confirmation Confirmation process Confirmation Process - Confirmation process should ensure that preventive preventive actions are are adequate and that appropriate adequate appropriate corrective actions actions have been completed completed and are effective.

(9) Administrative Controls - Administrative Administrative Administrative controls should provide for a formal review and approval approval process.

(10)

(10) Operating Experience - Operating Operating experience experience of the AMP, including past corrective corrective actions resulting resulting in program enhancements enhancements or additional programs, should provide provide objective evidence objective evidence to support the conclusion that the effects of aging aging will be adequately adequately managed managed so that the SC intended intended function(s) will be maintained during the period period of extended operation.

evaluation of program elements (1)

Details of the staffs audit evaluation documented in (1 ) through (6) are documented SER Section 3.0.3.

The staff staff reviewed the applicant's applicant's quality quality assurance assurance (QA) program and documented documented its its evaluations evaluations in SER Section 3.0.4. The staffs staffs evaluation evaluation of the QA program includedincluded assessment assessment of the "corrective "corrective actions," "confirmation process," and "administrative controls" program program elements.

3-5 3-5

The staff reviewed the information information on the "operating experience" program program element and documented its evaluation evaluation in SER Section 3.0.3.

3.0.2.2 Review of AMR AMR Results Each LRA Table 22 contains concerning whether or not the AMRs identified contains information concerning identified by thethe applicant align with the GALL Report AMRs. For a given AMR in aa Table 2, the staff reviewed reviewed the intended function, function, material, environment, AERM, and AMP combination combination for a particular particular system component component type. Item numbers numbers in column seven of the LRA, "NUREG-1801 Volume 2 "NUREG-1801 Item," correlate correlate to an AMR combination as identified in the GALL Report. The staff also AMR combination conducted onsite audits conducted audits to verify these correlations. A blank in column column seven indicates indicates that the the applicant was unable to identify identify an appropriate correlation in the GALL appropriate correlation GALL Report. The staff also conducted combinations not consistent with the GALL Report. The next conducted a technical review of combinations column, "Table 1 Item," refers to a number number indicating the correlating correlating row in Table Table 1. 1.

3.0.2.3 UFSAR 3.0.2.3 UFSAR Supplement SRP-LR for the AMRs and AMPs that it reviewed, the staff also reviewed Consistent with the SRP-LR Consistent the updated final safety analysis report (UFSAR) (UFSAR) supplement, which applicant's which summarizes the applicant's programs and activities programs activities for managing aging effects for the period of extended managing aging extended operation, operation, as as required by 10 CFR 54.21(d).

54.21 (d).

3.0.2.4 Documentation Documentation and Documents Documents Reviewed Reviewed In its review, the staff used the LRA, LRA supplements, the SRP-LR, and the GALL Report.

During the onsite audit, the staff also examined During examined the applicant's justifications justifications to verify that thethe applicant's activities programs will adequately manage the effects of aging activities and programs aging on SCs. The The staff also conducted detailed discussions conducted detailed discussions and interviews interviews with the applicant's applicant's license license renewal project personnel and others with technical technical expertise relevant relevant to aging management.

Management Programs 3.0.3 Aging Management Programs SER Table 3.0.3-1 3.0.3-1 presents the AMPs credited by the applicant and described described in LRA Appendix B. The table also indicates the SSCs that credit the AMPs and the GALL AMP with Appendix with which the applicant claimed consistency and shows the Section of this SER SER in which the staff's staff's evaluation evaluation of the program is documented.

Table 3.0.3-1 3.0.3-1 BVPS Aging Management Management Programs Programs AMP New or GALL GALL Report GALL LRA Systems Systems or Structures Staff's Staff's (LRA Section)

(LRASection) Existing Comparison Comparison Report Report That Credit the AMP SER Section AMP AMPs AMPs 10 10 CFR Part 50, Existing Consistent Consistent XI.S4 containments, containments, structures, and 3.0.3.1.1 3.0.3.1.1 Appendix Appendix J Program Program component supports supports (B.2.1)

(8.2.1) I_ _ _ _

3-6 3-6

AMP New New or GALL GALL Report Report GALL LRA Systems or Structures Staff's Staff's (LRA (LRA Section) Existing Comparison Comparison Report That That Credit the AMP SER Section Section AMP AMPs AMPsSection XI ASME Section X1 Existing Existing Consistent with XI.M1 reactor vessel, reactor vessel 3.0.3.2.1 Inservice Inservice Inspection, Inspection, exceptions internals, and reactor reactor coolant coolant Subsections Subsections IWB, IWB, system

IWC, IWC, and IWDIWD Program Program (B.2.2)

(B.2.2)

ASME Section XI, XI, Existing Consistent Consistent with XI.S1 containments, structures, and 3.0.3.2.2 3.0.3.2.2 Subsection Subsection IWE exceptions exceptions supports component supports Program (B.2.3)

ASME Section XI, XI, Existing Existing Consistent with XI.S3 containments, structures, and 3.0.3.2.3 Subsection Subsection IWF exceptions exceptions component supports component supports Program (B.2.4)

ASME ASME Section XI, XI, Existing Existing Consistent XI.S2 containments, structures, and containments, 3.0.3.1.2 3.0.3.1.2 Subsection IWL Subsection component component supports supports Program (B.2.5)

Bolting Integrity Integrity Existing Existing Consistent XI.M18 vessel, reactor vessel reactor vessel,.reactor 3.0.3.1.3 3.0.3.1.3 Program Program intemals, intemals, and reactor reactor coolant coolant (B.2.6) system I/ engineered safety features /I auxiliary systems I steam steam and and power conversion conversion systems systems Boric Acid Corrosion Existing Consistent Consistent XI.M10 XI.M10 reactor vessel, reactor reactor vessel 3.0.3.1.4 3.0.3.1.4 Program internals, and reactor coolant intemals, coolant (B.2.7) system I/ engineered safety features /I auxiliary systems /I steam and steam and power conversion systems I/ containments, systems structures, and component component supports /I electrical and and instrumentation and controls instrumentation controls Buried Piping and New New Consistent with XI.M34 XI.M34 auxiliary auxiliary systems I/ steam and 3.0.3.1.5 3.0.3.1.5 Tanks Inspection Inspection exceptions exceptions power conversion conversion systems systems Program (B.2.8)

Closed-Cycle Cooling Closed-Cycle Existing Consistent with XI.M21 XI.M21 reactor vessel, reactor reactor vessel 3.0.3.2.4 3.0.3.2.4 Water System enhancements enhancements internals, and reactor reactor coolant coolant Program Program system I/ engineered safety (B.2.9) features /I auxiliary systems!I auxiliary systems steam and steam and power conversion conversion systems systems 3-7 3-7

AMP AMP New or GALL Report GALL Report GALL GALL Systems or LRA Systems or Structures Staff's Staffs (LRA Section) Existing Existing Comparison Comparison Report Report That Credit thethe AMP AMP SER Section SER Section AMP AMPs AMPs Electrical Cable Electrical New Plant-specific electrical and instrumentation instrumentation 3.0.3.3.1 Connections Not controls and controls Subject to 10 Subject 10 CFR 50.49 Environmental 50.49 Qualification Qualification Requirements One-Inspection Time Inspection Program (B.2.10)

(8.2.10)

Electrical Cables and New Consistent XI.E1 and instrumentation electrical and instrumentation 3.0.3.1.6 3.0.3.1.6 Connections Not Connections and controls controls Subject to 10 CFR 50.49 Environmental Qualification Requirements Requirements Program (B.2.11)

(8.2.11)

Electrical Cables and New Consistent XI.E2 instrumentation electrical and instrumentation 3.0.3.1.7 3.0.3.1.7 Connections Connections Not controls and controls Subject Subject to 1010 CFR 50.49 Environmental Qualification Qualification Requirements Used in Instrumentation Instrumentation Circuits Program Program (B.2.12)

(8.2.12)

Electrical Wooden New Plant-specific Plant-specific containments, containments, structures, and 3.0.3.3.2 3.0.3.3.2 Poles/Structures component component supports supports Inspection Program Program (Unit (Unit 2 only)

(B.2.13)

(8.2.13)

Environmental Environmental Existing Consistent X.E1 X.E1 electrical electrical and instrumentation instrumentation 3.0.3.1.8 3.0.3.1.8 Qualification Qualification (EQ)

(EQ) of and controls controls Electrical Components Components Program Program (B.2.14)

(8.2.14)

External Surfaces External Surfaces New Consistent XI.M36 XI.M36 reactor reactor vessel, vessel, reactor vessel 3.0.3.1.9 3.0.3.1.9 Monitoring Program Monitoring Program internals, and and reactor reactor coolant (B.2.15).

(8.2.15) system / engineered engineered safety features / auxiliary auxiliary systems systems I/

and power steam and power conversion conversion systems systems Fire Fire Protection Protection Existing Existing Consistent with with XI.M26 XI.M26 auxiliary systems systems / 3.0.3.2.5 3.0.3.2.5 Program Program exceptions exceptions and and containments, containments, structures, and (B.2.16)

(8.2.16) enhancements enhancements component component supports supports 3-8 3-8

AMP New or GALL GALL Report Report GALL LRA Systems or Structures Structures Staffs Staff's (LRA Section) Existing Existing Comparison Comparison Report Report That Credit the AMPAMP SER Section Section AMP AMPs AMPs Fire Water System Existing Consistent with XI.M27 XLM27 auxiliary systems 3.0.3.2.6 Program Program enhancements enhancements (B.2.17)

(8.2.17)

Flow-Accelerated Flow-Accelerated Existing Consistent Consistent XI.M17 XLM17 auxiliary auxiliary systems I/ steam and 3.0.3.1.10 3.0.3.1.10 Corrosion Corrosion Program power conversion conversion systems systems (B.2.18)

(8.2.18)

Flux Thimble Tube Existing Existing Consistent Consistent with XI.M37 XLM37 reactor vessel, reactor reactor vessel 3.0.3.2.7 3.0.3.2.7 Inspection Program Inspection enhancement enhancement internals, and reactor coolant coolant (B.2.19) system Fuel Oil Chemistry Existing Existing Consistent Consistent with XI.M30 XLM30 auxiliary systems systems 3.0.3.2.8 3.0.3.2.8 Program exceptions exceptions and and (B.2.20)

(B.2.20) enhancements enhancements Inaccessible Inaccessible New Consistent Consistent XI.E3 electrical and instrumentation instrumentation 3.0.3.1.11 3.0.3.1.11 Medium-Voltage Medium-Voltage and controls controls Subject Cables Not Subject to 10 10 CFR 50.49 Environmental Qualification Qualification Requirements Requirements Program (B.2.21)

(8.2.21)

Inspection of Internal Inspection Internal New Consistent XI.M38 engineered features/I engineered safety features 3.0.3.1.12 3.0.3.1.12 Surfaces in auxiliary auxiliary systems /I steam and Miscellaneous Piping Miscellaneous power conversion systems power conversion systems Ducting and Ducting Components Components Program (B.2.22)

(8.2.22)

Inspection of Inspection Existing Existing Consistent with XI.M23 containments, structures, and 3.0.3.2.9 3.0.3.2.9 Overhead Overhead Heavy Heavy enhancements enhancements component component supports supports Load and Light Load Load (Related (Related to Refueling) Handling Refueling) Handling Systems Program Program (B.2.23)

(8.2.23)

Lubricating Oil Existing Consistent XI.M39 XI.M39 auxiliary auxiliary systems /I steam steam and 3.0.3.1.13 3.0.3.1.13 Analysis Program conversion systems power conversion systems (B.2.24)

Masonry Masonry Wall Existing Consistent with XI.S5 containments, structures, and 3.0.3.2.10 3.0.3.2.10 Program Program enhancement enhancement component supports supports (B.2.25) I III Metal Enclosed Bus Metal Enclosed New Consistent XI.E4 XI.E4 electrical electrical and instrumentation instrumentation 3.0.3.1.14 3.0.3.1.14 Program Program (Unit (Unit 2 only) and controls controls (B.2.26) 3-9 3-9

AMP New New or GALL Report Report GALL GALL LRA Systems or Structures Staffs Staffs (LRA (LRA Section)

Section) Existing Comparison Report Report That That Credit the AMP SER Section AMP AMPs AMPs Metal Fatigue of MetalFatigue Existing Existing Consistent Consistent X.M1 X.M1 reactor vessel, reactor vessel vessel 3.0.3.1.15 3.0.3.1.15 Reactor Coolant Reactor internals, and reactor reactor coolant Pressure 80undary Boundary system I engineered safety Program features features /I auxiliary systems I/

(B.2.27)

(8.2.27) steam and power power conversion conversion systems systems Nickel-Alloy Nickel-Alloy Existing Existing Consistent Consistent XI.M11A XI.M11A reactor vessel, reactor vessel 3.0.3.1.16 3.0.3.1.16 Penetration Nozzles Penetration Nozzles internals, and reactor coolant coolant Welded Welded to the Upper Upper system Reactor Vessel Closure Heads Closure Heads Program (B.2.29)

(8.2.29)

One-Time Inspection One-Time Inspection New New Consistent Consistent XI.M32 reactor vessel, reactor vessel 3.0.3.1.17 3.0.3.1.17 Program Program internals, and reactor coolant coolant (B.2.30)

(8.2.30) system /I engineered engineered safety features I/ auxiliary systems /I features steam and power conversion systems systems One-Time One-Time Inspection Inspection New New Consistent XI.M35 reactor vessel, reactor reactor vessel 3.0.3.1.18 3.0.3.1.18 of ASME internals, and reactor coolant coolant Code Code Class 1 Small system Bore 80re Piping Program (B.2.31)

(8.2.31 )

Open-Cycle Open-Cycle Cooling Cooling Existing Existing Consistent Consistent XI.M20 engineered safety safety features /I 3.0.3.1.19 3.0.3.1.19 Water System auxiliary systems auxiliary systems /I steam steam and Program power conversion systems power. systems (B.2.32)

(8.2.32)

Reactor Reactor Head Head Existing Existing Consistent Consistent with Xi.M3 XI.M3 reactor vessel, reactor vessel 3.0.3.2.11 3.0.3.2.11 Closure Studs exceptions exceptions internals, and reactor coolant Program Program system (B.2.34)

(8.2.34)

Reactor Reactor Vessel Existing Plant-specific reactor vessel, reactor reactor vessel 3.0.3.3.4 3.0.3.3.4 Integrity Integrity Program internals, and reactor coolant coolant (B.2.35)

(8.2.35) system Selective Leaching Leaching of New Plant-specific Plant-specific auxiliary systems I/ steam and 3.0.3.3.6 Materials Inspection MaterialS power conversion systems systems Program Program (B.2.36)

(8.2.36)

Settlement Existing Plant-specific Plant-specific containments, containments, structures, structures, and 3.0.3.3.5 Monitoring Program Monitoring Program component supports component supports (Unit (Unit 22 only)

(B.2.37)

(8.2.37)

Steam Generator Generator Existing EXisting Consistent Consistent XI.M19 XI.M19 reactor vessel, reactor vessel 3.0.3.1.21 Tube Integrity internals, and reactor coolant reactor coolant Program system (B.2.38)

(8.2.38) 3-10 3-10

AMP New New or GALL GALL Report GALL GALL LRA Systems Systems or Structures Staff's Staffs (LRA (LRA Section) Existing Comparison Comparison Report That Credit the AMP SER Section AMP AMPs AMPs Structures Monitoring Existing Consistent with XI.S6 containments, structures, and containments, 3.0.3.2.12 3.0.3.2.12 Program enhancements enhancements component supports I/

component (B.2.39) electrical and instrumentation instrumentation and controls controls Thermal Aging New Consistent Consistent XI.M12 reactor vessel, reactor vessel 3.0.3.1.23 3.0.3.1.23 Embrittlement Embrittlement of Cast internals, and reactor coolant Austenitic Stainless system I/ auxiliary systems I/

Steel (CASS) conversion steam and power conversion Program systems systems (B.2.41))

(B.2.41 Water Chemistry Chemistry Existing Existing Consistent Consistent with XI.M2 reactor reactor vessel reactor vessel, reactor 3.0.3.2.13 3.0.3.2.13 Program enhancement enhancement internals, and and reactor reactor coolant coolant (B.2.42) system I/ engineered engineered safety features I/ auxiliary systems I/

auxiliary systems steam and power power conversion systems I/ containments, structures, and component supports supports BoralSurveillance Boral Surveillance New Plant specific Unit 1 Spent Fuel Pool 3.0.3.3.7 3.0.3.3.7 Program (B.2.43)

(B.2.43) 3.0.3.1 Consistentwith the GALL 3.0.3.1 AMPs Consistent GALL Report In LRA Appendix B, the applicant identified the following AMPs as consistent consistent with the GALL Report:

• 10 CFR Part 50, Appendix J Program

• ASME Section Section XI, XI, Subsection Subsection IWL Program

• Bolting Integrity Integrity Program

• Boric Acid Corrosion Program

• Buried Piping and Tanks Inspection Program Program

• Electrical Cables Cables and Connections Not Subject to 10 CFR 50.49 50.49 Environmental Qualification Requirements Qualification Requirements Program Program Electrical Cables and Connections Electrical Connections Not Subject to 10 CFR 50.49 50.49 Environmental Qualification Requirements Qualification Instrumentation Circuits Program Requirements Used in Instrumentation

• Environmental Qualification Environmental Qualification (EQ)

(EQ) of Electrical Components Components Program Program

• External External Surfaces Monitoring Program Surfaces Monitoring

• Flow-Accelerated Corrosion Program Flow-Accelerated

• Inaccessible Medium-Voltage Inaccessible Medium-Voltage Cables Not Subject Subject to 10 CFR 50.49 Environmental Qualification Requirements Qualification Requirements Program 3-11 3-11

Inspection of Internal Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program .

" Lubricating Oil Analysis Program Program

• Metal Enclosed Bus Program Metal Program (Unit (Unit 2 only)

" Metal Fatigue of Reactor Metal Reactor Coolant Pressure Boundary Boundary Program

• Nickel-Alloy Penetration Nozzles Nickel-Alloy Nozzles Welded to the UpperUpper Reactor Vessel Closure Heads Heads Program

• One-Time Inspection One-Time Inspection Program Program

• Inspection of ASME Code Class 1 Small Bore Piping Program One-Time Inspection

• Open-Cycle Cooling Water System Program Open-Cycle Program

• PWR Vessel Internals Program Vessel Internals Program

• Generator Tube Integrity Steam Generator Integrity Program Program

• Thermal Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel Neutron Irradiation Embrittlement (CASS) Program Thermal Aging Embrittlement Embrittlement of Cast Austenitic Austenitic Stainless Steel (CASS) Program Program 3.0.3.1.1 10 CFR Part 50, Appendix Appendix J Program Technical Information Summary of Technical Information in the Application.

Application. In LRA Section B.2.1, B.2.1, the applicant applicant describes describes the existing 10 CFR Part 50, Appendix J Program as consistent with GALL AMP XI.S4, "10 CFR 50, Appendix J." The applicant uses Option B, the performance-based performance-based approach, to approach, to implement the requirement implement the requirement of containment leak of containment leak rate rate monitoring monitoring and and testing.

The 10 CFR 50, Appendix Appendix J Program monitors leakage rates through the containment monitors leakage containment pressure boundary, including penetrations penetrations and access access openings. Containment Containment leak rate tests assure that leakage through the primary containment and systems and components primary containment components penetrating penetrating primary containment exceed acceptance containment does not exceed acceptance criteria limits.

Staff Evaluation. During the audit, the staff interviewed the applicant's applicant's technical staff and and audited its 10 CFR Part Part 50, Appendix Appendix J Program onsite basis documents documents to determine the determine the consistency with GALL AMP XI.S4. Specifically, consistency Specifically, the staff reviewed the program elements and associated onsite documents associated documents and found that they are consistent with the GALL AMP.

The staff noted that in 10 CFR Part 50, Appendix J Program, Program, the applicant applicant utilizes the utilizes Option B, the performance-based performance-based approach, approach, to implement implement the containment integrated leak rate test (ILRT).

containment integrated (ILRT).

The staff was aware aware that a temporary construction opening opening was created for the Unit 1 steam generator generator (SG) and reactor head replacements replacements during refueling refueling outage (RFO)

(RFO) 17 17 (2006).

Inspections revealed degradation degradation from the inaccessible inaccessible side of steel liner for which the applicant applicant could not identify a root-cause, either from field observations or lab analysis. The staff further noted noted that since the relaxation of Option B ILRT ILRT frequency for 15 years is based on the risk impact impact assessment, the applicant incorporating the liner corrosion applicant must assess the risk impact, incorporating on the inaccessible inaccessible side, based on the 2006 2006 findings.

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In Request for Additional Information (RAI) B.2.1-1, Information (RAI) B.2.1-1, dated May 8,2008, 8, 2008, the staff requested that information relating to the risk impact of the liner corrosion the applicant provide information corrosion on the inaccessible inaccessible side, based on the 2006 findings.

In its response to RAI B.2.1-1, B.2.1-1, dated June June 16, 2008, the applicant stated that it had had included an evaluation of the risk of an unidentified through-wall leak in the containmentcontainment liner due to corrosion in the applicant's applicant's submittal submittal for a one-time 15-year interval in 2003, which was 15-year test interval was approved by the staff. The applicant further stated stated that the risk assessment assessment performed performed to evaluate the risk of extending the ILRT ILRT frequency, no longer applied following the 2006 ILRT, ILRT, and that Unit Unit 1 returned to the normal Option B ILRT frequency of once every 10 years.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.1-1 acceptable acceptable because because the current ILRT ILRT test interval returned to the normal interval interval in accordance guidance accordance with the guidance 94-01, as endorsed by Regulatory found in NEI 94-01, Regulatory Guide (RG) 1.163, for a frequency of once every 10 years, without extension. Therefore, the staff's concern described described in RAI B.2.1-1 is resolved.

The staff also noted that the applicant applicant must conduct a visual examination examination of accessible accessible interior interior and exterior surfaces surfaces of the containment containment system, prior to initiating an ILRT. The staff further noted that the purpose examination is to detect and repair, if necessary, structural purpose of the visual examination before an ILRT is performed, since steel liner degradation degradation before degradation may exist on the the inaccessible inaccessible side at Units 1 and 2.

In RAI B.2.1-2, dated May 8, 2008, the staff requested requested that the applicant applicant provide information information how it addressed addressed possible possible degradation on the outside of the liner during the ILRT pretest procedure.

In a letter dated June 16, 2008, in response to RAI B.2.1-2, the applicant explained that two June 16, additional requirements requirements were incorporated incorporated into the containment inspection procedures containment inspection procedures as aa result of the liner corrosion corrosion found in 2006: (1) When paint or coatings are to be removed removed for for inspection, the paint or coatings shall be visually examined further inspection, examined by a qualified VT-3 inspector prior to removal, removal, and (2)

(2) If If the visual examination detects surface flaws on the liner or suspect areas on the liner plate that could potentially potentially impact the leak tightness or structural integrity integrity of the liner, then surface or volumetric examinations shall be performed to characterize volumetric examinations characterize thethe condition (i.e., depth, size, shape, orientation). The applicant also stated stated that evidence of structural deterioration deterioration which may affect either the containment containment structural structural integrity or leak-tightness is entered entered into the FENOC Corrective Action Program. Program.

Based on its review, the staff finds the applicant's response response to RAI B.2.1-2 acceptable because because the applicant's implementation applicant's implementation of the above-mentioned additional requirements above-mentioned additional requirements during the the subsequent inspections, as well as the ILRT will provide assurance that the containment liners at BVPS will continue to perform their intended intended functions for the period of extended extended operation.

concern described Therefore, the staff concern described in RAI B.2.1-2 is resolved.

resolved.

Operating Experience. The staff also reviewed reviewed the operating operating experience, including including samples samples of condition reports, and interviewed interviewed the applicant's technical applicant's technical staff to confirm that the plant-specific plant-specific operating experience experience did not reveal any degradation degradation not bounded bounded by industry experience.

experience. The The staff noted that there were no instances of Appendix Appendix J test failures due to causes causes other than valve or flange seat leakage. For these failures, all conditions were evaluated and corrected. corrected.

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The staff confirmed that the operating experience experience program element satisfies the criterion defined in the GALL GALL Report and in SRP-LR SRP-LR Section A. o. The staff finds this program 1.2.3.10.

A.1.2.3.1 element acceptable.

UFSAR UFSAR Supplement. In LRA Section A.1.1, A.1.1, the applicant provided the UFSAR supplement supplement for the 10 CFR 50 Appendix J Program.

Program. The staff reviewed this Section and determines determines that the the information information in the UFSAR UFSAR supplement adequate summary description supplement is an adequate description of the program, as as required by 10 CFR 54.21(d).

Conclusion.

Conclusion. On the basis of its review of the applicant's applicant's 10 CFR Part 50, Appendix J Program and additional information provided information provided in the applicants applicants RAI responses, the staff finds all program program elements consistent with the GALL GALL Report. The staff concludes concludes that the applicant applicant has has demonstrated that the effects demonstrated effects of aging will be adequately adequately managed managed so that the intended intended functions will be maintained maintained consistent consistent with the CLB for the period of extended extended operation, operation, asas required 54.21 (a)(3). The staff required by 10 CFR 54.21(a)(3). staff also reviewed the UFSAR supplement for this this AMP and determines determines that it provides an adequate summary description description of the program, program, as as required by 10 CFR 54.21(d).

3.0.3.1.2 ASME Section 3.0.3.1.2 Section XI, XI, Subsection Subsection IWL Program Summary of Technical Summary Information in the Application. In LRA Section Technical Information Section B.2.5, the applicant applicant described the existing ASME Section XI, Subsection described Subsection IWL Program Program as consistent with GALL GALL XI.S2, "ASME Section XI, Subsection AMP XLS2, Subsection IWL."

The ASME Section XI, Subsection Subsection IWL Program consists of periodic IWL Program inspections of the periodic visual inspections the reinforced concrete containment structures reinforced concrete containment structures for Units 1 and 2.

Evaluation. During its audit, the staff interviewed Staff Evaluation. interviewed the applicant's applicant's technical staff and audited applicant's ASME Section XI, Subsection IWL Program onsite basis documents to the applicant's determine their consistency with GALL AMP XI.S2.

determine XLS2. Specifically, the staff reviewed the program elements and associated associated onsite documents documents and found that they are consistent with the GALL AMP. Based Based on its review, the staff concluded that the applicant'sapplicant's ASME ASME Section Section XI, Subsection Subsection IWL Program Program provides assurance assurance that the reinforced concrete containment containment structures adequately managed. The staff finds the applicant's structures will be adequately applicant's ASME ASME Section Section XI, Subsection IWL Program Subsection acceptable because Program acceptable because it conforms to the recommended recommended GALL AMP XI.S2.

XLS2.

Operating Experience.

Experience. The staff reviewed reviewed the operating operating experience, experience, including samples samples of condition reports, and interviewed interviewed the applicant's applicant's technical technical staff to confirm that the plant-specific plant-specific operating experience did not reveal any degradation bounded by industry experience. In the degradation not bounded the LRA, the applicant applicant explained that the operating experience operating experience of the ASME Section XI, Program activities Subsection IWL Program activities shows no adverse adverse trend of containment containment performance.

inspections for Units 1 and 2 have identified Previous IWL inspections identified minor issues such as mildew and rust stains, spalling, spalling, surface cracks, and loose foreign materials.

materials. The applicant documented and applicant documented tracked tracked inspection findings using the Corrective Corrective Action Program, which also detailed detailed the the corrective action(s) taken to mitigate the conditions. The applicant periodic applicant established periodic containment containment concrete concrete IWL inspections inspections in which which all accessible accessible external surfaces surfaces of the the containment buildings containment buildings are visually inspected inspected every 5 years for the duration of plant operation in in accordance accordance with its IWL AMP.

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On April 23, 2009, during aa Unit 1 IWE inspection, 23,2009, inspection, a paint blister was discovered on the the containment liner. Further investigation revealed through-wall through-wall corrosion of the containment containment liner.

The liner defect was associated with the presence of a piece of wood embedded in the concrete concrete directly directly behind the liner. In In response to this operating experience, by letter dated operating experience, dated May 7, 2009, B.2.5-1, requesting the applicant the staff issued RAI B.2.5-1, applicant explain whether or not the concrete or Or rebar behind the flaw was degraded. The RAI also asked asked the applicant to explain explain how the recent plant-specific operating experience plant-specific experience would be incorporated incorporated into the ASME Section Section XI,XI, Subsection Subsection IWL AMP.

In its response, dated dated June 1, 2009, the applicant stated stated that the exposed concrete was not degraded and no structural rebars were affected. The concrete degraded concrete behind the liner contained a small void associated associated with the volume of the embedded embedded wood. The applicant explained that applicant explained some concrete immediately immediately around the wood was removed in order order to remove the wood. This This concrete concrete void was repaired repaired with grout prior to replacement replacement of the liner section. The response response further stated that no enhancement enhancement to the AMP was needed needed and no plant-specific plant-specific program was was required. During required. During the removal removal of the wood, a a section of vertical rebar was encountered, encountered, but based on the location and orientation orientation itit was determined determined to be a non-structural non-structural member member used in in forming the rebar skeleton during the original concrete pour.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.3-5 acceptable acceptable because because it demonstrates demonstrates that the applicant reviewed reviewed the impact of the recent plant-specific plant-specific operating operating experience on their IWL Program. The condition of the exposed experience exposed rebar, as well as existing IWL IWL operating operating experience, provides reasonable assurance reasonable assurance that the existing program will capture capture aging effects effects of concrete during the period of extendedextended operation.

The staffs operating experience review concludes that that applicant's administrative operating experience controls administrative controls are effective in detecting detecting age-related degradation and initiating corrective age-related degradation corrective action. The staff did did not identify any age related issues not boundedbounded by the industry operatingoperating experience.

experience. The staff staff confirmed confirmed that the operating experience program operating experience program element element satisfies the criterion criterion defined in the the GALL Report and in SRP-LRSRP-LR Section A. 1.2.3.10.

A.1.2.3.1 O. The staff finds this program element acceptable.

acceptable.

UFSAR Supplement. In LRA Section A.1.5, the applicant provided the UFSAR supplement supplement for for the ASME Section XI, Subsection IWL Program. The staff reviewed reviewed this Section and determines determines that the information in the UFSAR UFSAR supplement is an adequate adequate summary summary description description of the the

program, program, as required required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's Conclusion. applicant's ASME ASME Section XI, Subsection IWL Program, the staff finds all program elements consistent with the GALL Report. The staff staff concludes that the applicant has demonstrated demonstrated that the adequately the effects of aging will be adequately managed so that the intended managed intended functions will be maintained maintained consistent with the CLB for the the period of extended extended operation, as required by 10 CFR 54.21(a)(3).

54.21(a)(3). The staff staff also reviewed reviewed the the UFSAR supplement supplement for this AMP and concludes concludes that it provides provides an adequate adequate summary description description of the program, program, as required by 10 10 CFR 54.21 54.21(d).

(d).

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3.0.3.1.3 Bolting Integrity 3.0.3.1.3 Integrity Program Summary Summary of Technical Technical Information Information in the Application.

Application. In LRA Section B.2.6, the applicantapplicant describes describes the Bolting Integrity Program Program as consistent with the GALL AMP XI.M18, XI.M1B, "Bolting "Bolting Integrity." This program manages manages the effects of aging for bolting within the scope of license license

renewal, renewal, through periodic inspections, inspections, for indication of loss of preload, preload, cracking, and loss of material material due to corrosion.

The applicant applicant stated stated that program program inspections inspections are implemented through other AMPs AMPs including:

the ASME Section XI, Inspection, Subsections XI, Inservice Inspection, Subsections IWB, IWC, & & IWD Program; the ASME ASME Section Section XI, Subsection IWE Program;Program; the ASME Section Program; the Section XI, Subsection IWF Program; the Structures Monitoring Program; Structures Monitoring Program; and the External Surfaces Surfaces Monitoring Monitoring Program.

Program.

Staff Evaluation.

Evaluation. In the LRA, the applicant applicant stated stated that the Bolting Integrity Program .is is an existing existing program program that is consistent with GALL GALL AMP XI.M18.XI.M1B.

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

In comparing the 10 program elements in the applicant's program program to GALL AMP XI.M18, XI.M1B, the the staff found that the GALL GALL Report "monitoring and trending" program program element, requiring that the the leak rate be monitored on a defineddefined schedule, properly documented schedule, was not properly documented in the applicant's applicant's program.

bolting integrity program.

In RAI B.2.6-2, dated MarchMarch 26, 2008, 200B, the staff requested that the applicant provide additional applicant provide information information on its leak rate monitoring schedule.

In its response to RAI B.2.6.-2, dated April 25, 200B, 2008, the applicant stated that leaks related to to bolting, not covered by ASME ASME Section XI, are monitored monitored and corrected corrected using the FENOCFENOC Corrective Corrective Action Program. The applicant further further stated that itit relies upon this corrective action action program to determine determine the inspection frequency frequency and required response response in order to adequately adequately address the leak. However, the staff noted that the FENOC Corrective Corrective Action Program has no no specific requirements, checks, or limiting processesprocesses which would ensure that the inspection inspection frequency frequency does not decrease decrease to less than the biweekly recommendation in the GALL biweekly recommendation GALL Report.

Therefore, the staff determined that the applicant did not provide sufficient information to to address address the concerns raised in the staff's RAI B.2.6-2, and finds that the program is not consistent consistent with the GALLGALL Report "monitoring and trending" program element. The staff further determined determined that, pursuant to the guidance guidance in SRP-LR Section 3.1.2.1, 3.1.2.1, this inconsistency inconsistency shall documented as a staff-identified be documented staff-identified difference.

As described described above, the staff noted a difference difference in the Bolting Integrity Program that the the applicant identified as an exception to the GALL AMP XI.M1B.

applicant should have identified XI.M18. Additionally, the staff staff determined determined that although the applicant provides provides some justification justification for the difference difference in thisthis monitoring program element, the justification monitoring and trending program justification is not sufficient sufficient to justify the inclusion inclusion of this staff-identified staff-identified difference.

difference. During a teleconference teleconference on September September 26, 200B, 2008, the applicant applicant agreed to submit a supplement supplement to the original original RAI response to further addressaddress the issues raised by the staff.

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By letter dated October October 10,10, 2008, the applicant applicant provided provided additional justification justification for the staff- .

identified difference identified difference resulting from its previous response to RAI B.2.6-2. The applicant applicant stated that although although itit has no specific written guidance guidance that requires daily monitoring of identified identified leaks leaks in non-ASME non-ASME boltedbolted connections, leaks are managed by one of several several plant programs, each each of which classifies and assesses assesses the significance ofthe of the leakage. The applicant applicant also stated that in addition addition to the FENOC FENOC Corrective Action Program Program which manages manages leaks leaks that are classified as being "conditions adverse adverse to quality" through periodic monitoring and trending, itit also utilizes the the Leak Elimination Elimination Program. The applicant identifies daily rounds and walk-downs walk-downs performed by by operators, operators, maintenance, maintenance, and system engineersengineers as contributing contributing to the identification identification and monitoring of leaks.

Additionally, the applicant stated that leak repair prioritization determined through the Work prioritization is determined Management Process for Units 1 and 2, in accordance Management accordance with Institute for Nuclear Power Nuclear Power Operations (INPO)

(INPO) AP-928, "Work Management Management ProcessProcess Description," which which prioritizes prioritizes leak repairs based on work classification and significance significance (i.e.,

(i.e., system and operational operational significance).

significance).

Furthermore, the applicant applicant stated that the Leak Elimination Elimination Program for Units 1 and 2, performs performs monitoring and trending trending to ensure ensure that leaks which are not considered considered a "condition adverse adverse to quality" do not challenge challenge system or component functions.

supplement to its original response The staff reviewed the applicant's supplement response to RAI B.2.6-2, and determines that proper plant programsprograms are in place that address leakage of non-ASME address leakage non-ASME bolted bolted connections through the implementation implementation of monitoring, monitoring, trending, classification, classification, and prioritization prioritization processes. The clarification clarification helped helped the staff determine that the applicant's leakage leakage monitoring monitoring for non-ASME bolted connections demonstrates proper management connections demonstrates management of leakageleakage through robust programs which plant programs which meet the intent of the GALL Report "monitoring and trending" program program element. Based on its review, the staff finds the applicant's response to RAI B.2.6-2 acceptable B.2.6-2 acceptable and this staff-identified staff-identified difference difference to be acceptable. Therefore, Therefore, the staff's concern described described in RAI RAI B.2.6-2 is resolved.

In the LRA, the applicant applicant stated that loss of preload is not an AERM. AERM. The staff requested that that the applicant applicant justify its position in not managing managing the aging effect effect for loss of preload preload in RAI B.2.6-3, by letter dated May 8, 2008.

By letter dated dated June 9, 2008, the applicant applicant responded responded to RAI B.2.6-3, stating that it manages manages loss of preload through leakage monitoring leakage monitoring and proper installation and maintenance maintenance of the the components, since the loss of preload in a mechanical joint can result in leakage. The applicant applicant references Electric references Electric Power Research Research Institute (EPRI)

(EPRI) Report 10106039 which offers guidance on Report 10106039 loss of preload for bolted closures. The guidance guidance states that loss of preload preload in a mechanical joint does not result in failure of that joint. It can only result in limited leakage that does not boundary to the extent that the intended impact the pressure boundary intended function is not accomplished.

accomplished. In In addition, by letter dated August August 22, 2008, the applicant provided provided clarification that its Bolting Bolting Integrity Program addresses addresses all bolting.

bolting. With this change, the applicant's management management of loss of preload due to thermal effects, gasket gasket creep and self loosening loosening of steel closure bolting, will be be consistent consistent with the GALL Report Report and therefore is acceptable acceptable to the staff.

staff.

The staff also found that although although the applicant applicant claimed that its Bolting IntegrityIntegrity Program was was consistent consistent with the GALL AMP, an exception to the GALL Report Report "parameters monitored/inspected" monitored/inspected" program element applicant's claim of crack monitoring element exists in the applicant's monitoring of highhigh 3-17 3-17

strength strength bolts (actual yield strength ><:! 150150 ksi) used in nuclear nuclear steam supply system (NSSS) component component supports.

In RAI B.2.6-1, B.2.6-1, dated dated March March 26, 2008, the staff requested that the applicant provideprovide additional information on its use of high strength bolts.

In its response to RAI B.2.6-1, B.2.6-1, dated April 25, 2008, the applicant applicant stated that the technical basis technical basis for this issue addressed in the "detection of aging effects" program element issue is addressed element evaluation evaluation in its Bolting Integrity Integrity Program evaluation evaluation document.

document. Since Since the GALL Report "detection of aging effects" program program element element includes the option of waiving waiving volumetric examination examination of cracking of high strength bolts if adequate adequate justification is provided, provided, the applicant applicant provided justification justification in its program evaluation program evaluation document. The applicant's justification includes applicant's justification includes an evaluation evaluation on the the environments at Units 1 and 2 where environments high-strength structural bolting or threaded fasteners where high-strength fasteners are exposed, and whether stress-corrosion stress-corrosion cracking (SCC) is an applicable applicable aging effect for thosethose conditions. Based on these evaluations, the applicant stated that SCC was not identified identified as an AERM. BasedBased on a review of the applicant's justification, the staff applicant's completed evaluation and justification, staff finds the applicant's applicant's response response to be acceptable acceptable because itit is consistent with the the recommendations provided recommendations provided in GALL AMP X1.18.

XI. 18.

Operating Experience. The staff also reviewed Operating reviewed the operating experience experience reports, including including a interviewed the applicant's sample of condition reports, and interviewed applicant's technical technical staff to confirm confirm that thethe plant-specific operating plant-specific experience did not reveal any degradation operating experience degradation not bounded by industry experience. The staff did not find any evidence of operating experience not bounded by industry operating experience experience. A condition condition report indicated that in 2002, during a VT-1 visual inspection inspection of reactor coolant pump flange bolts, the condition of a bolt was determined determined to be unsatisfactory. The The specific condition the applicant observed was blistering of the bolt coating in the mid-shank mid-shank areaarea between the head head and threads. The threads were also noted to be lightly rusted, and the bolt bolt was replaced. Upon further staff staff questioning questioning of the BVPS staff and review of the conditioncondition report, itit was learned learned that the applicant applicant performed investigation to verify the integrity performed additional investigation of the remaining flange bolts. As aa result, 3 bolts were replaced in total, and proper corrective corrective actions demonstrated.

actions were demonstrated.

The staff reviewed the operating operating experience experience provided in the LRA and interviewed interviewed the applicant's applicant's technical technical staff to confirm that the operating experience experience did not reveal degradations degradations that are not bounded by industry experience.

experience. Based on this review, the staff finds (1) that the operating operating experience experience for this AMP demonstrates Integrity Program demonstrates that Bolting Integrity Program is achieving achieving its objective of managing managing system components and (2) that the applicant is taking appropriate corrective actions appropriate corrective actions through implementation implementation of this program.

The staff confirmed that the operating operating experience experience program program element satisfies the criterion criterion defined defined in the GALL GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program program element acceptable.

acceptable.

Supplement. In LRA Section UFSAR Supplement. Section A.1.6, the applicant provided the UFSAR supplement applicant provided supplement for for the Bolting Integrity Integrity Program. The staff reviewed this Section Section and determines determines that the the information in the UFSAR supplement is an adequate information adequate summary description of the program, summary description program, as as required required by 10 10 CFR 54.21(d).

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Conclusion. On the Conclusion. the basis basis of itsits review review of the applicant's Bolting IntegrityIntegrity Program and and additional information provided in in the applicant's applicant's RAI responses, responses, the staff finds all programprogram elements elements consistent with the GALL Report. The staff concludes that the applicant applicant has demonstrated demonstrated that safety-related bolting, (b) bolting for NSSS effects of aging on (a) safety-related NSSS component supports, (c) bolting for other pressure retaining components, including including nonsafety-related nonsafety-related bolting, bolting, and (d) structural bolting measured yield strength ~> 150 ksi), will be bolting (actual measured be adequately managed so that their intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement supplement for this AMP and concludes that it provides an adequate summary description description of the program, as required by 10 CFR 54.21(d).

Boric Acid Corrosion Program 3.0.3.1.4 Boric Summary of Technical Technical Information in the Application. In LRA Section B.2.7, the applicant described the existing existing Boric Acid Corrosion Program as consistent with GALL AMP XI.M10, "Boric Acid Corrosion."

program manages This program manages loss of material due to borated borated water leakage through periodic visual inspections. The program provides for (a) determination determination of the principal locationlocation of leakage, (b) examination examination requirements and procedures procedures for locating small leaks, and (c) engineering engineering evaluations and corrective actions.

evaluations Staff Evaluation.

Evaluation. The staff reviewed reviewed the "scope of program," "preventative/mitigative "preventative/mitigative actions,"

monitored/inspected," "detection of aging effects,"

"parameters monitored/inspected," effects," "monitoring and trending,"

"acceptance criteria" and "operating experience" program program elements elements of the applicant's Boric Acid Acid Corrosion Program against the staff's recommended recommended criteria for these programs provided provided the in the corresponding corresponding program elements elements of GALL AMP XI.M10. The staff performed its review of the the "corrective actions," "confirmatory actions," and "administrative controls" program elements as "corrective actions," "confirmatory actions," and "administrative elements as part of the staff's staffs review of the applicant's Quality Quality Assurance Assurance Program. The staff's evaluationevaluation of the Quality Assurance Program documented in SER Section Program is documented Section 3.0.4.

With regard to the staff's review of the "scope of program" "preventative/mitigative "preventative/mitigative actions,"

"parameters monitored/inspected,"

monitored/inspected," "detection of aging effects," "monitoring "monitoring andand trending,"

"acceptance criteria" and "operating experience" program program elements elements for the AMP, the staff staff reviewed reviewed those portions of the applicant's Boric Boric Acid Corrosion Corrosion Program Program that the applicant applicant claimed claimed consistency consistency with GALL AMP XI.M1 XI.M100 and found found they they are are consistent with this GALLGALL AMP. The staff also also confirmed confirmed that the plant plant program program contains all of the elements elements of thethe referenced GALL referenced GALL Report program program and the conditions at the plant are bounded by the conditions conditions for which which the GALL Report is evaluated.

Report evaluated. Onsite interviews interviews with the applicant's applicant's technical staff staff were also also held to confirm confirm these these results.

The staff reviewed The reviewed the applicant's applicant's license license renewal basis documentdocument for for the Boric Boric Acid Corrosion Corrosion Program Program and confirmed that the program and confirmed program scope scope includes includes all components components and structures structures made made from aluminum alloy or from aluminum or steel steel materials materials (including (including carbon steels, alloy alloy steels, and cast cast irons) irons) that may be exposed exposed to leakage leakage of borated water from systems containing containing borated aqueous borated aqueous solutions. The staff determined determined that the applicant includes the applicant includes coppercopper alloy components components within the the scope scope of the Boric Boric Acid Corrosion Program.

Program. The staff finds finds this acceptable acceptable because because thethe applicant applicant conservatively conservatively treats copper copper alloy materials materials as an additional material type that additional material that may may be be 3-19 3-19

susceptible susceptible to wastage wastage induced induced by leakage from borated borated water sources. The staff finds that the the "scope of program" program element for the applicant's Boric Acid Corrosion "scope of program" program element for the applicant's Program acceptable acceptable because itit conforms conforms to the recommended recommended GALL AMP XLM10 XI.M10 and because because thethe applicant applicant has conservatively included copper alloy componentscomponents within the scope of the program.

The staff also noted that the applicant's Boric Acid Corrosion Corrosion Program was established based on the applicant's applicant's response to Generic Letter (GL) (GL) 88-05, "Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Reactor Boundary Components Components in PWR Plants." The staff finds this to be acceptableacceptable because itit is in conformance because conformance with GALL AMP XI.M10. XLM10.

The staff also noted noted that the Boric Acid Corrosion Program Program includes provisions for engineering engineering evaluations and corrective corrective actions, and that if the applicant detects detects any evidence of borated water leakage, either by programmatic programmatic inspections or by other activities, the leakageleakage is evaluated evaluated and resolved using the FENOC Corrective Corrective Action Program. The staff also noted that the boric acid leakage leakage inspections inspections are performed, performed, pursuant pursuant to the AMP, by qualified qualified boric acid acid corrosion control inspectors. As part of their training, these inspectors complete a VT-2 general corrosion training course course and perform the VT-2 visual examinations accordance with either examinations in accordance either direct visual examination methods or by remote visual examination examination examination techniques. The staff further noted noted that the FENOC Corrective Corrective Action Program requires that the applicant applicant document document its results from system walkdowns and VT-2 visual examinations examinations on a Boric Acid Corrosion Corrosion Control Leakage Control Leakage Inspection Report Form, which is retained on file.

The staff determined determined that these aspects aspects of the applicant's applicant's program were consistent with the the recommended recommended criteria provided in the program elements elements of GALL AMP XLM1 XI.M10.o. Based on thisthis review, the staff concludes concludes that, in addition to the "scope of program" program element, the programllprogram the remaining remaining program elements for the Boric Acid Corrosion Program are acceptable acceptable because they are consistent with the staff's corresponding corre~ponding program program element criteria criteria recommended in GALL AMP XLM10.

XI.M10.

Experience. The staff reviewed Operating Experience. reviewed the operating experience provided by the applicant in operating experience in the LRA and interviewed interviewed the applicant's personnel to confirm that the plant-specific applicant's technical personnel plant-specific operating experience operating experience did not reveal any aging aging effects effects not bounded by the GALL Report. The The staff also confirmed that applicable applicable aging effects effects and industry plant-specific operating industry and plant-specific operating experience experience have have been been reviewed by the applicant applicant and are evaluated in the GALL Report.

The staff also reviewed the "operating experience" discussiondiscussion in the applicant's applicant's license renewal basis document document for the Boric Acid Corrosion Program. Program. The staff reviewed reviewed a sample of the the condition reports and confirmed confirmed that the applicant has identified boric acid corrosion corrosion and has has implemented appropriate implemented appropriate corrective corrective actions.

The applicant periodically evaluated and enhanced applicant stated that the program is periodically enhanced to include include industry experience.

experience. The Boric Acid Program Program at BVPS was enhanced enhanced to include recommendations recommendations of the the Westinghouse Owner's Westinghouse Owner's Group, EPRI guidelines, NRC Bulletins 2002-01, 2002-01, "Reactor Pressure Vessel Head Degradation Degradation and Reactor CoolantCoolant Pressure Boundary Integrity,"

Integrity," and 2003-02, "Leakage from Reactor Coolant Coolant Pressure Vessel Lower Head Penetrations Penetrations and Reactor Reactor Coolant Coolant Pressure Boundary Integrity."

The staff reviewed applicant's responses reviewed the applicant's responses to NRC Order EA-03-009, as amended amended in the the applicant's response to First Order EA-03-009 applicant's EA-03-009 (henceforth the Order as Amended); NRC 3-20

Bulletin 2003-02, Bulletin 2003-02, "Leakage from Reactor Pressure Pressure Vessel Lower Head Head Penetrations Penetrations and Reactor Coolant Boundary Integrity," and NRC Bulletin 2004-01, Coolant Pressure Boundary 2004-01, "Inspection "Inspection of Alloy Alloy 82/182/600 Materials 82/182/600 Materials used in the Fabrication Fabrication of Pressurizer Pressurizer Penetrations Penetrations and Steam Piping Piping Connections at Pressurized-Water Pressurized-Water Reactors," to assess the relevancyrelevancy of borated water leakageleakage events associated associated with through-wall cracking in ASME ASME Code Class 1 nickel-alloy nickel-alloy locations. The The staff evaluated whether those steel components, aluminum alloy components, or copper evaluated whether copper alloy alloy components in the vicinity of ASME ASME Code Class 1 nickel-alloy nickel-alloy locations locations in the upper upper reactor vessel (RV) closure head, RV bottom head, and pressurizer pressurizer system are within the scope of the the visual examinations examinations and system walkdowns performed performed under the applicant's Boric Acid Acid Corrosion Control Program. The staff noted that the applicant's commitments commitments for bare metal examinations made in response to the Order, as Amended, NRC Bulletin visual examinations Bulletin 2003-02, 2003-02, and NRC Bulletin 2004-01, 2004-01, indicated indicated that the applicant applicant would perform perform bare metal visual examinations of these component examinations component locations; however, it was not clear to the staff whether the the inspections inspections in the applicant's responses responses to these generic generic communications communications (including (including thethe responses to the Order as Amended) were within the scope of the Boric Acid Corrosion responses Corrosion Control Program.

Program.

In RAI B.2.7-1, B.2. 7-1, dated May 22, 2008, the staff requested requested that the applicant applicant clarify the following:

(a) Identify which components components are included within the scope of this AMP, and whether whether the scope includes nickel-alloy locations.

includes all Class 1 nickel-alloy (b)

(b) For in-scope nickel-alloy nickel-alloy locations (if(if any), clarify whether the examinations examinations will implemented through this AMP or some other BVPS AMP in the LRA. If be implemented If another another AMP will be used for specific components, clarify which AMP will be be implemented for the examination.

examination.

(c) Clarify which programs will be used to evaluate the evidence evidence of leakage leakage that is detected detected through this AMP or other AMPs.

(d)

(d) For the in-scope Class 1 nickel-alloy components, clarify what type of visual examinations (Le.,

examinations (i.e., specify VT-1, VT-2 or VT-3, and whether specify whether VT-1, whether the visual examinations are examinations enhanced, bare-surface, qualified, etc.)

are enhanced, performed on etc.) will be performed on the components.

In its response to RAI B.2. B.2.7-1, 7-1, dated July 24, 2008, the applicant stated that it does not credit this program for management management of cracking in nickel-alloy components, including those in ASME ASME Code Class 1 systems. The applicant stated that, instead, management management of cracking cracking in in nickel-alloy components, including ASME Code Class 1 nickel'-alloy nickel-alloy nickel-alloy components, components, is accomplished through accomplished implementation of one or more through implementation more of the following AMPs:

• B.2.2 ASME Section XI Xl Inservice Inservice Inspection, Subsections IWB, IWC, and IWD Inspection, Subsections IWD

• B.2.9 Closed-Cycle Closed-Cycle Cooling Cooling Water System

• B.2.15 External Surfaces Surfaces Monitoring Monitoring

• B.2.22 Inspection Inspection of Internal Internal Surfaces Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Components S* B.2.29 Nickel-Alloy Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads Heads 3-21

" B.2.30 B.2.30 One-Time Inspection Inspection

" B.2.32 Open-Cycle B.2.32 Open-Cycle Cooling Water System

• Generator Tube Integrity B.2.38 Steam Generator

• B.2.42 Water Chemistry Components made from nickel-alloy alloy base metals and nickel-alloy welds are not wastage induced by boric acid leakage in the manner that steel components susceptible to wastage components (i.e.,

carbon steels, alloy steels, or cast irons) or aluminum componentscomponents are. Thus, the staff noted that the applicant's comment comment that nickel-alloy nickel-alloy components are not within the scope of the Boric Boric Acid Corrosion Program was valid because because it was consistent consistent with this technical basis and with the scoping assessment assessment in the "scope of program" program element in GALL AMP XI.M10. XI.M1 O. The The staff noted noted however, that leakageleakage from nickel-alloy nickel-alloy components potentially potentially could be sources sources of of borated water borated leakage for steel, copper alloy, or aluminum water leakage aluminum alloy components within the vicinity nickel-alloy components. Thus, the staff was of the opinion that steel, copper of these nickel-alloy copper alloy, and aluminum alloy components within the vicinity vicinity of nickel-alloy nickel-alloy components in systems containing systems containing borated water inventories borated inventories must be included within the scope of the applicant's applicant's Boric Acid Corrosion Control Program.

To address this, the staff reviewed reviewed the applicant's applicant's Type 2 AMR Tables in the LRA for BVPS to determine whether the applicant does credit the Boric Acid Corrosion Program for management determine management of loss of material due boric acid leakage in the surfaces surfaces of steel, aluminum alloy and copper alloy components components that are in vicinity of borated systems containing nickel-alloy component nickel-alloy component locations. The staff verified that the applicant does does credit the Boric Acid Corrosion Program Program to manage loss of material manage material due to boric acid leakage leakage in steel, copper alloy, and aluminum aluminum alloy alloy component surfaces that could be potentially exposed component exposed to leakage leakage from borated systems, including those in the vicinity of nickel-alloy including nickel-alloy component component locations locations or nickel-alloy welds. The staff staff also verified verified that this includes steel, aluminum alloy, and copper alloy componentscomponents in the RV, reactor coolant pressure pressure boundary boundary (RCPB) piping, pressurizer, SG, safety injection, injection, residual (RHR), containment heat removal (RHR), containment spray, chemical and volume control, boron recovery recovery and primary grade water, area area ventilation ventilation - other, and building and yard drain systems. Thus, the the staff found that the applicant applicant has updated its program to address the impacts impacts of borated water leakage that potentially potentially could occur from through-wall through-wall cracking in nickel-alloy nickel-alloy components components in borated systems systems and, therefore, as updated the program address address relevant operating experience experience from nickel-alloy nickel-alloy component locations. Thus, the staff finds that the applicant's applicant's Boric Acid Acid Corrosion Program Program has accounted for applicable applicable operating experience experience associated associated with borated water leakage, including operating operating experience associated with boratedborated water leakage that has has occurred occurred from nickel-alloy nickel-alloy components.

Based on this review, the staff concludes concludes that the applicant has demonstrated demonstrated that its Boric AcidAcid Corrosion Program is capablecapable of identifying, identifying, monitoring, monitoring, and correcting the effects of boric acidacid corrosion corrosion on the intended intended function of steel, copper alloy, and aluminum alloy components that may be exposed to borated borated water leakage, because the staff has verified that the program is consistent consistent with the recommendations recommendations in GALL GALL AMP XI.M1 0 and in SRP-LR SRP-LR Section A.1.2.3.10 A.1.2.3.1 0 and that the program program is updated to account account for relevant operating operating experience. this Based on this determination, determination, the staff concludes concludes that the Boric Acid Corrosion Corrosion Program Program can be expected expected toto ensure that the systems systems and components components within the scope of this program continue to program will continue perform perform their intended intended functions functions consistent with the CLB for the period extended operation.

period of extended 3-22 3-22

UFSAR UFSAR Supplement. In LRA Section A1.7, A 1. 7, the applicant provided provided the UFSAR supplement supplement for for the Boric Acid Corrosion Corrosion Program. The staff verified that the applicant'sapplicant's UFSAR supplement summary summary description description for the Boric Acid Corrosion Program conforms to the staff's staff's recommended UFSAR recommended UFSAR supplement supplement guidance for these types of programs programs as found in SRP-LR SRP-LR Table 3.1-2.

3.1 ~2.

Based on this review, the staff finds that UFSAR Supplement Section Section A.1.7 A.1. 7 provides an acceptable acceptable UFSAR UFSAR Supplement summary summary description description of the applicant's Boric Acid CorrosionCorrosion Program because because it is consistent consistent with the UFSAR Supplement summary description summary description in the SRP-LR for Boric Acid Corrosion Program.

Conclusion. On the basis of its review of the applicant'sapplicant's Boric Acid Corrosion Program Program and additional information provided in the applicant's information provided applicant's RAI responses, the staff finds all program program elements consistent with the GALL Report. The staff concludes concludes that the applicant applicant hashas demonstrated that the effects of aging will be adequately demonstrated adequately managed managed so that the intended functions will be maintained maintained consistent with the CLB for the period of extended extended operation, operation, as as required by 10 CFR 54.21(a)(3).

54.21(a)(3). The staff also reviewed the UFSAR UFSAR supplement for this this AMP and finds that it provides an adequate adequate summary summary description description of the program, program, as required by by 10 CFR 54.21(d).

54.21(d).

3.0.3.1.5 Buried Piping and Tanks InspectionInspection Program Program Summary of Technical Technical Information Information in the Application. In In LRA LRA Section B.2.8, the applicant described described the new Buried Piping Inspection Program and Tanks Inspection Program as consistent with GALL AMP XI.M34, XLM34, "Buried Piping and Tanks Inspection Inspection Program." The applicant submitted Amendment Amendment No. 23 dated September September 8, 2008, in which the applicantapplicant identified exception to identified an exception to several of the program program elements elements for this program. exception is evaluated in the staff program. The exception staff evaluation. The applicant applicant stated that this program program includes preventive measures to mitigate mitigate corrosion and periodic inspections to monitor monitor buried piping conditions for buried carbon steel and stainless steel piping.

Staff Evaluation. In the LRA, the applicant stated stated that the Buried Piping and Tanks Inspection Inspection Program is a new program that is consistent with GALL GALL AMP XI.M34, XLM34, "Buried Piping and Tanks Tanks Inspection Inspection Program" with exception.

The staff reviewed reviewed those portions of the applicants Buried Piping Piping and Tanks Inspection Program Tanks Inspection Program for which which the applicant applicant claimed consistency consistency with GALL AMP XLM34 XI.M34 and found they are are consistent. On the basis of the review, the staff concludes concludes that the applicant's Buried Piping and Tanks Inspection Program provides assurance Inspection Program assurance that the aging effect either is not occurring, occurring, or is occurring occurring at a very slow rate, and does not affect affect the intended function of the component component or or structure.

Exception Exception In Amendment Amendment No. 23 to the LRA dated dated September September 8, 2008, the applicant identified an an exception to the "preventive actions," "parameters monitored/inspected,"

exception monitored/inspected," and "acceptance "acceptance criteria" program program elements elements in GALL AMP XI.M34. XLM34.

3-23

"LRA Section B.2.8, "Buried Piping and Tanks Inspection,"

Inspection," requires a revision to to incorporate an exception to the NUREG-1801, incorporate NUREG-1 801,Section XI. XI.M34 M34 (same title) aging management program. NUREG-1801, management NUREG-1801, Section Section XI.M34 states that all buried piping is to be wrapped. However, BVPS installed installed buried buried stainless steel AL-6XN piping that is not coated coated or wrapped; the material material has excellent excellent corrosion resistance resistance and the manufacturer manufacturer recommends recommends no coating coating or wrapping on thethe piping.

piping. Therefore, Therefore, the Buried Piping and Tanks Inspection Program described described in the BVPS LRA LRA should include include and exception exception to the NUREG 1801 1801 program.

program. LRA B.2.8, affected subsections subsections as listed, is revised revised to read:

• • Preventive Preventive Actions Actions The "preventive actions" program element was modified to read (changes in in accordance with industry practice, bold), "In accordance practice, coatings and wrapping wrapping are used to protect protect against corrosion by isolating the external external surface of the piping from the the soil environment, as applicable.

applicable. Exception Exception is taken to coating and wrapping AL- AL-6XN stainless steel, because because it is resistant resistant to corrosion.

corrosion. The program program will ensure that the integrity integrity of the coatings and wrappings wrappings of buried pipe is maintained where they are used."

• • Parameters Monitored/Inspected Parameters Monitoredllnspected The "parameters monitored/inspected" program element monitoredlinspected" program element was modified modified to read (changes in bold), "When the opportunity arises, buried buried piping and tanks will bebe visually inspected inspected for corrosion and coating and wrapping wrapping integrity. Any evidence evidence of damaged damaged wrapping wrapping or coating defects, such as coating perforation, holidays, or other damage, is an indicator indicator of possible corrosion damage damage to the external surface of the piping and tanks."

surface

• • Acceptance Criteria Acceptance Criteria The "acceptance criteria" program element was modified program element modified to read (changes in bold), "Any coating and wrapping degradations degradations or evidence evidence of corrosion found during inspections of buried buried piping and tanks will be evaluated, tracked" tracked,, and repaired using the Corrective Action Program."

The staff finds that this exception exception is acceptable acceptable and that coating or wrapping is not required.

AL-6XN AL-6XN piping was developed for sea water service; service; thus, exposure to Ohio River water and and soil would not result in corrosion. The staff noted that AL-6XN AL-6XN piping is often used in soils wherewhere MIC causes corrosion of carbon steel piping. (J. R. Maurer, "Application of aa Six Percent Percent Molybdenum Stainless Molybdenum Stainless Alloy for Nuclear Nuclear Applications,"

Applications," NACE NACE Corrosion 89 Conference, New New Orleans, LA, National Association National Association of Corrosion Engineers, Engineers, Paper No. 501, 1989.)

501, 1989.)

The staff finds the applicant's applicant's Buried Piping and Tanks Inspection acceptable because Inspection Program acceptable because itit conforms to the recommended recommended GALL AMP XI.M34 XI.M34 with staff approved exception.

Operatingq Experience. The staff also audited the operating Operating operating experience, including including a sample of condition reports, and interviewed interviewed the applicant's applicant's technical staff to confirm confirm that the plant-specific plant-specific operating operating experience degradation not boun~ed experience did not reveal any degradation bounded by industry experience.

experience. In the In the 3-24

LRA, the applicant stated that there is no operating experience that demonstrates operating experience demonstrates the the effectiveness effectiveness of this program program because it is aa new program.

program.

complete its audit, the staff required additional In order to complete information on the applicant's additional information applicant's operating experience experience with buried buried piping and tanks at BVPS Units 1 and 2.

B.2.8-1, dated April 3, 2008, the staff requested In RAI B.2.8-1, requested that the applicant information on applicant provide information on major replacements any major replacements of buried buried piping at Beaver Valley Power Station Units 1 and 2.

In its response response to RAI B.2.8-1, B.2.8-1, dated May 5, 2008, the applicant 5,2008, applicant stated that major replacements major replacements of buried piping at BVPS have occurred occurred because because of corrosion. A 6-inch 6-inch carbon steel river water water line was replaced in 19951995 with AL-6XN stainless steel from the 24-inch 24-inch river water headers to to the emergency emergency diesel generators generators (EOGs).

(EDGs). This piping supplies cooling water to both trains of the the Unit 1 emergency generators. The cause cause of corrosion corrosion was microbiologically influenced corrosion microbiologically influenced corrosion (MIC). Because the AL-6XN piping is corrosion resistant, coating was not necessary.

(MIC).

The staff finds that this piping replacement is acceptable acceptable and that coating coating is not required.

AL-6XN piping was developed for sea water service; thus, exposure exposure to Ohio River water and soil would not result in corrosion.

corrosion. The staff noted noted that AL-6XN AL-6XN piping is often used in soils or raw water where MIC causes causes corrosion of carbon carbon steel piping.

The applicant also stated stated that the east and west cement-lined cement-lined gray gray cast-iron protection cast-iron fire protection headers from the intake structure structure to the yard loop were replaced in 2002 with cement-lined ductile ductile iron piping. The gray cast-iron piping experienced experienced graphic graphic corrosion, a form of selective selective leaching. The applicant stated stated that this piping is coated coated with a bituminous coating and wrapped wrapped with polyethylene polyethylene sheet.

The applicant applicant further stated stated that a 6-inch 6-inch carbon carbon steel line from the service service water system (SWS) supply for Unit Unit 2 and return headers to the control room chillers was replaced replaced in 2002 with AL- AL-6XN stainless steel. This piping supplies cooling water to both trains of the Unit 1 emergencyemergency generators generators and experienced experienced pitting and general Because the AL-6XN piping is general corrosion. Because corrosion corrosion resistant, coating it was not necessary.

B.2.30-1, dated In RAI B.2.30-1, dated April 30, 2008, the staff requested requested that the applicant respond to the the following staff concerns: (a) explain explain how the applicant manages the effects of aging beyond applicant manages the beyond the volumetric inspection that is conducted prior to the period of extended volumetric inspection extended operation; (b) describe describe the types of materials used to construct construct the aboveground aboveground tanks located located outside; and (c) discuss discuss the applicant's applicant's operating history with aboveground aboveground tanks.

In its response to RAI B.2.30-1, B.2.30-1, dated May 5,2008, 5, 2008, the applicant stated:

The inspection of the tank bottom prior to entering the period of extended operation operation is the only part of the AMP assigned to manage the potential for aging aging of the external external bottom surfaces surfaces of tanks mounted on concrete concrete foundations at BVPS.

BVPS has five aboveground tanks within the scope of license renewal renewal that are located outside and mounted located outside mounted on on concrete concrete foundations. These tanks are summarized summarized in the following table:

3-25

Tank name Material Material of Construction Refueling Water Refueling Water Storage Storage Tank Tank steel Stainless steel Refueling Water Refueling Water Storage Storage Tank Stainless steel steel Demineralized Water Turbine Plant Demineralized Aluminum Storage Tank Demineralized Water Storage Demineralized Storage Tank Stainless steel Stainless Demineralized Water Storage Tank Stainless steel Stainless includes one or more of the following design or construction Each of these tanks includes construction bitumastic coating, sloped foundations, caulking, features: an oil-sand bed, bitumastic and/or sealing fillets. These features are expected to preclude preclude water from the the bottom surfaces of the tanks that could result result in aging effects. In In the BVPS BVPS License Renewal Renewal Application, FENOC credits either the External Surfaces Surfaces Monitoring Program or the Structures Monitoring; Program Program for managing the the observable construction aging of the externally observable construction features (sloped foundations, caulking, and sealing fillets). However, since verification verification of the absence of water on the bottom surfaces surfaces of the tanks is impractical, these tanks are evaluated using the environment environment of "soil" for the external external bottom surfaces. "Soil" was was determined to approximate approximate the worst conditions that could exist if if water were not not excluded. Loss of material was identified as a potential potential aging effect for the the bottom surfaces of these tanks if if the design and construction construction features failed to exclude water. The One-Time Inspection Program was assigned to verify that the the aging effect is not occurring; should the aging effect be verified to be present, the the program additional actions that assure the intended function of the tanks program triggers additional will be maintained maintained during the period of extendedextended operation. No additional program program was assigned to manage the external bottom surfaces of the tanks, as as the aging effect is expected expected to be precluded precluded by design design and construction construction features, and the purpose purpose of the One-Time Inspection Inspection Program is to verify the absence of such effects.

The same aging management management approach approach was used to address aging of the the surfaces of the enclosure-protected external bottom surfaces enclosure-protected Primary Plant Demineralized Demineralized Water (Storage) Tanks at both units. The Unit 1 tank is fabricated fabricated of steel, and the Unit 2 tank is fabricated fabricated of stainless steel. Both tanks are mounted on on concrete foundations concrete foundations with design and construction construction features to preclude preclude the the presence presence of water water from the tank bottom bottom surfaces. Additionally, these tanks tanks are located located within reinforced reinforced concrete concrete structures structures that provide additional additional protection protection from the outside environment.

environment. TheThe One-Time Inspection Program is assigned to One-Time Inspection to confirm confirm the absence of aging effects from the external external bottom bottom surfaces surfaces of these these tanks.

The NUREG-1801, NUREG-1801, Section Section XI.M29, "Aboveground Steel Tanks" program program specifically specifically addresses addresses steel tanks, with an emphasisemphasis on coating inspection in coating inspection elements 1 through 6. The XI.M29 elements XI.M29 program program also recommends thickness also recommends thickness measurements measurements of inaccessible inaccessible locations, locations, suchsuch as tank tank bottoms.

bottoms. Since most elements elements of the XI.M29 XI.M29 program program dealdeal with coatings, coatings, and would not be applicable applicable to stainless stainless steel steel and aluminum aluminum tanks, thickness thickness measurements measurements of the bottoms of tanks mounted mounted on concrete foundations on concrete foundations was incorporated incorporated into the One-Time One-Time 3-26 3-26

program was credited for managing the aging of all Inspection program, and the program in-scope tanks mounted on concrete in-scope concrete foundations.

experience associated A review of operating experience A identified six instances in which associated with tank bottoms identified the actual or potential degradation was documented potential for tank bottom degradation evaluated. Five of documented and evaluated.

these instances either involved lubricating oil tanks, and none of the instances involved fuel oil or lubricating instances surfaces. A review of the applicant's operating external bottom surfaces.

involved external experience did not operating experience degradation of the tank bottoms.

identify any instances of degradation The staff finds the applicant's response B.2.301-1, dated May response to RAI B.2.301-1, May 5, 2008, acceptable acceptable because the applicant has verified that the above ground tanks are not constructed because constructed from carbon steel. The staff confirms that stainless steel and aluminum tanks do not require coating of the the external surfaces, which is, as the applicant applicant points out, a major part of the Aboveground Aboveground Tanks Aboveground Tanks Program Program. Both the Aboveground Program and the One-Time Inspection Program require One-Time Inspection inspection of the tank bottoms, and because one-time inspection a one-time external coatings are not an issue because the external issue for these tanks, the staff finds that One-Time Inspection Program for checking tank bottoms is One-Time Inspection is acceptable. Therefore, the staff's concerns concerns described described in in RAI B.2.30-1 B.2.30-1 are resolved.

The staff confirmed confirmed that the operating experience program element satisfies the criterion operating experience criterion defined in defined in the GALL GALL Report Report and inin SRP-LR Section A. 1.2.3.10.

Section A.1.2.3.1 O. The staff finds this program program element acceptable.

UFSAR UFSAR Supplement. In Section A.1.8, the applicant In LRA SectionA.1.8, applicant provided the UFSAR supplement supplement for the Buried Piping and Tanks Inspection Program. The staff reviewed this Section and determines that the information determines in the UFSAR supplement is an adequate information in description adequate summary description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's Buried Piping and Tanks Inspection Conclusion.

additional information provided Program and additional provided inin the the applicant's RAI responses, the applicant's RAI the staff staff finds all all program elements elements consistent Withwith the GALL Report. The staff concludes that the applicant has concludes that has demonstrated that the effects of aging will be adequately demonstrated adequately managed intended managed so that the intended maintained consistent with the functions will be maintained CLB for the period of extended operation, as extended as UFSAR supplement for this reviewed the UFSAR required by 10 CFR 54.21(a)(3). The staff also reviewed this provides an adequate summary description of the program, AMP and finds that itit provides program, as required by 10 CFR 54.21(d).

Connections Not Subject 3.0.3.1.6 Electrical Cables and Connections 3.0.3.1.6 Environmental Subject to 10 CFR 50.49 Environmental Qualification Requirements Qualification Requirements Program Summary of Technical Information in Technical Information in the Application. InIn LRA Section B.2.11, B.2.1 1, the applicant described the new Electrical Electrical Cables and Connections Connections Not Subject to 10 CFR 50.49 Environmental Qualification Environmental Requirements Program as consistent with GALL Qualification Requirements GALL AMP XI.E1,XI.E1, "Electrical Cables and Connections Not Subject to 10 10 CFR 50.49 Environmental Qualification Environmental Qualification Requirements Program."

Requirements The applicant stated that this program will provide reasonable assurance that intended functions reasonable assurance functions connections exposed to adverse localized insulated cables and connections of insulated environments caused by localized environments maintained consistent with the CLB through the period of heat, radiation and moisture can be maintained extended operation.

operation. The program implemented prior to the period of extended program will be implemented operation.

extended operation.

3-27 3-27

Staff Evaluation. The staff reviewed reviewed the LRA and the onsite bases documents related to the the applicant's Electrical Cables and Connections Not Subject to 10 applicant's Electrical 10 CFR 50.49 Environmental Environmental Qualification Qualification Requirements Requirements Program, Program, in which the applicant consistency with GALL applicant claims consistency AMP XI.E1, XI.E1, "Electrical Cables and Connections Connections Not Subject to 10 CFR 50.49 Environmental Qualification Qualification Requirements Requirements Program." The staff reviewedreviewed the applicant's program documents applicant's program documents and confirmed confirmed them to be consistent with GALL AMP XI.E1. XI.E1. The staff also confirms that the the program contains all of the elements of the referenced plant program referenced GALL program program and that thethe conditions at the plant are bounded bounded by the conditions conditions for which Report is evaluated.

which the GALL Report The staff held onsite onsite interviews interviews with the applicant's applicant's technical personnel to confirm these results.

Operatingq Experience. In LRA Section Operating B.2. 11, the applicant Section B.2.11, applicant stated that operating operating experience experience reports were not available, available, because this is a new AMP for which there is no plant-specific plant-specific program operating experience program experience for program program effectiveness.

In RAI B.2.11-1, B.2. 11-1, dated dated May May 22, 2008, the staff requested requested that the applicant applicant explain material degradation recently observed by the applicant degradation applicant during its implementation implementation of other existing activities that relate to the aging effects to be managed managed by this program.

In its response to RAI B.2.11-1 B.2.1 1-1 dated August 22,2008, 22, 2008, the applicant applicant stated that as aa result of the operating experience experience from Turkey Point Unit Unit 3, it conducted conducted a walk down of the Unit 2 cables in the pressurizer pressurizer area, during during RFO 11 (Spring 2005), to look for visual effects of cable cable overheating that could cause the jacket jacket and insulation to become brittle. No deficiencies deficiencies were were noted. The applicant further stated that in 2001, 2001, it identified identified severely severely burned and cracked wiringwiring on an equipment equipment field cable, resulting from excess cable contacting a hot relief valve. The The condition was entered entered into the FENOC Corrective Corrective Action Program. The cable condition was was evaluated, replaced and secured evaluated, secured to prevent a reoccurrence.

reoccurrence.

The staff finds the applicant's applicant's response acceptable acceptable because the aging effects of brittle, burned, and cracked cracked cables due to heat in an adverse adverse localized environment are bound by those localized environment those identified in GALL AMP XLE1, identified XI.E1, and the applicant took appropriate appropriate corrective corrective action to address address the aging of the equipment field cable.

The staffs review of operating experience experience followed the guidance found in SRP-LR Section A.1.2.3.10, A.1.2.3.1 0, which which states that in the future, an applicant applicant may be required to commit to providing operating operating experience experience for a new program program to confirm effectiveness. In the LRA, the confirm its effectiveness. the applicant stated that itit will evaluate applicant evaluate industry plant-specific operating experience industry and plant-specific the experience in the development and implementation development implementation of this program.

program. As additional operating operating experience is obtained, the applicant applicant will implement implement lessons lessons learned. The staff confirms confirms that the "operating experience" program program element element satisfies the criterion defined defined in the GALL Report and in SRP-LR Section A.1.2.3.10.

A.1.2.3.1 O. Therefore, Therefore, the staff finds this program element acceptable.

acceptable.

UFSAR Supplement. In LRA Section UFSAR A.2.1 1, the applicant Section A.2.11, applicant provided the UFSAR UFSAR supplement for the Non-EQ Insulated Cables and Connections Program.

Non-EQ Insulated Program. The staff reviewed this Section Section and determines determines that the information information in the UFSAR UFSAR supplement supplement is an adequate adequate summary summary description of the program, program, as required by 10 CFR 54.21 54.21(d).

(d). The staff also verified that applicant has has (Commitment No.4 committed (Commitment No. 4 in UFSAR UFSAR Supplement Supplement Table A.4-1 and Commitment Commitment No. No.44 in Supplement Table A.5-1)

UFSAR Supplement A.5-1) to implement implement its new Non-EQ Non-EQ Insulated Cables and Connections Program.

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Conclusion. On the basis of its review of the applicant's Electrical Conclusion. Electrical Cables and Connections Connections Not Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program and additional information provided information provided in the applicant's applicant's RAI responses, the staff finds all program program elements elements consistent with the GALL Report. The staff concludesconcludes that the applicant applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions functions will be be maintained maintained consistent with the CLB for the period period of extended extended operation, as required required by by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and finds that UFSAR supplement it provides an adequate adequate summary summary description of the program, as required by 10 CFR 54.21(d). 54.21 (d).

3.0.3.1.7 Electrical Cables and Connections Not Subject 3.0.3.1.7 Electrical Subject to 10 CFR 50.49 Environmental Qualification Environmental Requirements Used in Instrumentation Qualification Requirements Instrumentation Circuits Program Program Summary Summary of Technical Technical Information Information in the Application.

Application. In LRA, Section B.2.12, the applicant applicant described the new "Electrical Cables and Connections Not subject to 10 CFR 50.49 described Environmental Environmental Qualification Qualification Requirements Requirements Used Instrumentation Circuits Program," as Used in Instrumentation as consistent consistent with GALL AMP XI.E2, XI. E2, "Electrical "Electrical Cables Cables and Connections Connections Not Subject Subject to Environmental Qualification 10 CFR 50.49 Environmental Requirements Used in Instrumentation Qualification Requirements Instrumentation Circuits Circuits Program." The applicant stated that this programprogram will demonstrate demonstrate that sensitive sensitive instrument instrument cables and connections connections susceptible susceptible to aging effects from exposure to adverse localized localized environments environments caused by heat, radiation, radiation, and moisture moisture will be adequately managed so that there adequately managed is reasonable assurance assurance that the cables connections will perform cables and connections perform their intended intended function.

This program program will be implemented implemented prior to the period of extended operation.operation.

Staff Evaluation.

Evaluation. The staff reviewed reviewed the LRA and onsite documents related to the onsite bases documents the applicant's Electrical Cables and Connections applicant's Electrical Connections Not subject subject to 10 CFR 50.49 Environmental Qualification Qualification Requirements Used in Instrumentation Instrumentation Circuits Program, Program, in which the applicant applicant claimed consistency with GALL AMP XI.E2.

The staff reviewed the applicant's applicant's program documents documents and confirmed confirmed them to be consistent with with GALL GALL AMP XI.E2. The staff also confirmed that the plant program program contains contains all of the elements of the referenced referenced GALL GALL program program and that the conditions at the plant are bounded by the conditions conditions for which the GALL Report is evaluated. The staff held onsite interviews interviews with the applicant's applicant's technical personnel to confirm these results.

Operatinq Experience.

Operating Experience. In LRA Section Section B.2.12, the applicant statedstated that operating experience operating experience reports were not available available because because this is a new AMP for which there is no plant-specific plant-specific program operating operating experience experience for program program effectiveness.

effectiveness.

In RAI B.2-1, B.2-1, dated dated May 22, 2008, the staff requested 22,2008, requested that the applicant applicant explain material degradation recently degradation recently observed implementation of other existing activities that relate to observed during its implementation the aging effects effects to be managed managed by this program.

program.

In response to RAI B.2-1, B.2-1, dated dated August 22, 2008, the applicant applicant stated that during the periodicperiodic testing of nuclear instrumentation instrumentation system detectors detectors and associated associated field cabling, several connectors connectors were found with a degraded degraded condition. These connectors connectors were repaired or replaced and returned to service. A BVPS engineering engineering change package documentsdocuments that Amphenol triaxial connectors connectors used on the field cables cables associated associated with the Unit 1 neutron neutron detectors become become degraded due to radiation, heat degraded heat and high humidity humidity resulting resulting in system noise. Westinghouse Westinghouse 3-29

recommended recommended that the connectors be changed Westinghouse Crimp-On type, having a changed to a Westinghouse greater neutron radiation. The BVPS engineering change greater resistance to neutron change package approved approved replacement replacement of the subject Amphenol connectors connectors with the Crimp-On type, as a design equivalent equivalent change. Currently, the field cables associated with the neutron detectors for Unit 2 employ employ the Westinghouse Westinghouse Crimp-On Crimp-On type connector.

The staff finds the applicant's applicant's response to RAI B.2-1 acceptable because the staff determined acceptable because determined that adequate adequate operating operating experience experience is given in applicant's response to RAI B.2-1. B.2-1. The staff also finds that the aging effects identified by the applicant are bounded by those in GALL AMP XI,E2. XI.E2.

Therefore, Therefore, the staff's concern described described in RAI B.2-1 is resolved.

The staff's review of operating experience followed the guidance guidance found in SRP-LR SRP-LR Section A.1.2.3.10, A.1.2.3.1 0, which which states that in the future, an applicant applicant may be required to commit to to providing operating operating experience experience for a new program program to confirm its effectiveness.

effectiveness. In the LRA, the the applicant applicant states that itit will evaluate evaluate industry plant-specific operating industry and plant-specific operating experience the experience in the development and implementation development implementation of this program. The applicantapplicant stated that as additional operating experience is obtained, it will implement operating experience implement lessons learned. The staff confirms that the the applicant's "operating experience" program element satisfies the criterion defined defined in the GALL Report and the guidance guidance found in SRP-LR Section A. 1.2.3.10.

A.1.2.3.1 O. Therefore, Therefore, the staff finds this this program element acceptable.

UFSAR Supplement. In LRA Section Section A.1.12, the applicant provided provided the UFSAR supplement for UFSAR supplement the Electrical Cables and Connections Not Subject Subject to 10 Environmental Qualification 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Requirements Instrumentation Circuit Program. The staff reviewedreviewed this Section and determines determines that the information information in the UFSAR supplement adequate summary description supplement is an adequate of the program, as required by 10 CFR 54.21 54.21(d).

(d). The staff also verified that applicant hashas committed committed (Commitment (Commitment NO.5 No. 5 in UFSAR Supplement Table A.4-1 and Commitment Commitment No. NO.5 5 in UFSAR Supplement Supplement Table A.5-1) to implement A.5-1) implement its new Electrical Electrical Cables and Connections Not subject subject to 10 CFR 50.49 Environmental Qualification Environmental Requirements Used in Instrumentation Qualification Requirements Instrumentation Circuits Program.

Conclusion. Based on its review of the applicant's applicant's Electrical Cables and Connections Connections Not subject subject to 10 CFR 50.49 Environmental Environmental Qualification Qualification Requirements Used in Instrumentation Instrumentation Circuits Program, Program, the staff finds that those program program elements for which the applicant applicant claimed consistency consistency with the GALL Report are consistent with the GALL Report program elements. The The staff concludes that the applicant has demonstrated demonstrated that effects effects of aging will be adequately adequately managed managed so that the intended function(

function(s) s) will be maintained maintained consistent consistent with the CLB for thethe period period of extended extended operation, operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the the UFSAR UFSAR supplement for this AMP and concludes concludes that itit provides an adequate adequate summary description of the program, as required description required by 1010 CFR 54.21 54.21(d).

(d).

Qualification (EQ) of Electrical 3.0.3.1.8 Environmental Qualification Electrical Components Components Program Summary of Technical Information in the Application. In LRA, Section Technical Information applicant Section B 2.14, the applicant stated that the Environmental Qualification Environmental Qualification (EQ) of Electrical Electrical Components Program manages manages the effects effects of thermal, radiation, and cyclic aging through the use of aging aging evaluations based on on 10 CFR 50.49 qualification qualification methods. The applicant applicant also stated stated that the Environmental Qualification Qualification (EQ) of Electrical Electrical Components Program is an existing program and claimed Components Program claimed consistency consistency with GALL AMP X.E1, X.E1, "Environmental Qualification (EQ) of Electrical Qualification (EQ) Electrical Components."

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As required by 10 CFR 50.49, environmentalenvironmental qualification program components qualification program components not qualified qualified for for the current license term are refurbished, refurbished, replaced, or havehave their qualification extended extended prior to reaching the aging limits established in the evaluations.

evaluations. Aging evaluations for environmental qualification qualification program program components components are time-limited time-limited aging analyses (TLAAs) for license license renewal.

Staff Evaluation.

Evaluation. The staff reviewed reviewed the LRA and onsiteonsite bases documents documents related to the the Environmental Environmental Qualification Qualification (EQ) (EQ) of Electric Component Component Program in which the applicant applicant assessed its program program consistency with GALL AMP X.EI. X.E1.

The staff reviewed reviewed the applicant's applicant's EQ documents documents and confirmed confirmed them to be consistent with with GALL AMP X.EI. X.E1. The staff also confirmed that the plant program program contains all of the elements of referenced GALL program the referenced program and that the conditions at the plant are bounded by the conditions conditions for which the GALLGALL Report is evaluated. The staff held onsite interviews interviews with the applicant's applicant's technical personnel to confirm these results.

technical personnel In LRA Section Section 4.4, the applicant indicated that the aging effects applicant indicated effects of the EQ of electrical equipment equipment identified identified as TLAAs will be managed managed during during the period period of extended extended operation operation under 54.21(c)(iii).

10 CFR 54.21 (c)(iii). However, the applicant applicant failed to provide information information in its program description and UFSARUFSAR supplement supplement regarding the reanalysis reanalysis attribute to extend the qualified life qualified life of EQ components. The staff noted that the important attributes for the reanalysis of an aging evaluation include include analytical analytical methods, data collection and reduction methods, underlying underlying assumptions, acceptance acceptance criteria, and corrective corrective actions (if acceptance criteria are not met).

(if acceptance In RAI 8.2.14-1, B.2.14-1, dated dated May 15, 2008, the staff requestedrequested that the applicant applicant provide this this information in the program descriptiondescription of the EQ program program and UFSAR supplement or provide a technical justification as to why inclusion technical justification inclusion of this information information is not necessary.

In its response to RAI B.2.14-1, 8.2.14-1, dated June June 17, 2008, the applicant applicant stated that the program program description in LRA Section B.2.14, 8.2.14, "Environmental Qualification Qualification (EQ) Component (EQ) of Electrical Component Program," are revised to include include the EQ component component reanalysis reanalysis attributes as described described in GALL AMP X.E1.

X.E1. The applicant applicant further stated that additional additional details regarding component regarding the EQ component reanalysis attributes attributes are added to the LRA Section 8.2.14 B.2.14 Program Program Description and is revised to to now read:

B.2.14 Environmental Qualification 8.2.14 Environmental Qualification (EQ) of Electrical Electrical Components Components The Environmental Qualification (EQ)

Environmental Qualification (EQ) of Electrical Electrical Components Components Program Program manages the effects manages effects of thermal, radiation, and cyclic aging through the use of aging evaluations evaluations based on 10 CFR 50.49 qualificationqualification methods. As required by 10 CFR 50.49, environmental environmental qualification program components qualification components not qualified for the current license license term are refurbished, refurbished, replaced, or their qualification extended extended prior to reaching the aging limits established in the evaluation. evaluation. Aging evaluation environmental qualification program for environmental program components are TLAAs for license license renewal.

renewal.

EQ Component Reanalysis Attributes:

Component Reanalysis Attributes: The reanalysis reanalysis of an aging evaluation is normally performed normally performed to extend the qualification qualification by reducing reducing excess conservatism incorporated incorporated in the prior evaluation. Reanalysis Reanalysis of an aging evaluation to extend 3-31

the qualification qualification of a component is performed performed on a routine basis pursuant to 10 CFR 50.49(e) as part of the BVPS EO EQ program.

program. While a component component life-life-limiting condition may be due to thermal, radiation or cyclical aging, the vast majority majority ofof component aging limits component aging limits are are based based on on thermal thermal conditions.

conditions.

Conservatism Conservatism may exist in aging evaluation parameters, such as the assumed ambient ambient temperature temperature of the component, an unrealistically unrealistically low activation activation energy, or in the application application of a component (de-energized (de-energized versus energized).The energized).The reanalysis of an aging evaluation evaluation is documented documented according to BVPS quality assurance assurance program requirements, which require require the verification verification of assumptions assumptions and conclusions. Important Important attributes of a reanalysis reanalysis include analytical methods, include analytical data data collection collection and reduction methods, underlyingunderlying assumptions, acceptance acceptance

criteria, criteria, and corrective corrective actions (if(if acceptance acceptance criteria are not met).These met).These attributes attributes are discussed in the following four subsections.

Analytical Methods: The analytical Analytical Methods: analytical models used in the reanalysisreanalysis of an aging evaluation evaluation are the same same as those previously applied during the original evaluation. methodology is an acceptable evaluation. The Arrhenius methodology acceptable model model for a thermal aging evaluation. For license renewalrenewal radiation aging evaluation, evaluation, 60-year normal radiation dose is established established by extrapolating extrapolating the 40-year 40-year normal dose (40-year(40-year dose X 1.5) plus accident radiation dose. 60-year 60-year cyclical aging is established established in in a similar manner. OtherOther models may be justified on a case-by case basis.

Data Collection Collection and Reduction Methods: Reducing excess conservatism Reduction Methods: conservatism in the the component service service conditions (for example, temperature, temperature, radiation, and cycles) used in the prior aging evaluation evaluation is the chief method method used for a reanalysis.

reanalysis.

Actual Actual monitored service conditions, such such as temperature, temperature, are typically lower lower than the design service service conditions conditions used in the prior aging, evaluationevaluation and, therefore, can support extended thermal life of the equipment.

Underlying Underlying Assumptions:

Assumptions: EO EQ component component aging evaluations contain sufficient sufficient conservatism conservatism to account for most environmental changes environmental changes occurring due to plant modifications and events. When unexpected modifications unexpected adverseadverse conditions are identified identified during operational or maintenance maintenance activities that affect affect the normal operating environment of a qualified environment qualified component, component, the affected EO EQ component is evaluated and appropriate corrective actions are taken, which may include changes to the appropriate corrective the qualification bases qualification bases and conclusions. Excess conservatism Excess conservatism in thermal life analysis analysis may be reduced reduced by reevaluating material material activation activation energy, to justify a higherhigher value that value that would would support extended extended life at elevated temperature. Similar methods methods of reducing excess conservatism in the component component service conditions and material properties material properties used in prior aging evaluations evaluations may be used for radiation and cyclical aging. Any changes to material activation activation energy will be justified.

Acceptance Acceptance Criteria Criteria and Corrective Corrective Actions: If If qualification qualification cannot be extended by reanalysis, the component is refurbished or replaced prior to exceeding the the period for which the current qualification qualification remains valid. A reanalysis is to be be performed in a timely manner (that is, sufficient time is available performed available to refurbish, replace or requalify the component component if if reanalysis is unsuccessful).

unsuccessful).

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The Environmental Environmental Qualification (EQ) of Electric Components Qualification (EQ) Components Program is an existing existing program established to meet BVPS commitments program established commitments for 10 CFR 50.49. It It is consistent with NUREG-1801, NUREG-1 801,Section X.EI, X.EI, "Environmental Qualification Qualification (EQ)

(EQ) of Electric Components." This program program includes includes consideration of operating operating experience to modify qualification experience conclusions, including qualified life.

qualification bases and conclusions, Compliance Compliance with 10 10 CFR 50.49 provides reasonable reasonable assurance assurance that components components can perform perform their intended intended function(s) function(s) during accident accident conditions after experiencing experiencing the effects of inservice inservice aging.

aging.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.14-1 acceptable acceptable because because the applicant has amended amended the LRA such that the Environmental Environmental Qualification Qualification (EQ)

(EQ) of Electric Electric Components ProgramProgram now contains the reanalysis attributes. These attributes are consistent consistent with those described in GALL GALL AMP X.EI. X.E1. Therefore, Therefore, the staffs concern described in concern described RAI B.2.14-1 is resolved.

The applicant stated in its basis documents documents that the Detection Detection of Aging Affects and Monitoring Monitoring and Trending program program sub-element sub-element is consistent consistent with that of GALL AMP X.E1 and was was addressed in basis document document references.

references. However, the staff reviewed these references references and found that they did not specifically specifically address address monitoring or inspection inspection of certain environments environments to to ensure that a component component is within the boundsbounds of its qualification basis, or as aa means to modify qualified life.

the qualified In RAI B.2.14-2, dated May 15, 2008, the staff requested requested that the applicant address address how it performs or inspects certain environments to ensure certain environments ensure that a component component is within the bounds bounds of its qualification basis or aa means to modify the qualified qualified life during the extended extended period of operation. The staff also requested requested the applicant applicant revise the plant procedure procedure to address this this element.

In its response to RAI B.2.14-2, dated June 17, 2008, the applicant applicant stated that 10 CFR 50.49, "Environmental Qualification of Electric Equipment "Environmental Equipment Important to Safety for Nuclear Power Plants," and GALL AMP X.E1, X.E1, do not require detection, monitoring or trending detection, monitoring trending of aging effects effects of in-service in-service components. GALL AMP X.E1, X.E1, elements 4 and 5 state:

4. Detection of Aging Effects: 10 CFR 50.49 does not require the detection Detection detection of aging effects for in-service Monitoring or inspection of certain in-service components. Monitoring environmental conditions or component parameters environmental parameters may be used to ensure ensure that the component component is within the bounds of its qualification qualification basis, or as a means to modify the qualified life.

5. Monitoring Monitoring and Trending:

Trending: 10 CFR 50.49 does not require monitoring and trending of component component condition or performance performance parameters parameters of in-service in-service components to manage components manage the effects of aging. EQ program actions that could be viewed viewed as monitoring monitoring include monitoring how long qualified components components have been installed. Monitoring installed. Monitoring or inspection inspection of certain environmental, environmental, condition, or component parameters parameters may be used to ensure that a component is within the bounds of its qualification qualification basis, or as a means means to modify the qualification.

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applicant also stated that while The applicant while the the BVPS BVPS Environmental Qualification (EQ) of Electrical Electrical Components Program Components Program doesdoes not require monitoring monitoring and trending of component condition condition or performance parameters of in-service components to manage the effects of aging, the program procedure does provide for inspections and monitoring activities, which are acceptable bases to ensure that the component is within the bounds of its its qualification qualification basis or to modify the qualified life through reanalysis. Specifically the EQ Program Program procedure requires that: that:

• " Engineer determine The EQ Engineer determine the established qualified life values by by developing and verifying an aging analysis for establishingestablishing the replacement cycle for electrical equipment replacement equipment and/or associated associated parts.

• • Based on the results of the aging analysis,analysis, the EQ Engineer Engineer designate designate the equipment and part service life values that shall be utilized in in determining the replacement replacement period.

• • Engineer prepare aa Maintenance The EQ Engineer Maintenance Assessment Package Package identifying specific maintenance identifying maintenance requirements requirements to preserve qualification, replacement intervals based on verified qualified replacement qualified life values, and any interface requirements, and maintenance surveillances (such as interface as temperature temperature or radiation monitoring) necessary monitoring) necessary to monitor certain equipment parts that are likely to experience age-related age-related degradation.

• " FENOC implement the maintenance maintenance surveillances necessarynecessary to monitor certain equipment equipment parts that are likely to experience experience age-related age-related degradation.

The applicant further stated that the BVPS EQ procedure procedure is compliant with the requirements requirements of 10 CFR 50.49. GALL AMP X.E1 X.E1 program program sub-elements sub-elements do not require monitoring monitoring or inspecting inspecting certain environments environments ensure to ensure that a component component is within the bounds of its qualification qualification basis, or as aa means to modify modify the qualified qualified life. Therefore, Therefore, no changes required for the BVPS EQ changes are required EQ program.

Because GALL AMP X.E1 program Because program elements elements do not require monitoring and trending require monitoring trending of component condition component condition or performance parameters of in-service performance parameters in-service components components to manage manage the the effects of effects aging,aging, the staff determines determines that the BVPS Environmental Qualification Environmental Qualification (EQ) of(EQ) of Electrical Components Program, Electrical Program, which which is consistent with GALL X.E1, are not GALL X.E1, not required to be be changed.

changed. The staff concludes concludes that the applicant's applicant's implementation implementation procedures provide provide for inspections and monitoring activities to ensure that the component inspections component is within the bounds of its qualified qualified life and that this procedure procedure is in compliance compliance with 10 10 CFR 50.49. Therefore, Therefore, the staff staff finds the applicant's applicant's response acceptable.

Operatingq Operating Experience.

Experience. The staffstaff reviewed the applicant's applicant's operating experience reports, operating experience including including aa sample sample of condition condition reports, reports, and interviewed the applicant's and interviewed applicant's technical personnel to technical personnel to confirm confirm that that the plant-specific plant-specific operating operating experience experience did did not reveal reveal any aging effects effects not not bounded bounded by the industry experience.

experience. The applicant applicant performed performed aa self-assessment self-assessment in 2006 based upon industry operating experience that identified upon industry operating experience that identified discrepancies discrepancies in the information information contained contained within the the applicant's applicant's preventive preventive maintenance database and maintenance database and the associated program associated EQ program documentation.

documentation. The The self-assessment self-assessment found found that that one one of the 94 EQ EQ Maintenance Maintenance Assessment Assessment Packages Packages in the preventive preventive maintenance maintenance database database was deficient deficient and would would have caused 3-34 3-34

installation of equipment installation equipment beyond its qualified qualified life value. A corrective action program program report was was generated to correct the frequency generated frequency of replacement replacement from 22 years to 20 years.

The staff finds that the applicant's operating experienceexperience identified identified above above and those identified in program basis documents, demonstrate documents, demonstrate that the identification identification of program weakness and timely corrective actions as part of the applicant's applicant's EQ program, provide assuranceassurance that program program will effective in maintaining remain effective maintaining equipment equipment within its qualified basis and qualified life.

The staff confirms that the "operating experience" program program element satisfies the criterion defined in GALL Report Report and the guidance guidance found in SRP-LR SRP-LR Section A.1.2.3.1 A.1.2.3.10. O. Therefore, the the staff finds this program element acceptable.

acceptable.

UFSAR UFSAR Supplement. In LRA Section Section A.1.14, the applicant applicant provided the UFSAR supplement for UFSAR supplement Environmental Qualification the Environmental Qualification (EQ)

(EQ) of Electric Components Components Program. The staff reviewed this this Section Section and identified areas in which additional informationinformation was necessary necessary to determine determine whether an adequate summary description of the applicant's program was consistent with the the SRP-LR. The staff noted that, in comparing comparing the UFSARUFSAR supplement supplement with SPR-LR, Table Table 4.4-2, "Examples of FSAR Supplement Supplement for Electrical Electrical Qualification Qualification of Electric Equipment Equipment TLAA Evaluation,"

Evaluation," the applicant applicant did not address the reanalysis attributes.

RAI B.2.14-1, In RAJ B.2.14-1, dated May 15, 2008, the staff requested requested that the applicant applicant provide this provide this information information in the FSAR supplement.

In its response to RAI B.2.14-1, B.2.14-1, dated dated June June 17, 2008, the applicant applicant stated that LRA LRA Section A.1.14 does SectionA.1.14 does not provide provide sufficient details regarding the "EQ Component Reanalysis Component Reanalysis Attributes" as described described in GALL AMP X.E1. X.EI. The applicant provided provided the additional details and revised the LRA Section Section A.1.14 Program Description Description to read:

A. 1.14 Environmental A.1.14 Environmental Qualification (EQ) Components Program (EQ) of Electrical Components Environmental Qualification The Environmental Qualification (EQ) of Electrical Components Program manages the effects of thermal, radiation, manages radiation, and cyclic aging through the use of evaluations based on 10 CFR 50.49 qualification aging evaluations qualification methods. As required required byby 10 CFR 50.49, environmental environmental qualification qualification program program components components not qualified qualified for the current license license term are refurbished, refurbished, replaced, replaced, or their qualification qualification extended extended prior to reaching the aging limits established in the evaluation. Aging evaluation environmental qualification for environmental qualification program program components components are TLAAs for license license renewal.

EQ Component Component Reanalysis Attributes:

Attributes: The reanalysis of an aging evaluation evaluation is normally performed to extend the qualification normally performed qualification by reducing excess conservatism incorporated incorporated in the prior evaluation. Reanalysis of an aging evaluation evaluation to extend the qualification qualification of a component is performed on a routine basis pursuant to 10 CFR 50.49(e) 50.49(e} as part of the BVPS EQ program. While a component component life-limiting life-limiting condition condition may be due to thermal, radiation or cyclical cyclical aging, the vast majority component aging limits are based on thermal conditions.

majority of component Conservatism Conservatism may exist in aging evaluation parameters, such as the assumed evaluation parameters, ambient temperature temperature of the component, an unrealistically unrealistically low activation activation energy, or in the application application of a component component (de-energized versus energized).energized). The The 3-35

reanalysis of an aging evaluation evaluation is documented documented according according to BVPS quality program requirements, assurance program requirements, which require the verification verification of assumptions assumptions and conclusions.

conclusions. Important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying underlying assumptions, acceptance acceptance criteria, and corrective actions (if acceptance acceptance criteria are not met). These These attributes are discussed in the following four subsections.

,'.f.

Analytical Methods:

Methods: The analytical models used in the reanalysis analytical models reanalysis of an aging evaluation evaluation are the same same as those previously applied during during the original evaluation.

evaluation. The Arrhenius methodology acceptable model for a thermal methodology is an acceptable aging aging evaluation.

evaluation. For license renewal radiation evaluation, 60-year radiation aging evaluation, 60-year normal radiation dose is established by extrapolating extrapolating the 40-year normal dose dose (40-year (40-year dose dose X 1.5) plus accident accident radiation dose. 60-year cyclical aging is established established in a similar manner. OtherOther models may be justified on a case-by case basis.

Data Collection Collection and Reduction Reduction Methods: ReducingReducing excess conservatism conservatism in the the component service service conditions (for example, temperature, radiation, and cycles) evaluation is the chief method used for a reanalysis.

used in the prior aging evaluation Actual monitored monitored service conditions, such as temperature, temperature, are typically lower than the design service service conditions conditions used in the prior aging, aging, evaluation and, therefore, can support extended thermal life of the equipment.

Underlying Assumptions:

Underlying Assumptions: EQ component aging evaluations evaluations contain sufficient sufficient environmental changes conservatism to account for most environmental changes occurring occurring due to plantplant modifications and events. When unexpected modifications unexpected adverse adverse conditions are identified identified during operational operational or maintenance maintenance activities activities that affect affect the normalnormal operating operating environment environment of a qualified qualified component, the affected affected EQ component is evaluated and appropriate appropriate corrective actions are taken, which may include changes to the the qualification bases and conclusions. Excess Excess conservatism in thermal thermal life analysis analysis may be reduced reduced by reevaluating material activation energy, to justify a higher reevaluating material higher value that would support extended life at elevated elevated temperature. Similar methods methods of reducing reducing excess excess conservatism conservatism in the component service conditions and material properties properties used in prior aging evaluations may be used for radiation radiation and cyclical aging. Any changes to material activation energy will be justified. justified.

Acceptance Acceptance Criteria and Corrective Corrective Actions: If If qualification qualification cannot be extended extended by reanalysis, the component component is refurbished or replaced prior to exceeding exceeding the the period for which the current current qualification qualification remains valid. A reanalysis is to be be performed in a timely manner performed manner (that is, sufficient sufficient time is available available to refurbish, replace or re-qualify re-qualify the component component ifif reanalysis is unsuccessful).

The Environmental Environmental Qualification (EQ) (EQ) of Electric Components Components Program Program is an an existing program established to meet BVPS commitments commitments for 10 10 CFR 50.49. It is consistent with NUREG-1801, NUREG-1801, Section Section X.EI, "Environmental Qualification (EQ) of "Environmental Qualification Electric Components." This program includes consideration Electric consideration of operating operating experience experience to modify modify qualification bases and conclusions, including qualified qualified life.

Compliance with 10 CFR 50.49 provides reasonable reasonable assurance assurance that components components can perform their intended function(s) function(s} during accident conditions conditions after experiencing the effects of inservice experiencing inservice aging.

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Based on its review, the staff finds the applicant's applicant's response to RAI B.2.14-1 acceptable because B.2.14-1acceptable because the applicant has provided provided additional additional details regarding the EQ component reanalysis EO component reanalysis attributes attributes and has revised the LRA Section A.1.14 Program Description Description to now contain the reanalysis reanalysis attributes.

attributes. The staff finds the applicant's applicant's response acceptable. With the UFSAR supplement supplement described described above, the staff finds that the informationinformation in the UFSAR supplement supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d). 54.21(d).

Conclusion. Based on its review, the staff finds the applicant's Environmental Qualification applicant's Environmental Qualification (EO)

(EQ) of Electrical Component acceptable because it is consistent with the GALL Report and Component Program acceptable bounded by the conditions the plant is bounded conditions set forth in the GALL Report for this AMP. The staff staff concludes concludes that the applicant has demonstrated demonstrated that the effects of aging will be adequately managed so that the intended intended function(s) function(s) will be maintained maintained consistent consistent with the CLB for the the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the the FSAR supplement supplement and the amendments amendments as described described above for this AMP and concludes that itit provides an adequate summary descriptiondescription of the program, as required by 10 10 CFR 54.21(d).

54.21 (d).

External Surfaces 3.0.3.1.9 External Surfaces Monitoring Monitoring Program Summary of Technical Information in the Application.

Technical Information Application. In In LRA Section B.2.15, the applicant applicant described described the new External Surface Surface Monitoring Program, and claimed consistency consistency with GALL AMP XI.M36, XI,M36, "External Surface Surface Monitoring." The applicant applicant stated that the program will consist of inspections to monitor the external periodic inspections external surfaces surfaces of in-scope steel components components and other other metal components components for material degradation and leakage, material degradation leakage, and periodic periodic inspection inspection of in-scope in-scope elastomer components for hardening, hardening, loss of strength strength or cracking cracking through physical manipulation. The program will also manage manage reduction reduction of heat transfer of radiator fins.

Staff Evaluation. The staff reviewed reviewed those portions of the applicant's External External Surface Surface Monitoring Program Monitoring Program that the applicant applicant claimed consistency consistency with GALL GALL AMP XI.M36 XI,M36 and found they are consistent with this GALL AMP. The staff also confirmed that the plant program contains all of the elements elements of the referenced referenced GALL program and the conditions at the GALL Report program the plant are bounded by the conditions for which the GALL Report is evaluated. evaluated. The staff heldheld interviews with the applicant's onsite interviews applicant's technical technical personnel to confirm confirm these results.

The staff also reviewed the applicant's license license renewal basis document for the External basis document External Surface Surface Monitoring Monitoring Program and confirmed that the program scope includes all those systems for which the applicant credited this program program in its AMR results.

The staff finds the applicant's applicant's External Surface Monitoring acceptable because Monitoring Program acceptable because itit conforms to the recommended conforms recommended GALL AMP XI,M36. XI.M36.

GALL GALL AMP XI,M36XI.M36 is credited for managing the aging effect of loss of material material due to general, pitting and crevice corrosion for steel components. However, the applicant applicant expanded the scope scope to include additional additional aging effects and materials.

B.2.15-1, dated In RAI B.2.15-1, dated May 22, 2008, the staff requested that the applicant justify the following:

(a) How this program program will manage reduction of heat transfer of ERF diesel generator generator jacket jacket water radiator fins; (b)(b) How this program will manage hardening, loss of strength and cracking 3-37

of elastomers; elastomers; and (c) Why crediting this program for managing managing loss of material aluminum, material for aluminum, CASS, stainless stainless steel, copper alloy and nickel-alloy nickel-alloy material is not considered considered an exception to to the GALL Report.

In its response to RAI B.2.15-1 B.2.15-1(a(a and b), dated July 24, 2008, the applicant applicant stated stated the following:

Item (a). The applicant applicant stated that the program will require inspection of radiators radiators associated associated with dieseldiesel engines and diesel diesel driven driven equipment. The radiator fins fins are externally externally visible and can be inspected for build-up of dust, dirt, and debris debris that could result in a reduction of heat transfer. The applicant applicant also referred referred to its response to RAI 3.3.2.7-1, response 3.3.2.7-1, provided provided in its letter dated June 9, 2008. In that RAI, 9,2008. RAI, the staff requested requested that the applicant justify whether tubes are included included in this this line item for radiator fins. The applicant responded responded that the LRA SectionSection B.2.15 B.2.15 was revised to state that inspection inspection is required for radiators radiators (fins and tubes) associated associated with diesel engines and diesel driven equipment for build-up of dust, dirt and debris. The applicant applicant also revised UFSAR Supplement Section A.2.15 to Supplement Section identify both fins and tubes.

identify The staff reviewed reviewed the applicant applicant response and noted that the radiator fins and tubes, which which are externally accessible, will be inspected inspected for dust, dirt and debris. Because accumulation of dust, Because accumulation dirt and debris could cause a reduction in heat transfer, inspection inspection and appropriate appropriate corrective corrective actions to clean the surfaces would ensure that the aging effects will be appropriately appropriately managed.

Therefore, the staff finds the applicant's responseresponse to RAI B.2.15-1 B.2.15-1 (a) acceptable and concludes concludes that the External External Surface Surface Monitoring Program Program will adequately manage manage the aging effects of reduction reduction of heat transfer for radiator fins and tubes associated associated with diesel engines engines and diesel driven equipment equipment through the period of extended operation.

Item (b). For aging management management of elastomers, the applicant referenced its applicant referenced response response to RAIs RAls 3.3.2.3-03, 3.4.2.3-3, RAI 3.3.2.2.5.1-1, 3.3.2.3-03,3.4.2.3-3, 3.3.2.2.5.1-1, and 3.4.2.3-1A, provided provided in its letter letter dated July 21, 21, 2008. In this response, the applicant applicant stated that itit will perform repetitive maintenance maintenance tasks prior to the period of extended operation, elastomeric components operation, to replace the elastomeric components identified identified in LRA Sections 3.1, 3.1, 3.2, 3.3, and 3.4, such that those components components are classified classified as "short-lived" and not subject subject to aging management management pursuant to 10 CFR 54.21(a)(1)(ii).

54.21(a)(1)(ii). The The remainder of the applicant's remainder response addressed applicant's response addressed aging management management of elastomeric flexible connections elastomeric connections in ventilation systems, which are the only remaining elastomeric elastomeric components subject to aging management.

components subject For elastomeric elastomeric components components in the ventilation systems, the applicant stated that its External Monitoring Program contains increased Surface Monitoring increased scope beyond GALL AMP XI.M36 to include include management of elastomeric aging management elastomeric flexible connections.

connections. The applicant originally did not identify the increased increased scope of the elastometer elastometer nor include an evaluation evaluation of the 10 program program elements elements related to the increased increased scope in the External External Surfaces Surfaces Monitoring Monitoring Program discussion discussion in LRA Appendix Appendix B. Therefore, the applicantapplicant provided provided a 1 10-element O-element summary of the increased increased scopescope that addresses addresses elastomers in its response response to RAls RAIs 3.3.2.2.5.1-1 3.3.2.2.5.1-1 and 3.4.2.3-1A.

3.4.2.3-1A.

In its response, the applicant also summarized how its External External Surface Monitoring Program will Monitoring Program manage the aging effect of hardening, hardening, loss of strength and cracking of elastomeric flexible flexible connections. The applicant applicant stated that physical manipulation of elastomerelastomer components, such as as 3-38 3-38

by pinching or prodding prodding flexible connections in ventilation systems will be performed, which will identification of elastomer aging effects. The applicant further stated that cracking aid in identification cracking of elastomer components elastomer components becomes becomes evident at the outside radius radius of elastomer elastomer deformations deformations as the the cracks open, and changes in materialmaterial properties, such as hardening hardening and loss of strength, strength, can can be detected during manipulation elastomer components by the relative inflexibility of the manipulation of elastomer the component, component, or by the failure of the component component to return to its previous shape or configuration.

configuration.

Additionally, the applicant stated that as the external environment environment of ventilation systems is similar similar to the internal environment, the condition of the external surface expected to be surface is expected be representative of the internal surface representative surface condition.

The staff reviewed the applicant's RAI responses and the 10 10 element summary summary description.

description. OnOn the basis that physical manipulation manipulation of elastomeric components components will be performed to inspect for for cracks, and changes in material properties, the staff finds the applicant applicant response acceptable.

acceptable.

Since the GALL GALL AMP XI.M36 XI.M36 does does not address elastomeric elastomeric components, components, the staff finds that these physical manipulation activities in addition to the visual inspection, will adequately physical manipulation adequately manage the aging effects of cracking, and change in material properties manage properties of elastomeric elastomeric components in ventilation ventilation environment environment through the period of extendedextended operation.

In its response to RAI B.2.15-1(c),

B.2.15-1(c), dated July 24,2008, 24, 2008, the applicant stated the following:

following:

applicant responded that loss of material Item (c). The applicant material from the external surface external surface of stainless steel (or other metals) will be evident by surface irregularities irregularities or localized discoloration before loss of function occurs. Although discoloration before materials other Although materials than steel are not discussed discussed in the GALL Report Report for this program, identification identification of the loss of material aging effect for other metals metals is amenable amenable to the same same types of visual inspections.

The staff reviewed the response response and concurs concurs that pitting and crevice corrosion will show similar similar characteristics for stainless steel, copper alloy or aluminum as itit shows for steel. In that regard, characteristics all metallic components would corrode corrode similarly and and visual inspection will detect age related degradation. Based on degradation. on its review, the staff finds the applicant's response acceptable acceptable and concludes that the External Surface Monitoring Monitoring Program will adequately manage the aging adequately manage effects of loss of material material on external surfaces surfaces of all metallic components components through the period of extended operation.

operation.

During During the regional regional inspection in June June and July July 2008, the staff requested requested additional additional information information from the applicant for "detection of aging effects" programprogram element to clarify what is meant meant by the term "not readily accessible," and to incorporate incorporate examples of those inaccessible inaccessible areas areas and when and how external surfacessurfaces of equipment in those areas will be inspected. inspected.

In its letter dated September 8, 2008, the applicant applicant stated:

surfaces in areas that are not readily Component surfaces readily accessible during plant operations operations and refueling outages outages will be inspected at such intervals that will provide reasonable assurance assurance that the effects of aging will be managed managed such applicable components that applicable components will perform their intended intended function during the period of extended extended operation. Examples Examples of areas that are not readily accessible accessible are are Intake Structure (and Auxiliary Intake Auxiliary Intake Structure) bays and River Water Service Water Service Water Valve Pits. Valve pits are located adjacent adjacent to the southern southern end of the the 3-39

Intake Structure, adjacent to the northern end of the Unit 2 Safeguards Intake Safeguards Area, and in the yard areas where where the Auxiliary River Water system connects to the the River Water system. These areas areas are accessible inspections during specific accessible for inspections specific activities such as bay cleaning, maintenance, maintenance, clearance operations, or valve valve stroke tests. Areas such as pipe trenches trenches are to be inspected inspected when the areas areas are made made accessible for maintenance maintenance or other reasons. If If only partial inspections inspections are possible possible for an area area such as a pipe trench, the extent of condition condition of any deficiencies deficiencies identified identified are to be evaluated evaluated to provide assurance that any inaccessible components remaining inaccessible components (such as within pipe trenches) trenches) will remain remain capable capable of performing their intended intended functions, or the remaining remaining portion of the the normally inaccessible inaccessible areas areas are to be exposed exposed for inspection.

The staff reviewed reviewed the applicant response and noted noted that the applicant has identified the areas areas that are not readily accessible, and defined how how and when the inspections inspections will be performed.

performed. On the basis that these inaccessible inaccessible areas will be inspected inspected during cleaning, maintenance or cleaning, maintenance performance performance testing, and that results of any partial inspection will be evaluated evaluated and results applied to the remainder of the inaccessible inaccessible area, the staff finds the applicant response applicant response acceptable and considers acceptable considers the issue closed.

Operating Operating Experience.

Experience. The staff reviewed the applicant's applicant's operating operating experience experience and interviewed interviewed the applicant's technical personnel personnel to confirm that the plant-specific plant-specific operating operating experience experience did did not reveal any aging effects not bounded bounded by the GALL Report. In the LRA, the applicant applicant stated that there is no operating operating experience with the effectiveness effectiveness of the program becausebecause itit is a new program. The staff issued a generic RAI B.2-1, B.2-1, Part 1 by letter dated May 22, 2008, requesting requesting the applicant applicant to discuss recent observed material degradation observed material degradation during the implementation implementation of other existing activities activities that relate to the aging effects that will be managed managed by the new new program program and provide the results in the "operating experience" element for that new new program. Additionally, in RAI B.2-1, A. 1.2.3.10.2, the applicant was requested B.2-1, Part 2, as stated in SRP-LR, Appendix A.1.2.3.10.2, to include a commitment commitment to provide operating experienceexperience in the future for new programs programs to to confirm their effectiveness.

effectiveness.

In its letter letter dated August 22, 2008, in response to RAI B.2-1, B.2-1, Part 1, the applicant responded that corrosion corrosion of external surfaces surfaces has been reported in the course of performing surveillance surveillance maintenance programs, and system walk-downs at BVPS. The applicant tests, preventive maintenance applicant stated that in 2006, a walkdown of the BVPS Service Water Water System identified a very small leak in the Service Water one-inch Water one-inch diameter piping. The applicant further stated that the leakage leakage rate was estimated estimated to be less than one drip per minute, with no spray that could impact other other equipment, and a condition report was written and corrective corrective action taken to repair repair the pipe.

In its letter dated August 22, 2008, in response response to Part 2, the applicant amendedamended the LRA to include a new Commitment No. 29 in Table A4.1 for Unit 1 and Commitment No. 28 in in Table A5.1 for Unit 2, to perform a program self-assessment of all new license renewal aging program self-assessment management management programs, to be completed completed five (5) (5) years after entering the period of extended extended operation.

On the basis that the applicant applicant ha identified an example of plant operating operating experience experience observed performance of system walkdown, the staff finds the response acceptable during the performance acceptable and considers the issue in RAI B.2-1, considers B.2-1, Part 1 closed. On the basis that the applicant has amended the LRA to include a new commitment commitment to confirm confirm the effectiveness effectiveness of the new new license license renewal 3-40

aging management incorporation of operating experience, programs based on the incorporation management programs experience, the staffstaff finds finds response acceptable the response acceptable and considers the issue in B.2-1, B.2-1, Part 2 closed.

The staff confirms that the "operating experience" program program element element satisfies the criterion criterion defined in GALL guidance found in SRP-LR GALL Report and the guidance SRP-LR Section Section A. 1.2.3.10.

A.1.2.3.1 O. Therefore, the the staff finds this program element acceptable.

program element UFSAR Supplement. In LRA Section A provided the UFSAR supplement 1.15, the applicant provided A1.15, supplement for External Surface Monitoring the External Monitoring Program. The staff verified that the UFSAR supplement description for the External summary description Monitoring Program External Surface Monitoring Program conforms to the guidance guidance found in SRP-LR Table 3.2-2. The staff also verified that the applicant committed applicant has committed (Commitment Nos. 6 and 7) to implementimplement its new External Monitoring Program External Surfaces Monitoring Program in in UFSAR Supplement Tables A.4-1 and A.5.1, UFSAR Supplement A.5.1, respectively.

Based on this review, the staff finds that FSAR Supplement Section A.1.15 A. 1.15 provides provides an acceptable FSAR Supplement acceptable Supplement summary summary description description of the applicant's External Surfaces Surfaces Monitoring Program because Monitoring Supplement summary because it is consistent with the FSAR Supplement description summary description External Surfaces Monitoring Program, for External Program, as required by 10 CFR 54.21 54.21(d).

(d).

Conclusion. Based on its review, the staff finds the applicant's External Surface Monitoring Surface Monitoring Program acceptable Program because it is consistent with the GALL acceptable because GALL Report and the plant is bounded by by the conditions set conditions s'et forth in the GALL Report for this AMP. The staff also finds that the applicant's applicant's External Monitoring Program will adequately manage the aging effects so that the External Surface Monitoring the intended intended functions will be maintained consistent with the CLB for the period maintained consistent period of extended required by 10 operation, as required 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement UFSAR supplement provides an adequate for this AMP and finds that it provides adequate summary summary description program, as description of the program, as required by 10 CFR 54.21(d).

Flow-Accelerated Corrosion 3.0.3.1.10 Flow-Accelerated Corrosion Program Summary of Technical Information Summary Information in the Application. In LRA Section B.2.18, the applicant applicant described the existing Flow Accelerated described Accelerated Corrosion Corrosion Program Program and claimed consistency with GALL AMP XI.M17, XI.M17, "Flow-Accelerated "Flow-Accelerated Corrosion."

The applicant stated that this program program is based on EPRI guidelines guidelines in Nuclear Nuclear Safety Analysis Analysis "Recommendations for an Effective Center-202L-R2, "Recommendations Center-202L-R2, Accelerated Corrosion Program."

Effective Flow Accelerated program includes analyses to determine critical locations. The applicant The program performs initial applicant performs determine the extent of thinning, using ultrasonic or other approved inspection inspections to determine inspection techniques inspections to confirm the predictions.

techniques and follow-up inspections predictions.

Staff Evaluation. The staff reviewed those portions of the applicant's Flow-Accelerated Flow-Accelerated Corrosion Program that the applicant conSistency with GALL AMP XI.M17 and found applicant claimed consistency found they are consistent consistent with this GALL AMP. The staff also confirmed that the plant program contains contains all of the elements of the referenced referenced GALL program and GALL Report program and the conditions at the the plant are bounded by the conditions for which which the GALLGALL Report is evaluated.

evaluated. The The staff held held interviews with the applicant's technical personnel onsite interviews personnel to confirm these results.

The staff reviewed the applicant's license renewalrenewal basis documents for the Flow-Accelerated Flow-Accelerated Corrosion Program and confirmed that the program's program's scope includes includes the systems and and 3-41

components components that could be affected affected by flow-accelerated flow-accelerated corrosion (FAC). (FAC). The staff finds the the applicant's Flow-Accelerated applicant's Flow-Accelerated Corrosion Corrosion Program Program acceptable acceptable because it conforms to the the recommended GALL recommended GALL AMP XI.M17.

The staff reviewed reviewed the operating operating experience experience provided in the LRA and interviewed interviewed the applicant's applicant's technical technical personnel to confirm that the plant-specific plant-specific operating experience did not reveal any operating experience aging effects not bounded bounded by the GALL GALL Report. The staff also confirmed that applicable applicable aging aging effects and industry industry and plant-specific experience have been plant-specific operating experience been reviewed by the the evaluated in the GALL Report.

applicant and are evaluated Operatinq Experience.

Operating Experience. The staff also reviewed the applicant's applicant's "operating experience" discussiondiscussion provided in the applicant's license renewal basis document provided document for the Flow-Accelerated Flow-Accelerated Corrosion Program. Additionally, the staff reviewed a sample of condition reports and confirmed Program. confirmed that thethe applicant has identified FAC and has implemented appropriate implemented appropriate corrective actions. The staff staff noted that in the last outages for Units 1 (1 (1R17), February-April 2006 and Unit 2 (2R12),

R17), February-April October-November 2006, the applicant inspected over 70 locations per unit and performed October-November performed fifteen additional examinations per unit as expanded scope. The staff also noted additional examinations noted that the the applicant schedules and implements applicant implements replacements of those steel components components that are determined determined to have have an unacceptable unacceptable amount amount of FAC-induced FAC-induced corrosion corrosion or whose rate of corrosion predicts corrosion predicts that the components will be unacceptable unacceptable for service prior to reaching reaching thethe next scheduled inspection scheduled inspection outage (usually scheduled scheduled RFOs). The staff reviewed the results of the outages from Units 1 and 2 and confirms that the applicant has implemented implemented appropriate appropriate corrective actions.

corrective The staff verified that the applicant applicant has evaluated evaluated the relevant relevant pressurized-water pressurized-water reactor (PWR) operating experience identified operating experience identified in NRC Bulletins, GLs, and Information Information notices the notices listed in the Reference Section of GALL Reference GALL AMP X1.17,XI. 17, for their relevance relevance to the Flow-Accelerated Flow-Accelerated Corrosion Program. The applicant applicant has used this information information or has performed an engineering engineering evaluation to to justify that the relevant relevant operating experience experience is not applicable applicable to the plant designs designs for Units 1 and 2; or, has used the operating operating experience experience as the basis for including components evaluated including components evaluated in the generic generic communications communications in its Flow-Accelerated Flow-Accelerated Corrosion Program. Program. Thus, based on this this review, the staff concludes concludes that the applicant's program incorporates relevant operating program incorporates experience experience on FAC identified in applicable applicable NRC generic generic communications.

Thus, based on this review, the staff has confirmed confirmed that the applicant applicant has addressed addressed thethe relevant operating experience relevant operating experience that is applicable applicable to the applicant's Flow-Accelerated Corrosion applicant's Flow-Accelerated Program, and finds that the applicant's Flow-Accelerated Corrosion Program, applicant's Flow-Accelerated Program, with thethe corrective corrective actions actions discussed in the LRA, has been effective effective in identifying, monitoring, monitoring, and correcting the effects of FAC and can be expected expected to ensure that piping wall thickness will be be maintained above the minimum required by design.

UFSAR Supplement.

Supplement. In LRA Section A Al.18, 1.18, the applicant provided provided the UFSAR supplement supplement for the Flow-Accelerated Flow-Accelerated Corrosion Program. The staff verified that the UFSAR supplement Corrosion Program. supplement ,

summary description Flow-Accelerated Corrosion description for the applicant's Flow-Accelerated Corrosion Program Program conforms conforms to thethe staff's guidance guidance found in SRP-LR SRP-L~ Table Table 3.4-2.

Based on this review, the staff finds that FSAR Supplement Supplement Section A. 1.18 provides an A.1.18 an acceptable acceptable FSAR Supplement Supplement summary description description of the applicant's Flow-Accelerated Flow-Accelerated 3-42

Corrosion Corrosion Program because itit is is consistent consistent with the the FSAR FSAR Supplement Supplement summary description description for for Flow-Accelerated Corrosion Program found in the Flow-Accelerated the SRP-LR.

Conclusion. Based on its review, review, the staff finds the applicant's applicant's Flow-Accelerated Flow-Accelerated Corrosion acceptable because it is Program acceptable is consistent with the GALL Report Report and the plant is bounded by the conditions set forth in in the GALL GALL Report for this AMP. The staff also finds that the program will adequately manage the aging effects so that the intended intended functions will be maintained maintained consistent with the CLB for the period of of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement supplement for this AMP and finds that itit provides an adequate summary description of the program, as required by by 10 CFR 54.21 54.21(d).

(d).

3.0.3.1.11 Inaccessible 3.0.3.1.11 Inaccessible Medium-Voltage Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Requirements Program Qualification Requirements Summary of Technical Summary Information in the Application. In LRA Section B.2.21, Technical Information B.2.21, the applicant applicant stated that the Inaccessible Inaccessible Medium-Voltage Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Environmental Qualification Requirements Requirements Program is a new program that is consistent with GALL AMP XI.E3, Medium-Voltage Cables Not Subject to 10 CFR 50.49 XI,E3, "Inaccessible Medium-Voltage Environmental Qualification Environmental Qualification Requirement."

The applicant applicant also stated that the purpose of this AMP will be to demonstrate demonstrate that inaccessible, non-EQ medium-voltage medium-voltage cables, susceptible to aging effects caused by moisture and voltage voltage managed such that there is reasonable stress, will be managed reasonable assurance that the cables will perform their intended intended function in accordance accordance with the CLB during the period of extended extended operation.

operation.

Staff Evaluation.

Evaluation. The staff reviewed the LRA and onsite bases documents documents related to the the Inaccessible Medium-Voltage Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Environmental Qualification Qualification Requirements Program in which the applicant Requirements consistency with GALL AMP X1.E3.

applicant claimed consistency The staff reviewed the applicant's inaccessible medium-voltage applicant's inaccessible medium-voltage cable documents documents and confirmed confirmed them to be consistent consistent with GALL GALL AMP XI.E3.

X1.E3. The staff also confirmed confirmed that the plant program program contains all a/l of the elements elements of the referenced GALL GALL program and that the conditions conditions at the plant are bounded by the conditions conditions for which the GALLGALL report is evaluated.

evaluated. The staff held onsite onsite interviews interviews with the applicant's applicant's technical personnel personnel to confirm these results. Within the Scope Scope of of Program element, the staff staff found that the applicant define the elements applicant did not define elements "significant moisture" and "significant voltage," contrary contrary to GALL AMP XI.E3.XI,E3.

In RAI B.2.21-1, B.2.21-1, dated May 15, 15, 2008, the staff requested that the applicant applicant define define the program elements "significant moisture" and "significant voltage" or provide provide aa technical technical justification for justification for why the definition is not required.

In its response response to RAI RAI B.2.21-1, B.2.21-1, dated June June 17, 17, 2008, the applicant applicant stated that the Scope of Program Program element element of of LRA, Section B.2.21, "Inaccessible Medium-Voltage B.2.21, "Inaccessible Medium-Voltage Cables Not Subject Subject to 10 CFRCFR 50.49 50.49 Environmental Environmental Qualification Qualification Requirements Requirements Program" for BVPS, BVPS, is is revised revised to to include include the definition of definition of "significant moisture" and and "significant voltage," as defined as defined in in GALL AMP AMP XI.E3XI,E3 as follows:

"Significant moisture" exposure exposure is defined defined as periodic periodic exposure exposure to moisture moisture that lasts more than a few days days (e.g., cable cable in standing water). Periodic exposure exposure to to 3-43 3-43

moisture which lasts less than a few days (Le., (i.e., normal rain andand drain) is not not significant.

"Significant voltage" exposure is is defined as being subjected to system voltage voltage for more than twenty-five percent (25%) of the time.

review, the staff finds the applicant's response Based on its review, response to RAI B.2.21-1 acceptable acceptable because because the applicant amended LRA Section B.2.21 to add definitions for "significant moisture" and voltage" that are consistent with GALL AMP XI.E3. Therefore, the staff's concern significant voltage" described in RAI described RAI B.2.21-1 is resolved.

Under the program program description, GALL AMP XI.E3 identifies NUREG/CR-5643, NUREG/CR-5643, IEEE Std. P1205, TR-1 09619, and EPRI SAND96-0344, EPRI TR-109619, EPRI TR-103834-P1-2 as the basis for technical information and guidance. However, the applicant applicant did not identify identify these documents as the basis basis B.2.21, "Inaccessible Medium-Voltage for its BVPS AMP B.2.21, Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Environmental Requirements Program."

In RAI B.2.21-2, dated May 15, 2008, the staff requested that the applicant applicant identify specific specific documents used as technical information and guidance considered in the Inaccessible Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Medium-Voltage Environmental Qualification Qualification Requirements Program or provide a justification as to why consideration Requirements consideration of the above documents are not necessary.

In response to RAI B.2.21-2, B.2.21-2, dated June 17, 2008, the applicant applicant stated that the technical information information and guidance guidance of NUREG/CR-5643, NUREG/CR-5643, IEEE Std. 1205, SAND 96-0344, and EPRI TR-1 09619 TR-109619 were used in developing its "Inaccessible Medium-Voltage "Inaccessible Medium-Voltage Cables Not Subject to to 10 CFR 50.49 Environmental Environmental Qualification Qualification Requirement Requirement Program as described in LRA Section B.2.21. These documents Section B.2.21. documents are listed as cited references references in the BVPS Program Evaluation Document Document for the Inaccessible Inaccessible Medium-Voltage Medium-Voltage Cables Not Subject to 10 10 CFR 50.49 Environmental Qualification Environmental Qualification Program.

Full Reference Listing:

1. NUREG/CR-5643, NUREG/CR-5643, "Insights Gained From Aging Research," dated March, March, 1992.

1992.

2. IEEE Standard Standard 1205-2000, 1205-2000, "IEEE "IEEE Guide Guide for Assessing, Monitoring, Monitoring, and Mitigating Mitigating Aging Aging Effects on Class 1 E Equipment Equipment UsedUsed in Nuclear Generating Stations,"

Nuclear Power Generating Revision Revision of IEEE IEEE Std. 1205-2000, 1205-2000, March March 30, 2000.

3. SAND96-0344, SAND96-0344, "Aging Management Management Guideline Guideline for Commercial Commercial Nuclear Power Power Plants - Electrical Electrical Cable and and Terminations," September, 1996.

4. EPRI TR-1 09619, "Guideline for the Management Management of AdverseAdverse Localized Localized Equipment Equipment Environment,"

Environment," Revision Revision Final, June, 1999.

1999.

5. EPRI TR-103834-P1-2, TR-103834-P1-2, "Effects of Moisture Moisture on the Life of Power Power Plant Cables,"

Revision Revision Final, August, 1994.

3-44 3-44

Based on its review, the staff finds the applicant response to RAI B.2.21-2 B.2.21-2 acceptable acceptable because because confirmed the use of technical applicant has confirmed the applicant guidance of the staff and technical information and guidance industry guidance documents industry guidance documents to develop Inaccessible Medium-Voltage develop the Inaccessible Medium-Voltage Cables Not Subject 10 CFR 50.49 Environmental to 10 Environmental Qualification Qualification Requirements Program. The staff notes that the Requirements Program. the applicant applicant has listed these documents documents in its program evaluation program evaluation document. Therefore, the staff's staff's concern described in RAI B.2.21-2 concern described B.2.21-2 is resolved.

Operating Experience. The staff reviewed the operating Operating operating experience experience reports, including including a sample sample of condition reports, and interviewed interviewed the applicant's applicant's technical staff to confirm that the plant-experience did not reveal any degradation specific operating experience degradation not bounded by industry experience. LRA Section B.2.21 states that the inaccessible inaccessible medium-voltage medium-voltage cables is a new program for which there is not plant-specific plant-specific operating experience experience for program effectiveness.

Industry and plant-specific Industry plant-specific operating operating experience experience will be evaluated in the development development and implementation implementation of this program. GALL AMP XI.E3 states states that operating experience experience has shown that cross linked linked polyethylene polyethylene or high molecular molecular weight polyethylene polyethylene insulation materials are insulation materials most susceptible susceptible to waterwater tree formation. The formationformation and growth growth of water trees varies directly directly with operating voltage. Also, minimizingminimizing exposure exposure to moisture moisture minimizes the potential for the the development of water development water treeing.

treeing.

In LRA Section B.2.21, the applicant Section B.2.21, applicant also states that currently it has a manhole inspection program which identifies program which identifies and evaluates water collection in the manholes.

manholes. The applicant further stated that this prevention prevention program program has been effective in monitoring monitoring and evaluating evaluating thethe exposure exposure of water to cable and cable supports located located in manholes. The staff noted during the the audit that in Corrective Report Report 04-03545, 04-03545, the applicant discovered discovered that the Manhole EMH-1 9A Manhole 1EMH-19A Duct 944 had 34 inches of water in itit during performance performance of its manhole manhole inspection inspection for water induced damage in 2004. The water was removed, and the lower induced damage lower cable tray was severely deteriorated deteriorated to the point where one of the ladder runs of the tray had fallen out and the tray tray support support brackets were also badly rusted. The applicant's manhole inspection was last applicant's manhole performed in September September 2006. The findings included included missing seals, cracked walls, corroded supports, and water intrusion, intrusion, but no cable damage was found. In reviewing cable damage corrective reviewing the corrective report, the staff noted noted that certain certain manholes had chronic flooding problems. These manholes, numbered 1EMH-8A, numbered EMH-BA, BB, 8B, and 15, are located located below grade near the intake intake structure and and repeatedly had water levels of 10 10 to 15 feet. Manholes Manholes 1EMH - BA&BB 8A&8B contain safety-related safety-related cables cables from both Units 1 and 2. Based on the above, the staff was concerned concerned that the the applicant's corrective applicant's corrective actions and periodic inspection for water collection in the manholes manholes were not adequate.

In RAI B.2.21-3, dateddated May 15, 200B, 2008, the staff requested that the applicant staff requested applicant provide a technical justification as to (a) how the applicant's applicant's proposed proposed once once every two-year water inspection of the the manholes adequate to ensure manholes is adequate ensure that the cables are kept from experiencing significant moisture moisture during the period of extended extended operation; operation; (b) how the applicant applicant adjusts the inspection inspection frequency based

. based on operating experience, operating experience, and (c) what are the applicant's address applicant's corrective actions to address submerged submerged cable conditions that exist in certain certain manholes.

In its response to RAI B.2.21-3, dated June 17, 200B, 2008, the applicant applicant stated Corrective stated that Corrective Report Report 04-03545 identified identified water in manhole 1EMH-19A EMH-1 9A Duct 944, and engineering engineering performed performed an inspection of the cable and tray after the water was removed. Corrective removed. Corrective Action 04-03545-1 requires requires that other manholes be inspected inspected for this condition. Manholes 1EMH-OBA&B EMH-08A&B were inspected and found to have water in them, inspected and found to have water in them, although although the depth of water was not provided.

3-45

Engineering performed Engineering performed a visual evaluation evaluation of the cable conditions determined that the conditions and determined the cables were acceptable.

acceptable. The cable submergence submergence issue previously addressed in issue had been previously Corrective Corrective Reports 02-02302 and 02-02348.

The applicant further stated that historical operating experienceexperience information information from 2001, 2001, included in the documentation documentation for Corrective Action 04-03545-104-03545-1, , was presented presented to the NRC Resident Resident Inspector on October Inspector October 26, 2001. historical information identified 2001. The historical identified certain manholes with with problems. These manholes, numbered chronic flooding problems. numbered 1EMH-8A, 8B, 8B, and 15, are located below grade structure and were repeatedly found to have water levels of 10 to grade near the intake structure 15 feet. The plant operating experience was used as input to the existing 15 existing BVPS manhole manhole inspection program. The applicant also stated that the program, inspection program, as described in LRA Section B.2.21, B.2.21, requires that the applicant take periodic actions, at least least once every two years, to prevent cables from being exposed to significantsignificant moisture. These include inspecting for water include water collection in cable manholes and conduit, and draining draining water, as needed.

needed. The applicant further stated this program program requirement requirement is consistent with GALL AMP XI.E3, Element Element 2 and states that the maximum period period allowed between inspections is two years. Also, LRA Section B.2.21, between inspections B.2.21, under the heading, "Detection of Aging Effects" stated:

This inspection inspection frequency frequency will be based on actual plant experience with water water accumulation accumulation in the manhole, with the first inspection inspection to be completed prior to the period of extended extended operation.

The applicant stated that plant-specific plant-specific and industry operating operating experience experience will be used to identify areas for program improvement, including adjustment of the manhole inspection inspection frequency.

inspection results and industry operating experience Therefore, plant inspection experience will be evaluated evaluated toto determine if if the manhole manhole inspection inspection frequency frequency needs to be adjusted to ensure the cables are are not exposed exposed to significant moisture.

moisture. The applicant further stated that as indicated indicated by the the corrective action to Corrective Report 04-03545, indication of water and cable submergence corrective submergence are visually evaluated evaluated by engineering Corrective Action Program, and further engineering using the BVPS Corrective actions are taken based on the evaluation.

During the regional onsite inspection performed during the week week of June 23, 2008, the staff staff found water in the manholes that contain safety-related safety-related cables. The staff staff determined determined that these these incidents demonstrate that the corrective actions actions described by the applicant have applicant have not been properly implemented, or were not adequate. In light of this operating operating experience, experience, the staff is concerned that inaccessible inaccessible medium-voltage medium-voltage cables that have have been submerged submerged for a period period of time may be degraded degraded and may not perform their intended intended function during the period of extended operation. The staff finds that the applicant applicant has not used the operating experience for operating experience program improvement improvement and enhancement, including including adjustment of the manhole manhole inspection inspection frequency frequency and/or using using automatic means, if frequent frequent inspection inspection fails to keep the cables dry.

In a letter dated September September 8, 2008, the applicant stated that LRA Section B.2.21 requires requires replacement replacement of the entire section, because because the program program is being being changed from a new new program that is consistent with the GALL Report, to a new plant-specific plant-specific program.

The staff noted that FENOC concluded inaccessible medium-voltage concluded that that all inaccessible medium-voltage cables within within the scope of the new plant-specific plant-specific program are suitable for operation in submerged water in a submerged water environment.

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The GALL Report Report does does not require inspection and testing of cables that are approved/qualified approved/qualified environment (i.e., submarine for submerged environment submarine cables). Therefore, the applicant applicant did not identify identify an AERM AERM for the BVPS cables. However, However, the staff notes that FENOC has has concluded concluded that periodic periodic inspection and testing of submerged medium-voltage cables was conservative submerged medium-voltage conservative to confirm that the aging effects are not occurring, and is revising the program program to be plant-specific.

plant-specific. Pending the the staff's review of review cable cable qualification submergence (i.e., submarine cables), this issue was for submergence was 01 3.0.3.1.11-1.

identified as open item 013.0.3.1.11-1.

identified During a conference conference call with the applicant on SeptemberSeptember 5, 2008, the staff requested requested that the the applicant provide cable procurement applicant procurement and manufacturer manufacturer test results to demonstrate demonstrate that the in-inaccessible medium-voltage scope inaccessible medium-voltage cables connecting connecting the power power block to the reactor reactor plant river water pumps and Unit 2 service service water pumps, and the emergency response facility feeder were designed for submerged submerged service. In In aa letter dated October 24, 2008, the applicant applicant provided two Specification for 5,000 V Power reports, "BVS-356, Specification Power Cable for Beaver Valley Power Station -

Unit 11,"," and "2BVS-309, Specification Specification for Insulated Insulated 5,000 V Power Power Cables Cables (Final (Final Version) for Beaver Valley Valley Power Station - Unit 2."

The staff reviewed the above BVPS documents documents and determined determined that an additional additional request for information (RAI) additional information (RAI) was needed needed to complete the review. In aa letter dated January 5, 2009, the staff issued an RAI requesting additional additional applicant and/or vendor evaluations to verify vendor evaluations that the above cables are designed for submerged submerged applications applications through the period period of extended operation at BVPS Units 1 and 2.

By letter dated dated March 24, 2009, the applicant amended amended LRA (Amendment No. No. 35) and stated that in order to close the staff's open item 3.0.3.1.11-1 3.0.3.1.11-1 of the BVPS Safety Evaluation Report; the applicant applicant would implement the following license license renewal commitments commitments prior to entering the the period extended operation:

period of extended (1) Adopt an acceptable acceptable methodology that demonstrates demonstrates that the in-scope, continuously continuously submerged, inaccessible, medium-voltage cables will continue inaccessible, medium-voltage continue to to performtheir perform their intended intended function during the period of extended operation, or; or; (2) Implement measures to minimize Implement measures minimize long-term submergence, submergence, or;or; (3) Replace Replace the in-scope, continuously continuously submerged submerged medium-voltage medium-voltage cables.

The applicant applicant further stated stated that the above action is intended intended to complement complement the AMP identified identified in BVPS LRA Amendment Amendment 23, Section Section B.2.21, Medium-Voltage Cables Suitable B.2.21, "Inaccessible Medium-Voltage Suitable Submergence and Not Subject to 10 CFR 50.49 Environmental for Submergence Environmental Qualification Qualification Requirements."

By letters dated May 14 14 and May 20, 2009, the applicantapplicant amended its LRA LRA (Amendment Nos.

36 and 37) by removing the "suitable for submergence" language language from the LRA and revising revising LRA Section associated sections Section B.2.21 and associated sections to be consistent with GALL AMP XI.E3. In In addition, the applicant clarified the commitment by stating that prior to the period of extended operation; itit will implement implement measures measures to minimize cable exposure exposure to significant These significant moisture. These measures measures include the dewatering dewatering of manholes and the use of dewateringdewatering operating operating experience experience to adjust the dewatering dewatering frequency frequency to minimize cable exposure exposure to significant significant moisture. Further, the applicant defined applicant defined significant moisture moisture consistent with GALL AMP XI.E3, which states, "Significant moisture is defined periodic exposures defined as periodic exposures to moisture that last moremore than a few days days 3-47

(e.g., cable cable in standing water). Periodic Periodic exposures to moisture moisture that last less than a few days days (i.e., normal rain and drain) are not significant." The applicant also revised Commitment (Le., Commitment 3 to to state that ifif in-scope, continuously continuously submerged inaccessible medium-voltage submerged inaccessible medium-voltage cables are replaced; replaced; these cables will be designed submerged environments.

designed for submerged environments.

The issue of whether inaccessible inaccessible medium-voltage medium-voltage cables installed at BVPS and within scope of license license renewal renewal are designed for continuous submergence and are in compliance continuous submergence compliance with the the current current licensing licensing basis is being evaluated by the staff in according with 10 CFR Part 50.

Resolving this issue under 10 10 CFR Part 50 is consistent consistent with 10 10 CFR 54.30, "Matters "Matters not subject to a renewal renewal," ," which states that, "If "If the reviews required by 10 CFR 54.21 (a) or (c) show that there is not reasonable assurance assurance during the current license term that licensed conducted in accordance activities will be conducted accordance with the CLB, then the licensee licensee shall take measures measures under its current current license, as appropriate, to ensure that the intendedintended function of those system, structures or components maintained in accordance components will be maintained accordance with the CLB throughout throughout the term of Requirements incorporated its current license." Requirements incorporated into the current CLB operating term as a result of the staff's Part 50 evaluation evaluation would be carried carried forward to the period of extended extended operation.

operation.

Based on the above, the staff determines determines that the implementation implementation of GALL AMP XI.E3 and the the above license commitments will address the issue of continuous license renewal commitments continuous submergence submergence of inaccessible medium inaccessible medium voltage cable at BVPS for the period of extended extended operation. With LRA Section B.2.21 revised to be consistent with GALL and the implementation implementation of the aboveabove commitments (Commitments 11 and 12 as described commitments described in Tables A.4-tA.4-1 and A.5-1 A.5-1 for Unit 1 and respectively), the applicant Unit 2, respectively), applicant will be able to demonstrate demonstrate that the in-scope, continuous continuous submerged, inaccessible inaccessible medium-voltage medium-voltage cables will perform their intended intended functions by (1) adopting an acceptable acceptable methodology demonstrates that the in-scope, continuously methodology that demonstrates medium-voltage cables will continue submerged, inaccessible, medium-voltage continue to perform their intended intended function function during the period period of extended extended operation, or (2) (2) implementing implementing measures measures to minimize minimize long term inaccessible medium inaccessible medium voltage voltage cable submergence, submergence, or (3) replacing in-scope continuous replacing in-scope continuous inaccessible medium voltage cable with cables designed for submerged service.

submerged inaccessible The staff finds that if the applicant implements implements Commitment Commitment 1 or 3, the aging effect and mechanism due to significant mechanism significant moisture will not be significant significant for medium medium voltage cables that are designed for these conditions. If the applicant implements Commitment applicant implements Commitment 2, it will minimize cable minimize cable exposure to significant moisture and thus minimize the potential potential for insulation degradation degradation consistent with GALL AMP XI.E3. ConsistencyConsistency with GALL AMP XI.E3 and the applicant's applicant's license renewal commitments license commitments will ensure that submerged inaccessible inaccessible medium-voltage medium-voltage cablescables will perform their intended functions consistent with the CLB during the period period of extended extended operation. The staff concerns with 01 3.0.3.1.11-1 3.0.3.1.11-1 are resolved.

UFSAR Supplement.

UFSAR Supplement. The staff reviewed reviewed this Section and determines determines that the information information in the the FSAR supplement provides provides an adequate description of the program program as required by 10 CFR 54.21(d). The staff also verified that applicant has committed (Commitment No. 11 in UFSAR Supplement UFSAR Supplement Table Table A.4-1 and Commitment Commitment No. 12 in UFSAR UFSAR Supplement Table A.5-1) A.5-1) to implement its new Inaccessible Inaccessible Medium-Voltage Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Environmental Qualification Requirements Program Program Conclusion. Based on its review, the staff finds that, the applicant's Inaccessible Inaccessible Medium-Medium-Voltage Voltage Cable Not Subject to Environmental Environmental Qualification Qualification Requirements acceptable acceptable because itit is consistent with the GALL Report Report program program elements elements and the plant is bounded by the the conditions set forth in the GALL Report Report for this AMP. The staff concludes concludes that, the applicant has has 3-48

demonstrated that the effects of aging will be adequately demonstrated managed so that the intended adequately managed maintained consistent function(s) will be maintained function(s) extended operation, as consistent with the CLB for the period of extended as required by 10 CFR 54.21 (a)(3). The staff also reviewed reviewed the UFSAR supplement this supplement for this concludes that it provides AMP and concludes provides an adequate adequate summary summary description of the program, as as required by 10 CFR 54.21(d).

54.21 (d).

Inspection of Internal 3.0.3.1.12 Inspection 3.0.3.1.12 Internal Surfaces Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Components Program Program Summary of Technical Summary Information in the Application.

Technical Information Application. In LRA Section B.2.22, the applicant stated that the Inspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Ducting Components Program is a new program that is consistent consistent with GALL AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Surfaces Miscellaneous Piping and Ducting Ducting Components."

The applicant stated that the programprogram will consist of inspections of the internal surfaces surfaces of piping, piping components, components, ducting and other components within the scope of license license renewal that are not covered covered by other other AMPs. These internal inspections are performed performed during thethe periodic system and component component surveillances surveillances or during the performance performance of maintenance maintenance activities when the surfaces are made accessible for visual inspection.

Evaluation. The staff reviewed those portions of the applicant's Staff Evaluation. applicant's Inspection Inspection of Internal Surfaces in Miscellaneous Surfaces Miscellaneous Piping and Ducting Components Components Program Program that the applicant claimed claimed consistency with GALL AMP XI.M38 XI.M38 and found they are consistent with this GALL AMP. The The staff also confirmed confirmed that the plant program contains all of the elements elements of the referenced referenced GALL program and the conditions at the plant are bounded by the conditions for which the GALL Report is evaluated.

evaluated. The staff held onsite interviews applicant's technical personnel to interviews with the applicant's confirm these results.

The staff reviewed reviewed the applicant's license license renewal basis document document for the Internal Surfaces in in Miscellaneous Piping and Ducting Components Miscellaneous Components Program and confirmed confirmed that the program program scope scope includes all those systems for which which the applicant applicant credited this program program in its AMR results. The The staff finds the applicant's Inspection applicant's Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program acceptable acceptable because itit conforms conforms to the recommended recommended GALL AMP XI.M38.

In comparing comparing the elements elements in the applicant's applicant's AMP with GALL AMP XI.M38, the staff found that the "acceptance criteria" element element states that the program will inspect for indications of material degradation (i.e., corrosion, cracking, fouling, etc.). However, the applicant did not define degradation define the the acceptance criteria.

acceptance criteria.

In RAI B.2.22-1, B.2.22-1, dated May 22, 2008, the staff requested requested that the applicant applicant define the define the acceptance criteria.

acceptance criteria.

In its response to RAI B.2.22-1, dated July 24, RAI B.2.22-1, 2008, the applicant revised LRA Section 24,2008, Section B.2.22, Acceptance Criteria, and provided acceptance criteria. The applicant stated that provided details of the acceptance for painted or coated surfaces, any evidence evidence of damaged damaged or degraded degraded coating is an indicator indicator of possible corrosion corrosion damage to the surface surface underneath.

underneath. Therefore, evidence evidence of damaged or unacceptable and will be evaluated degraded coatings is unacceptable Corrective Action evaluated through the FENOC Corrective Action Program. The applicant applicant further further stated that any indication of cracking or fouling (i.e., built up dirt, 3-49

dust, or debris) is unacceptable evaluated using the Corrective Action Program.

unacceptable and will be evaluated Program. For corrosion is unacceptable.

materials susceptible to corrosion, significant corrosion includes heavy unacceptable. This includes corrosion, localized corrosion, corrosion, blistered material due to blistered material, pitted material, or visible loss of material corrosion. The applicant also stated that a thin, light, and even layer of oxidation can provide provide against protection against further corrosion. It is expected It expected in some systems, and is acceptable.

acceptable.

Based on its review, the staff finds the applicant's response to RAI B.2.22-1 acceptable because acceptable because acceptance criteria and has revised LRA adequately defined the acceptance that applicant has adequately Section B.2.22 accordingly. Therefore, the staffs concern described described in RAIRAI B.2.22-1 is resolved.

resolved.

3.3.2-11 and 3.3.2-12, the applicant 3.3.2-1, 3.3.2-2, 3.3.2-11 In LRA Tables 3.3.2-1, Inspection of applicant credited the Inspection Internal Surfaces Components Program Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Program to manage the the aging effects cracking and reduction of heat transfer of stainless steel, aluminum, and copper effects of cracking exchangers. In LRA Section separators and heat exchangers.

alloy <15% Zn moisture separators Section B.2.22, the applicant applicant consistent with GALL AMP XI.M38.

stated that this program is consistent stated However, the staff noted that XLM38. However, that GALL AMP XI.M38 GALL managing the aging effect of loss of material due to corrosion XLM38 is credited for managing steel components only.

for steel September 3, 2008, the staff requested that the applicant justify how the In RAI 3.3-A, dated September the manage the aging program will manage aging effect reduction of heat transfer, or provide effect of (a) reduction provide a plant-specific plant-specific provide a plant-specific moisture separator, or provide program and (b) cracking of moisture plant-specific program.

program.

In its response to RAI 3.3-A, Part (a); dated October 3, 2008; the applicant responded (a)i dated responded that the the Inspection of Internal Surfaces Inspection Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Program Components Program performing visual inspection for reduction of heat transfer by performing manages the aging effect of reduction accumulation of dirt and debris on heat transfer surfaces. The applicant accumulation applicant also stated that fouling included in the GALL AMP XI.M38 is specifically included XLM38 in "monitoring and trending" and "acceptance criteria" elements.

The staff reviewed the GALL AMP XI.M38 elements elements and noted noted the "monitoring and trending" indications of corrosion inspections are monitored for indications element states that results of the periodic inspections indications of fouling that would

"'acceptance criteria" element states that indications and fouling; and the ;'acceptance would impact component intended component intended function are reported and will require further evaluation. On the the Inspection of Internal Surfaces basis that the Inspection Miscellaneous Piping and Ducting Components Surfaces in Miscellaneous Components accumulation of dirt and debris, and that this program is requires visual inspection for accumulation Program requires consistent with the GALL AMP XI.M38, the staff finds the applicant acceptable. The applicant response acceptable. The staff concludes that the Inspection Surfaces in Miscellaneous Inspection of Internal Surfaces Miscellaneous Piping and Ducting manage the aging effects of reduction of heat transfer of adequately manage Components Program will adequately the copper exchanger exposed copper alloy <15% Zn heat exchanger condensation external exposed to condensation environment external environment during the period of extended operation.

In its response to RAI 3.3-A, Part (b), applicant stated that the October 3, 2008; the applicant (b), dated October the separators potentially susceptible moisture separators associated with Unit 1 emergency susceptible to cracking are associated diesel generator air start system. The applicant further stated that the determination determination that aging effect for aluminum alloys relevant aging cracking is a relevant presence of zinc dependent upon the presence alloys is dependent zinc magnesium above the threshold levels in the aluminum or magnesium aluminum alloy. However, levels of zinc and magnesium above these thresholds (greater than 12%

magnesium and/or 6% magnesium) 12% zinc and/or magnesium) are not common in aluminum alloys, so the aging effect is not expected expected to occur. The applicant has has amended the LRA to credit the One-Time Inspection Program to confirm the absence of Inspection Program 3-50 3-50

cracking in these moisture separators, instead Inspection of Internal Surfaces instead of the Inspection Surfaces inin Miscellaneous Piping and Ducting Components Program that it had proposed Miscellaneous proposed in the LRA.

On the basis that cracking cracking is not likely likely to occur in aluminum alloys and the applicant is crediting crediting Inspection Program to ensure the One-Time Inspection ensure either either aging is not occurring, occurring, or aging is so insignificant insignificant that an aging management management program is not warranted, the staff finds the applicant applicant response response acceptable. The staff reviewed the One-Time One-Time Inspection Inspection Program and documented documented its evaluation in SER Section 3.0.3.1.17.

Operatingi Experience. The staff reviewed the operating Operating Experience. operating experience experience provided provided in the LRA and interviewed the applicant's interviewed applicant's technical personnel to confirm that the plant-specific plant-specific operating experience did not reveal any aging effects not bounded experience bounded by the GALLGALL Report. The staff also confirmed that the applicant has has reviewed reviewed applicable applicable aging effects effects and industry and experience and are evaluated plant-specific operating experience evaluated in the GALL Report. Furthermore, Furthermore, the the staff confirmed confirmed that the applicant has has addressed experience identified after the addressed operating experience the issuance of the GALL Report.

issuance Although the applicant stated that this is a new program, inspectioninspection of internal surfaces during internal surfaces during the performance surveillances and maintenance performance of periodic surveillances maintenance activities activities has been in effect at BVPS BVPS in support of plant component reliability programs. The staff reviewed a sample of corrective corrective reports and confirmed that the applicant degraded conditions in the internal applicant has identified degraded surfaces surfaces during during the performance performance periodic surveillances and has implementedimplemented appropriate appropriate corrective actions.

The staff finds that the applicant's applicant's Inspection Inspection of Internal Internal Surfaces in Miscellaneous Miscellaneous Piping and and Ducting Components Program, with the corrective corrective actions discussed discussed in the LRA, will be effective effective in identifying, monitoring, and correcting the aging effects and can be expected expected to ensure ensure that the systems systems and components within the scope of this program will continue continue to perform their their intended functions consistent with the CLB for the period of extended intended extended operation.

operation.

UFSAR Supplement. In LRA Section Section A A1.22, 1.22, the applicant applicant provided provided the UFSAR supplement for UFSAR supplement the Inspection Inspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program.

The staff verified that the UFSAR Supplement Supplement summary description for the Inspection summary description Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program Program conforms conforms to the staff's staff's recommended UFSAR Supplement recommended Supplement guidance guidance provided in SRP-LR Table 3.3-2. The staff also verified that, in LRA Commitment Commitment No. 12 of UFSAR Supplement Table Table A.4-1 and Commitment Commitment No. 13 in UFSAR UFSAR Supplement Table A.5.1, A.5.1, the applicant has committed committed to implementing its new implementing Inspection Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Program.

Components Based on its review, the staff finds that UFSAR Supplement Section UFSAR Supplement Section A.1.22 provides provides an acceptable acceptable UFSAR Supplement summary UFSAR Supplement summary description of the applicant's applicant's Inspection Inspection of Internal Surfaces Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program because because itit is consistent with the UFSAR supplement supplement summary description description of the program, as required by 10 10 CFR CFR 54.21(d).

Conclusion.

Conclusion. Based on its review, the staff finds the applicant's applicant's Inspection of Internal Surfaces in Miscellaneous Miscellaneous Piping and Ducting Components Components Program Program acceptable because it is consistent acceptable because consistent with the GALL Report Report and the plant is bounded by the conditions set forth in the GALL GALL Report for this AMP. Based on its review, the staff staff finds that the applicant's applicant's Internal Surfaces Surfaces in in 3-51

Miscellaneous Piping and Ducting Components Miscellaneous Components Program Program will adequately manage the aging adequately manage effects effects so that the intended intended functions will be maintained maintained consistent consistent with the CLB for the period of extended extended operation, as required by 10 54.21(a)(3).

10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR UFSAR supplement supplement for this AMP and finds that itit provides adequate summary provides an adequate description of the summary description the

program, program, as required by 10 CFR 54.21(d).

3.0.3.1.13 Lubricating Oil Analysis Program Program Summary of Technical Information in the Application. In LRA Section B.2.24, the applicant described the existing existing Lubricating Lubricating Oil Analysis Program as consistent with GALL GALL AMP XI.M39, XLM39, "Lubricating "Lubricating Oil Analysis."

Analysis." The Lubricating Lubricating Oil Analysis Program maintains the lubricating oil environment environment to the required quality for mechanical mechanical systems within the scope of license license renewal.

The program monitors and controls abnormal levels of contaminants contaminants (i.e., primarily water and particulates) for lubricating oil system components within the scope scope of license renewal to to preserve an environment not conducive to loss of material, cracking, or reduction of heat preserve transfer. The One-Time Inspection Inspection Program will verify the effectiveness effectiveness of the Lubricating Lubricating Oil Analysis Program.

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

XLM39.

The staff reviewed reviewed those portions of the applicant's Lubricating Oil Analysis Program that the applicant's Lubricating the applicant applicant claimed consistency consistency with GALL AMP XLM39 XI.M39 and found they are consistent consistent with thisthis GALL AMP. The staff also confirmed that the plant program program contains all of the elements of the the referenced GALL program program and the conditions conditions at the plant are bounded bounded by the conditions for for which the GALL ReportReport is evaluated. The staff reviewed the applicant's applicant's Program Evaluation Evaluation Document and confirmed that the program program scope includes all in-scope mechanical mechanical components components exposed exposed to a lubricating lubricating oil environment. The staff held onsite interviews interviews with the applicant's applicant's technical personnel personnel to confirm confirm these results. The staff finds the applicant's Lubricating Oil applicant's Lubricating Analysis Program, as confirmed confirmed by the One-Time Inspection Program acceptable One-Time Inspection because it acceptable because conforms conforms to the recommended recommended GALL AMP XLM39. XI.M39.

Operatingq Operating Experience. In LRA AMP B.2.24, the applicant applicant provided the following operating operating experience evaluation for BVPS:

experience evaluation The Lubricating Lubricating Oil AnalYSis Analysis Program Program is an existing program that maintains oil systems systems free of contaminants contaminants (primarily water and particulates) particulates) thereby environment that is not conducive to loss of material, preserving an environment material, cracking, or Program activities include sampling and analysis of lubricating fouling. Program lubricating oil for for contaminants, water, particulates, particulates, and bearing wear bearing wear materials.

Analysis of samples taken in 2006 2006 from lube oil subsystems subsystems for several in-scope several in-scope pumps and motors showed that the oil in these components was within normal tolerances and was satisfactory satisfactory for continued continued use. However, the presence presence of elevated amounts of water, wear elevated wear particles, and contaminants in routine samplingsampling led to documenting documenting the issues in the Corrective Action Program. Use of warning warning level indicators to direct corrective direct corrective actions prior to equipment degradation degradation provides provides evidence evidence that the program is effective effective in managing managing aging effects caused by oil impurities.

impurities.

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The BVPS practice practice of regular regular lube lube oil system analysis analysis is consistent consistent with industry experience in which operating experience which significant and potentially disabling failures could potentially disabling have been prevented by following this same policy. A specific example example is Information Notice, 2001-06 in which aa 40-fold increase described in NRC Information increase inin particle particle count for the lube lube oil in a. a high-head high-head SI pump thrust bearing bearing was not recognized recognized as a potential indicator indicator of bearing damage.

Other practices such as assessing the storage and distribution of Other good practices lubricating oil from the site warehouse lubricating warehouse helps helps to ensure that high quality contaminant-free oil is added to the lubricating systems for in-scope pumps and contaminant-free motors.

The BVPS Lubricating Lubricating Oil Analysis Program incorporates operating experience incorporates operating experience from the sampling sampling and testing of lubricating lubricating oil for the various in-scope pump and bearing packages. Operating experience motor bearing experience has shown that a precursor precursor event to bearing failures is elevated lubricating lubricating oil particulate concentration. The The program is designed to detect this elevated particulate concentration elevated particulate concentration which which preemptive actions allows preemptive actions such as oil replacement to be performed performed prior to loss loss of intended intended function. Current operating operating experience experience (Corrective (Corrective Action Program documents, Information documents, Information Notices, etc.) validates the effectiveness etc.) validates effectiveness of the BVPSBVPS Lubricating Oil Analysis Program. The BVPS Lubricating Lubricating Lubricating Oil Analysis Program Program has been effective effective at managing managing aging aging effects effects by periodically periodically sampling sampling and analyzing lubricating lubricating oil from these in-scope components.

The staff reviewed the operating experience experience provided in the LRA LRA and interviewed the applicant's applicant's personnel to confirm that the plant-specific operating technical personnel operating experience experience did not reveal any aging effects effects not bounded bounded by the GALL Report. The staff also confirmed confirmed that applicable aging effects and industry and plant-specific plant-specific operating operating experience have been evaluated and incorporated incorporated into the BVPS Lubricating Oil Analysis Analysis Program.

Program.

During the audit audit and review, the staff noted that the applicant's applicant's program is implemented implemented through through site-specific site-specific procedures procedures and that the procedures appropriate American procedures incorporate appropriate American Society Society for Testing of Materials Materials (ASTM) standards standards for the collection collection and testing of lubricating lubricating oil samples samples (i.e., ASTM D 6595 for determining presence presence of wear materials materials and contaminants, contaminants, and ASTM D 6304 for determining presence determining presence of water in lubricating oil), and other appropriate appropriate industry standards. The staff also confirmed that the plant-specific procedures contain plant-specific procedures acceptance contain the acceptance criteria in accordance accordance with the industry industry standards upon which procedures are based. The which the procedures The staff noted that when lubricating oil parameters parameters are found outside tolerances defined outside of tolerances defined in thethe plant-specific plant-specific procedures, the procedure procedure directs that the condition condition is documented documented in the the condition condition reporting process to determine causes and to effect appropriate corrective effect appropriate corrective actions, including including actions to revise the acceptance acceptance criteria or the sampling and testing frequencies, if required.

required.

The staff noted that the applicant's applicant's program also incorporates incorporates industry industry operating experience experience such as that provided in NRC Information Information Notices (INs) and that the industry operating operating experience is evaluated experience determine adverse trends that could impact the ability of the evaluated to determine the lubricating lubricating oil analyses to conservatively conservatively predict equipment failures. The staff noted noted that thethe applicant's program applicant's program also is subject subject to periodic self assessments assessments and QA reviews reviews and that the the 3-53

applicant uses these quality reviews to insure insure that the program incorporates incorporates industry and plant-specific plant-specific operating operating experience experience and to adjust the program program elements elements of the AMP accordingly, if the need need arises.

Based Based on its review, the staff finds that the applicant's applicant's Lubricating Lubricating Oil Analysis Program Program hashas been effective in monitoring, controlling, been effective controlling, and correcting correcting the aging aging effects effects of components components within within the scope of this program because because (a) the applicant is implementing implementing its program in accordance accordance with appropriate appropriate ASTM standards monitoring of lubricating oil quality, (b) standards for monitoring (b) the applicant appropriately appropriately takes prompt corrective corrective actions when the lube oil property property and quality are out of specification specification with the ASTM standards, and (c) the program includes includes periodic self assessments assessments and QA controls that are used to adjust and improve the programs based on past performance.

UFSAR Supplement. In LRA Section A.1.24, the applicant applicant provided the UFSAR supplement for UFSAR supplement for the Lubricating Oil Analysis Program. The staff reviewed this Section and determines determines that thethe information in the UFSAR SupplementSupplement provided an adequate description of the adequate summary description the program, as required by 10 10 CFR 54.21(d),

54.21 (d), and is consistent with the guidance guidance for the lubricating lubricating oil analysis program found in SRP-LR SRP-LR Table 3.1-2.

Conclusion. Based on its review, the staff finds the applicant's Lubricating Oil Analysis Program applicant's Lubricating Program because itit is consistent acceptable because acceptable consistent with the GALL GALL Report and the plant is bounded by the the conditions set forth in the GALL conditions GALL Report for this AMP. Based on its review, the staff finds that the the applicant's program applicant's program will adequately manage the aging effects so that the intended adequately manage intended functions will be maintained maintained consistent consistent with the CLB for the period of extendedextended operation, operation, as required by by 10 10 CFR 54.21 (a)(3).

54.21(a)(3). The staff also reviewed the UFSAR supplement supplement for this AMP and finds that itit provides an adequate adequate summary summary description of the program, as required by 10 10 CFR 54.21 54.21(d).

(d).

3.0.3.1.14 MetalMetal Enclosed Enclosed Bus Program (Unit 2)

Summary of Technical Information in the Application. In LRA, Section Technical Information Section B.2.26, the applicant stated that the Metal Metal Enclosed Enclosed Bus Program Program is a newnew program that is consistent consistent with GALL AMP XI,E4, XI.E4, "Metal Enclosed Enclosed Bus."

The applicant stated that in-scopein-scope metal enclosed bus internal surfacessurfaces will be visually inspected for aging degradation inspected degradation of insulating insulating and conductive conductive components. This visual inspection inspection will also identify evidence of foreign debris, excessive excessive dust buildup, or moisture moisture intrusion. The The applicant further states that the bus insulating insulating system, including the internal supports, will be be visually inspected for structural structural integrity and signs of aging aging degradation. A sample sample of accessible accessible bolted connections connections will be checked for loose connection connection using thermography. The applicant will complete inspections inspections prior to the period of extended operation operation and every 10 years thereafter.

Staff Evaluation. The staff reviewed the LRA and the applicant's applicant's onsite bases documents documents related to the Metal Enclosed Bus Program in which the applicant claimed consistency consistency with GALL AMP X1.E4.

The staff reviewed the applicant's enclosed bus documents applicant's metal enclosed documents and confirmed confirmed them to be be consistent consistent with GALL GALL AMP XI.E4.X1.E4. The staff also confirmed confirmed that the plant program contains all of the elements referenced GALL elements of the referenced GALL program and that the conditions at the plant are bounded by the conditions for which the GALL report is evaluated. The staff held onsite interviews with the applicant's applicant's technical personnel personnel to confirm these results.

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In LRA Section B.2.26, the applicant stated that the metal enclosed bus is only applicable applicable to the the 480 Vac metal metal enclosed enclosed bus feeders to emergency sUbstationssubstations (2-8 and 2-9) for Unit 2. It also stated that there is no in-scope in-scope metal enclosed enclosed bus at Unit 1. The applicant UFSAR applicant stated that UFSAR Section 8.4 for Units 1 and 2 complies complies with 10 10 CFR Part 50, Appendix A, Genera Genera Oesign Design Criteria (GOC) 17. GDC (GDC) 17. GOC 17 requires that two physical independent 17 requires independent circuits circuits be designed designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure failure under operating operating and postulated postulated accident accident conditions.

conditions. Each Each of these circuits shall be deSigned designed to be available available in sufficient time, following a loss of all onsite ac power supplies and the other other offsite electric power circuit to assure assure that specified acceptable fuel design limits and design specified acceptable design conditions of the RCPB are not exceeded.

exceeded. One of these circuits shall be designed designed to bebe available available within a few seconds following aa loss-of-coolant loss-of-coolant accident accident to assure that core cooling, containment integrity, and other vital safety functions maintained. These offsite circuits are functions are maintained.

relied on in analyses analyses or plant evaluations evaluations to perform a function that demonstrates demonstrates compliance compliance with the station blackout blackout (SBO) rule, 10 CFR 50.63, and should be included included within the scope of license renewal in accordance accordance with 10 CFR 54.4(a)(3).

In RAI B.2.26-1, B.2.26-1, dated May May 15, 2008, that staff requested that the applicant (a) describe the two two independent offsite circuits and their associated metal enclosed independent enclosed buses (i.e., iso-phase and non-segregated) and (b) non-segregated) (b) explain why other metal enclosed buses buses (e.g., iso-phase iso-phase metal enclosed buses) are not included within the scope of the Metal Enclosed Bus Program.

In its response response to RAI B.2.26-1, B.2.26-1, dated dated June June 17, 2008, the applicant stated that LRA Figure Figure 2.5-1 shows that Unit 1 receives offsite power from the 138kV switchyard. The 138kV bus #1 #1 (switchyard breaker 92) is connected to the high-voltage high-voltage side of the 138kV/4.16kV 138kV/4.16kV system station service transformer transformer (TA-1A) via overhead overhead and transmission transmission conductor. The low voltage voltage side of the 138kV/4.16kv 138kV/4.16kv system station service transformer (TR-1A) transformer (TR-1 connected to 4.16kV A) is connected nonsafety-related bus (1A) nonsafety-related (1A) via insulated cables. The nonsafety-related nonsafety-related bus (1A) (1A) supplies the the safety bus (1AE)

(1AE) via insulated cables. The applicant applicant further stated that LRA Figure 2.5-1 also shows that the 138kV Bus #2 (switchyard circuit breaker 83) is connected

1. 2 (switchyard connected to the high-voltage high-voltage side of the 138kV/4.16kV 138kV/4.16kV system station service transformer transformer (TR-1B). This connection is made connection made via the switchyard switchyard bus and overhead overhead transmission transmission conductor. The low voltage side of the the 138kV/4.16 138kV/4.16 kV system station service transformer transformer (TR-1 B) is connected connected to 4.16 kV kV nonsafety-related bus (1 nonsafety-related D) via insulated (10) insulated cables, which supplies the safety bus (1 (1DF)

OF) via via insulated cables.

applicant also stated The applicant stated that LRA Figure 2.5-2 shows shows that Unit 2 receives receives offsite power from from the 138kV 138kV switchyard.

switchyard. The 138kV bus #2

1. 2 (switchyard breaker 85) is connected connected to the high-voltage side of the 138kV/4.16kV 138kV/4.16kV system station service transformer (TA-2A) via overhead overhead transmission conductors. The low voltage side of the 138kV/4.16kv138kV/4.16kv system station service service (TR-2A) is connected to the 4.16kV nonsafety-related transformer (TR-2A) nonsafety-related bus (2A) (2A) via insulated insulated cables.

The nonsafety-related nonsafety-related bus (2A) supplies the safety-related safety-related bus (2AE) via insulated cables. In addition, the applicant applicant stated stated that LRA Figure 2.5-2 also shows that the 138kV 138kV Bus #1 (switchyard circuit breaker 94) is connected to the high-voltage high-voltage side of the 138kV/4.16 138kV/4.16 kV kV system station service transformer transformer (TR-2B) via overhead overhead transmission transmission conductors. The low low voltage side of the 138kV/4.16kV 138kV/4.16kV system station service transformer (TR-2B) is connected to the 4.16 kV nonsafety-related nonsafety-related bus (2D) insulated cables, which (20) via insulated which supplies supplies the safety-related safety-related bus (1(1 DF)

OF) via insulated insulated cables. The applicant further stated stated that in response response to part (a) of this this RAI and as shown in LRA Figures 2.5-1 and 2.5-2, the 'commodity RAJ commodity group group metal metal enclosed bus is 3-55

not used used in the offsite power power paths for Units 1 and 2. Therefore, Therefore, no metal enclosed enclosed bus for the the offsite power path is included included within the scope of license renewal. Lastly, the applicant stated that the only metal enclosed enclosed bus within the scope of license license renewal renewal is the Unit 2 Section of the the 480V bus which is addressed which addressed in LRA Section B.2.26.

Based on its review, the staff finds the applicant's applicant's response to RAI B.26-1 acceptable because acceptable because the applicant has adequately adequately described described the two independent independent offsite circuits pursuant to circuits pursuant 10 CFR Part 50, Appendix A, GDC 17 and their associated associated components components for both Units 1 and 2.

The staff also finds that the applicant has adequately explained explained why other metal enclosed buses buses (other than the Unit 2 Section Section of 480V bus) are not within the scope of its Metal Enclosed Bus Bus Program. Therefore, Therefore, the staff's concern concern described described in RAI B.2.26-1 is resolved.resolved.

Operatincq Operating Experience. reviewed the operating Experience. The staff reviewed experience reports, including a sample operating experience sample of condition reports, and interviewed interviewed the applicant's applicant's technical staff to confirm that the the plant-specific operating experience plant-specific experience did not reveal any degradation degradation not bounded by industry experience.

experience. The applicant states in LRA Section Section B.2.26 that the Metal Enclosed Enclosed Bus Program is aa new AMP for which there is no plant-specific plant-specific operating experience experience for program effectiveness.

program effectiveness.

The applicant also stated that industry and plant-specific plant-specific operating experience operating experience will be evaluated in the development development and implementation implementation of this program.

program. The applicant further further stated that as as additional operating experience is obtained, lessons operating experience lessons learned will be appropriately incorporated appropriately incorporated in the program. GALL GALL AMP XI.E4, under under Operating Operating Experience, Experience, states that industry operating operating experience experience has shown that failures have have occurred occurred on metal enclosed buses by cracked insulation insulation and moisture or debris buildup internal to metal enclosed Experience also has enclosed buses. Experience has shown that bus connections in metal metal enclosed enclosed buses exposedexposed to appreciable appreciable ohmic heating, during operation, may experience experience loosening loosening due to repeated repeated cycling of connected loads.

In RAI B.2-1, B.2-1, dated dated May 22, 2008, the staff requested that the applicant address address plant-specific plant-specific operating operating experience.

experience.

In its response to RAI B.2-1, B.2-1, dated dated August 22, 2008, the applicant stated 22,2008, stated that during a 2003 4kV bus inspection on a Unit 1 metal enclosed bus of similar design and material material but not in-scope in-scope of for license renewal, the applicant applicant found that several insulator several insulator bolts were loose loose and one missing missing in a bus cubicle. The applicant entered this degradeddegraded condition into the FENOC Corrective Corrective Action Program. The applicant re-torqued the loosened bolts to the vendor recommended recommended value value and through an engineering engineering evaluation, addressed the missing bolt. As aa result of this evaluation, addressed this inspection, the applicant performed performed an unplanned unplanned inspection inspection of an additional cubicle and found no problems.

no problems.

Based on its review, the staff finds that applicant applicant response to RAI B.2-1 acceptable because the the applicant adequately applicant adequately discussed the operating experience associated experience associated with components components of the the Metal Enclosed Bus program, includingincluding past corrective actions that resulted in program program enhancements.

enhancements. The staff finds that this information information should provide objective evidence evidence to support the conclusion that the effects of aging will be managed adequately adequately so that structure structure and component intended function(s) will be maintained component intended maintained during the period of extended extended operation. The The staff notes that the applicant also has committed committed to evaluate industry and plant-specific plant-specific operating experience operating experience in the development implementation of this program.

development and implementation program. As the applicant applicant obtains additional operating experience, it will appropriately appropriately incorporate incorporate lessons learnedlearned in thethe program.

program. Therefore, the staff's concern described described in RAI B.2-1 is resolved.

resolved.

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The staff confirms that the "operating experience" program element satisfies the the recommendation in the GALL report and the guidance in SRP-LR Section recommendation Section A.1.2.3.10.

A.1.2.3.1 O. The staff staff program element acceptable.

finds this program acceptable.

UFSAR Supplement. The staff reviewed this Section and determines determines that the information in the the UFSAR supplement supplement provides provides an adequate description of the program adequate description program as required by by 10 CFR 54.21(d). The staff also verified that applicant has committed 10 committed (Commitment (Commitment No. 16 16 in UFSAR Supplement A.5-1) to implement Supplement Table A.5-1) implement its new Metal Enclosed Bus Program.

Conclusion. Based on its review, the staff finds that the applicant's Metal Metal Enclosed Bus Program acceptable because it is consistent with the GALL report and the plant is bounded acceptable bounded by the the conditions set forth in the GALL Report for this AMP. The staff concludes concludes that the applicant applicant hashas demonstrated demonstrated that the effects effects of aging managed so that the intended aging will be adequately managed function(s) will be maintained consistent with the CLB for the period of extended extended operation, operation, as as required required by 10 10 CFR 54.21(a)(3).

54.21 (a)(3). The staff also reviewed reviewed the UFSAR UFSAR supplement for this this AMP and concludes that it provides an adequate adequate summary description description of the program, as as required by 10 required 10 CFR 54.21(d) 54.21(d) 3.0.3.1.15 3.0.3.1.15 Metal Fatigue of Reactor Metal Fatigue Reactor Coolant Pressure Boundary Boundary Program Technical Information Summary of Technical Information in the Application. In LRA LRA Section B.2.27, the applicant applicant described described the existing Metal Fatigue of Reactor Coolant Boundary Program as Coolant Pressure Boundary as consistent with GALL GALL AMP X.M1, X.M1, "Metal Fatigue of Reactor Reactor Coolant Pressure Pressure Boundary."

The applicant stated stated that the Metal Fatigue of Reactor Reactor Coolant Pressure Pressure Boundary Program is a TLAA that uses preventive measures to mitigate fatigue cracking caused by anticipated cyclic cyclic strains in metal components of the RCPB. The preventive measures monitor and track critical thermal and pressure transients for RCS components to prevent prevent them from exceeding fatiguefatigue design limits. Critical transients are the subset of the design transients transients likely to approach approach or or exceed the number number of design cycles cycles during the Sixty-year sixty-year operating operating life of the units. These These critical transients include include plant heatup, plant cooldown, reactor trip from full power power (Unit 1),

inadvertent auxiliary spray, safety inadvertent safety injection injection activation (Unit 1), and RCS cold over-pressurization. The program pressurization. The program also monitors supplemental supplemental transients transients like the pressurizer pressurizer insurge insurge transient, selected chemical and and volume control system (CVCS)

(CVCS) transients, auxiliary feedwater auxiliary feedwater (AFW) injections, and RHR actuation (Unit 2). Before these transients exceed exceed the fatigue design design limit, the program program triggers preventive or corrective actions or both.

In addition, the applicant also stated stated that the program evaluates evaluates environmental environmental effects in effects in accordance accordance with the guidance in NUREG/CR-6260, NUREG/CR-6260, "Application of NUREG/CR-5999 NUREG/CR-5999 Interim Interim Fatigue Curves for Selected NuclearNuclear Power Plant Components," and EPRI Technical Technical Report (MRP)-47, "Guidelines for Addressing Fatigue Environmental Materials Reliability Program (MRP)-47, Environmental Effects in aa License Renewal Application." The program evaluates evaluates selected components using selected components material-specific guidance material-specific guidance found in NUREG/CR-6583, NUREG/CR-6583, "Effects of LWR Coolant Environments Environments Design Curves of Carbon and Low Alloy Steels," and in NUREG/CR-5704,"Effects on Fatigue DeSign NUREG/CR-5704,"Effects of LWR Coolant Environments on Fatigue Design Curves of Austenitic Stainless Coolant Environments Stainless Steels."

Staff Evaluation. During its audit and review, the staff reviewed the applicant's applicant's claim of consistency conSistency with the GALL Report.

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Specifically, the staff reviewed reviewed the "scope of program" "preventative/mitigative actions,"

program""preventative/mitigative parameters monitored/inspected,"

"parameters monitored/inspected," "detection of aging effects," "monitoring and trending,"

"acceptance criteria" and "operating experience" program elements elements of the applicant's applicant's Fatigue of Reactor Reactor Coolant Pressure Boundary Program Pressure Boundary Program against the staff's recommended recommended criteria for these programs that are provided in the corresponding program program elements of GALL AMP X.M1. X.M1. The The staff performed performed its review of the "corrective actions," "confirmatory actions," and "administrative "administrative controls" program program elements as part of the staff's review of the applicant's Quality Assurance Assurance Program.

The staffs staff's evaluation evaluation of the Quality Assurance Assurance Program is provided in SER Section Section 3.0.4.

The staff reviewed reviewed the technical information information in LRA LRA Section B.2.27 and the applicant's applicant's onsite onsite documentation documentation supporting the applicant's applicant's conclusion conclusion that the program program elements elements are consistent consistent with the elements elements in the GALL Report. The staff also interviewed the applicant's technical staff staff to verify the description description of the LRA and its supplementing supplementing documents.

The staff determined determined that the applicant's MetalMetal Fatigue Fatigue of Reactor Reactor Coolant Pressure Pressure Boundary Program is based, in part, on a cycle counting process that is performed performed for the design basis basis transients transients that have been defined for the Units 1 and 2 facilities in LRA Table 4.3-2. The staff staff noted that the cycle counting counting is required required for these transients in accordance accordance with the applicant's applicant's Technical Specification (TS) 5.5.3, which reads as follows:

Technical Specification 5.5.3 Component Cyclic or Transient Limit Limit This program provides provides controls to track the UFSAR UFSAR Table 4.1-10 (Unit 1) and UFSAR UFSAR Table 3.9N-1 3.9N-1 (Unit (Unit 2), cyclic and transient occurrences occurrences to ensure that components are maintained components maintained within the design limits.

The staff noted that this TS requirement provided the applicant's applicant's basis for the cycle counting counting that is part of the "monitoring and trending" program element aspect of the applicant's applicant's program.

program.

However, in comparing other aspects of the applicant's program program elements to the -program element element criteria in GALL AMP X.M1, X.M1, the staff found that LRA Section B.2.27 did not provide provide sufficient sufficient detail for the staff to determine determine whether whether the "Metal Fatigue of Reactor Coolant Coolant Pressure Boundary Boundary Program" is adequate for the period of extended operation. operation. The staff staff therefore therefore issued to the applicant applicant a number of RAlsRAIs on the Metal Fatigue of ReactorReactor Coolant Boundary Program.

Pressure Boundary Program.

The staff noted that the applicant applicant defines the term "critical transients" and provides provides the lists of the transients for each unit in the LRA Table Table 4.3-2. The staff issued an RAI for its clarification and review.

In RAI B.2.27 In B.2.27-1,

-1, dated May 28, 2008, the staff requested requested that the applicant provide a list of the applicant provide the critical critical design basis transients that could impact the cumulative cumulative usage factor (CUF) assessments assessments for the applicant applicant and to justify its basis for selecting these transients as the critical ones for the CUF calculation.

calculation.

In its response to RAI B.2.27-1, B.2.27-1, dated July 11,2007, 11, 2007, the applicant identified identified the critical transients, which include include plant heat heat up and cool down, down, reactor trip from full power (Unit 1 only),

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inadvertent auxiliary inadvertent auxiliary spray, safety injection injection activation (Unit 1 only) only) and RCS RCS cold over pressurization, that that will bebe monitored by Metal Fatigue of Reactor Reactor Coolant Pressure Pressure Boundary applicant further identified supplemental transients, Program. The applicant transients, which include include pressurizer insurge transient, selected CVCS transients, AFW injections and RHR RHR actuation that will be be monitored by Metal Fatigue of Reactor Reactor Coolant Pressure Boundary Program and stated that critical and supplemental these critical supplemental transients will be monitored and tracked in order to ensure that the fatigue design limit is is not exceeded. The staff noted that as part of the response, the applicant provided a table of the critical and supplemental transients that are required for monitoring for Units monitoring Units 1 andand 2, along with the basis of selection and the selection criteria of these transients. The staff further noted that the applicant selected selected these critical and supplemental transients because the projected cycles for these transients are expected expected to approach approach the design cycles during the period of extended operation.

Based on its review, the staff finds the applicant's response to RAI B.2.27-1 acceptable because because provided the complete list of critical and supplemental transients that will be the applicant has provided be monitored by the Metal Fatigue of Reactor Coolant Pressure Boundary Program Program and has has included an appropriate appropriate basis for selecting these transients to be monitored by the program during the period of extended operation. Therefore, Therefore, the staff's concern concern described in B.2.27-1 is resolved.

RAI B.2.27-1 In LRA Section B.1.3, the applicant provided provided the following elements: (a) corrective actions, (b) confirmation (b) confirmation process, and (c) administrative administrative controls common to all AMPs. The staff issued RAI in order to verify the specific activities for those elements under this program.

an RAI RAI 8.2.27-2, In RAI B.2.27-2, dated 28, 2008, the staff requested that the applicant provide the dated May 28,2008, the information on the design transient cycle-based cycle-based acceptance acceptance criterion that will be used to initiate initiate corrective actions actions ifif the criterion is exceeded, exceeded, and provide provide a discussion on what these follow-up follow-up corrective actions actions would entail if the acceptance acceptance criterion is exceeded exceeded and the process is incorporated into the plant-specific incorporated plant-specific implementation implementation procedure procedure for the Metal Fatigue of Reactor Coolant Pressure Pressure Boundary Boundary Program.

response to RAI In its response RAI B.2.27-2, dateddated July 11, 11, 2007, the applicant applicant stated that, as part of thethe implementing procedure for the Metal Fatigue implementing Fatigue of Reactor Boundary Program, Reactor Coolant Pressure Boundary the number number of accumulated accumulated cycle occurrences occurrences for the critical transients, including thethe supplemental supplemental transients, is updated updated on an annual annual basis to determine determine and and identify identify any adverse adverse trends, adverse adverse conditions and deficient deficient conditions.

conditions. The applicant defined defined the terms "adverse trend," "adverse condition" and "deficient condition" as they apply to the implementingimplementing procedure procedure for the Metal Fatigue Metal Fatigue of Reactor Coolant Pressure Boundary Program.

Reactor Coolant Pressure Boundary Program. The applicant clarified clarified that the intent of its implementing implementing procedure procedure is to detect adverse adverse trends and adverse adverse conditions conditions early on, so that the likelihood of a deficient deficient condition can be prevented. The applicant applicant further further indicated indicated that it will perform perform an evaluation to determine determine when aa rigorous analysis or an alternate alternate solution is needed. When an adverse adverse trend or condition has occurred occurred the deficient condition(s) condition(s) will be addressed addressed with with the the applicant's applicant's Corrective Actions Actions Program.

Based Based on its review, the staff finds the applicant's response to RAI applicant's response RAI B.2.27-2 B.2.27-2 acceptable acceptable because because the applicant clarified applicant clarified the triggering points associated associated with the implementing implementing procedures procedures of the the Metal Metal Fatigue Fatigue of Reactor Reactor Coolant Pressure Pressure Boundary Boundary Program and the the applicant's procedures applicant's procedures initiate corrective corrective actions actions prior to the loss loss of the components components intended intended function.

function. Therefore, Therefore, the the staff's concern staffs concern described described in RAI B.2.27-2 B.2.27-2 is resolved.

resolved.

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The staff noted that in LRA B.2.27, the applicant indicated indicated that supplemental transients transients are identified by the Metal Fatigue of Reactor identified Reactor Coolant Pressure Boundary Boundary Program Program for monitoring.

The staff required additional information information in order order to complete its review of this program.

In RAI B.2.27-7, dated May 28, 2008, the staff requested 28,2008, requested that the applicant provide provide additional information information related to the supplemental supplemental transients identified by the program for monitoring.

Specifically, Specifically, the applicant was asked to (a) identify the major components affected by the the transients and confirm that a related fatigue analysis has been updated; updated; (b) justify consistency between between supplemental supplemental transients and design transients, (c) explain the method used to monitor monitor these transients, and indicate indicate whether the number of number design design cycles for the supplemental transients will remain valid for the period of extended operation.

In its response to RAI B.2.27-7, dated July 11, 11, 2007, the applicant clarified that all supplemental transients listed in the LRA are applicable applicable to both Units 1 and 2. The applicant applicant continued in its response response by listing those components components that are affected by each of the transients transients (pressurizer (pressurizer insurge/outsurge, insurge!outsurge, selected CVCS, AFW injection and RHR activation). The staff noted that the the applicable analyses applicable analyses for the components specified components specified by the applicant applicant have have incorporated incorporated the the corresponding corresponding transients transients affecting affecting these components components and do not require require a revision, with the the exception exception of the ASME Class 1 portion of the Unit 2 charging piping. piping. The applicable applicable analyses analyses for the ASME Class 1 portion of the Unit 2 charging piping is part of the applicant's applicant's commitment commitment (Commitment (Commitment No. No.1)1) to perform perform a re-analysis and to incorporate incorporate the revised revised design cycles of the the selected selected CVCS transients.

The applicant stated that the AFW injection transient was incorporated incorporated into the original analysis analysis for the Unit Unit 2 reactor coolant pumps (RCPs), pressurizer and loop stop valves. However, Westinghouse Westinghouse did not identify this transient in the NSSS transients transients and; therefore, itit was not a part of the original design basis. The applicantapplicant specifically added this transient for the SGs as as part of the design design basis for the extended extended power uprate. The staff noted that the RHR Activation Activation for Unit 2 was part of the original design design basis, and was considered considered a supplemental supplemental transient

.because because the applicant expected expected that the cycles would exceed exceed the design cycles. HoweverHowever based based on its response response to RAI B.2.27-4, the applicant no longer expects these cycles to exceed the design cycles.

The staff noted that in its response to RAI B.2.27-7, the applicant is capable of monitoring monitoring thethe pressurizer insurge/outsurge, selected pressurizer insurge!outsurge, selected CVCS and AFW injection transient with the use of the the Plant Computer data archiving system. The staff further noted noted that with the use of the Plant Plant Computer, the applicant applicant is able to identify identify the pressurizer pressurizer insurge!outsurge insurge/outsurge transient the transient via the surge surge. line thermocouple thermocouple that will detect a delta-temperature delta-temperature and allocateallocate itit into a pre-existing pre-existing band band of delta-temperatures.

delta-temperatures. The applicant applicant explained that the selected CVCS transients are identified identified with the use of the Plant Computer by noting the valve positions and that the AFW injection transient can be identified by noting the operation operation and system flow rates of the AFW pumps during Plant Mode 1,2 1, 2 and 3. As discussed in the staff's evaluationevaluation of RAI B.2.27-4, RHR activation RHR activation can be identified identified when the plant transitions transitions between between Mode 3 and Mode Mode 4.

Based Based on its review, the staff finds that the applicant has provided provided sufficient sufficient detail pertaining to to the supplemental supplemental transients transients identified by the applicant, the components components affected by these these transients and the method method of monitoring monitoring and identification identification of these transients during the period of extended extended operation.

operation. The staff concludes concludes that, based on its review, the adequate information information 3-60 3-60

provided by the applicant, and the fact that the applicant has committed provided committed to re-analyzing re-analyzing the the Unit 2 charging charging piping to incorporate incorporate the revised revised design cycles, the applicant's applicant's response is acceptable.

acceptable. Therefore, the staff's concern concern described in RAI B.2.27-7 is resolved.

During the audit, the staff reviewed reviewed the onsite basis documents documents supporting supporting the LRA and and discussed its review with the applicant. The staff found that LR basis document document (FMP(FMP Program Program Document LRBV-PED-X.M1)

LRBV-PED-X.M1) Table Table 6.0-1, 6.0-1, element 10 stated that "The design transient transient assumed by original designdesign analysis will be sufficient for 60 years operation." The staff noted this sentence sentence is also stated in the operating experience experience Section of LRA Section Section B.2.27.

However, the annotation (a) of LRA Table 4.3-1 states that the projected 60-year cycles RHR cycles of RHR system piping are expected to exceed the design cycles cycles by 50 percent.

In RAI B.2.27-4, B.2.27 -4, dated May 28, 2008, the staff requestedrequested that the applicant applicant justify the the discrepancy discrepancy between between the text in the LRA and onsite basis documents documents and the annotation (a) of 4.3-1.

LRA Table 4.3-1.

In its response to RAI B.2.27-4, dated July 11, 2007, the applicant stated that for the location July 11,2007, location with the annotation (a), RHR System Piping, the transient that is of concern is "Placing RHR in in Service,"

Service," which occurs at approximately approximately 350OF 350°F during plant shutdown shutdown procedures. The applicant applicant further stated that Westinghouse Westinghouse performed performed its initial counting of this transient transient assuming assuming that itit occurs every time the plant transitions transitions from Mode Shutdown) to Mode 4 (Cold Mode 3 (Hot Shutdown)

Shutdown),

Shutdown), which is documented documented in Westinghouse Westinghouse Commercial Power (WCAP)-16173-P. The The staff verified in the applicant's applicant's UFSAR and TSs that RHR is placed placed into service when the plant plant cools down from 350 35000 F to less than 200 20000 F. The applicant applicant noted that this method of counting is very dependent dependent on an accurate account accurate account of the plant modes and the transition between between ModeMode 3 and Mode Mode 4.

The staff noted that the applicant applicant had performed performed an evaluation, to obtain an accurateaccurate count from the plant mode history from Power Ascension Testing until October 15, 2003. The applicant's applicant's result from this recount was 31 events compared to Westinghouse's Westinghouse's count of 85 events. The The staff compared compared the results of the applicant's recount with LRA Table 4.3-2 and noted noted that Unit 2 has had 30 plant cooldown cooldown cycles.

Based on its review, the staff finds the applicant's response response to RAI B.2.27-4 RAI B.2.27 acceptable because

-4 acceptable because the applicant applicant performed evaluation to determine performed an evaluation determine an accurate accurate count of the "Placing RHR in Service" transient and has demonstrated demonstrated that its new count is reasonable, reasonable, since the transient has occurred occurred every every time the plant experienced experienced the transient "Plant Cooldown." Therefore, Therefore, thethe staff's concern concern described in RAI B.2.27-4 is resolved.

In LRA Table 4.3-2, the applicant provided the design transients transients for the transient transient cycle cycle projection. Plant program basis documentdocument ADM 2115 also provides those transients. The staff staff noted noted that the design transients were inconsistent inconsistent with those in the latest associated associated piping design design specification. determined that additional specification. The staff determined additional information was required In order to to confirm consistency between confirm the consistency between the documents.

documents.

In RAI B.2.27 B.2.27-5,

-5, dated May 28, 2008, the staff requested that the applicant provide aa comparison comparison of the design transients in the LRA table and the basis document document and the transients transients in the latest latest associated piping design specification documents for Unit 2. The staff also specification documents

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justify any discrepancy requested that the applicant justify discrepancy between between the LRA table and plant documents documents (ADM 2115 and design design specification).

specification).

In its response to RAI B.2.27-5, dated July 11, 11, 2007, the applicant confirmed that there are no no discrepancies between discrepancies between LRA Table 4.3-2 and its plant documents, which include include AMD 2115 and the design specifications.

specifications.

Based on its review, the staff finds the applicant's response to RAI B.2.27-5 B.2.27-5 acceptable acceptable because because the applicant has confirmed confirmed that there are no discrepancies between LRA Table 4.3-2 and its discrepancies between plant documents. Therefore, the staffs staff's concern described described in RAI B.2.27 -5 is resolved.

B.2.27-5 resolved.

The staff noted during review of the applicant's basis document during its review document that the design transient, RHR actuation (activation), for Unit 1 does not require monitoring. The staff determined that additional information additional information was required in orderorder to complete its review.

In RAI B.2.27 May 28, 2008, the staff requested that the applicant

-9, dated May B.2.27-9, applicant justify the basis for monitoring the Unit 1 design transient, RHR actuation, not monitoring actuation, for the period of extended extended operation.

In its response to RAI B.2.27-9, dated July 11, 11, 2007, the applicant RHR system applicant stated that the .RHR tee for Unit 1 is a NUREG/CR-6260 NUREG/CR-6260 location that has been evaluated environmentally evaluated for environmentally originally designed to the assisted fatigue. The applicant further stated that this location was originally assisted the American American National Standards Standards Institute (ANSI)

(ANSI) B31.1 standard standard and re-evaluated re-evaluated under American American (ASME) Code Section III to determine Mechanical Engineers (ASME)

Society of Mechanical determine a CUF. The staff noted that the applicant has amended the LRA to include enhancement to the Metal include an enhancement Metal Fatigue Fatigue of Boundary Program to require that the design Pressure Boundary Reactor Coolant Pressure RHR design transient, RHR Activation monitored. The applicant Activation for Unit 1 be monitored. committed (Commitment Nos. 25 and 26 for applicant committed respectively) to monitor Units 1 and 2, respectively) monitor transients in which which the 60-year projected cycles are used 60-year projected environmentally assisted fatigue evaluations.

in environmentally applicant's response Based on its review, the staff finds the applicant's response to RAI B.2.27 B.2.27-9-9 acceptable because acceptable because the applicant applicant has amended the LRA and has committed (Commitment No.25) to monitor the committed (Commitment the RHR activation transient for Unit 1 with the Metal activation transient Metal Fatigue of Reactor Coolant Pressure Boundary Program. Therefore, the staff's concern described Boundary described in RAI B.2.27-9 is resolved.

During the onsite discussion, the applicant applicant stated "the surge line to hot leg nozzle stated "the nozzle for Units 1 included in a stress and fatigue model to be used in an on-line monitoring system.

and 2, is included system. The The staff determined information was required determined that additional information required in order to complete complete its review.

In RAI B.2.27-3, dated May 28, 2008, the staff requested that the applicant explain the purpose May 28,2008, purpose of the on-line (WESTEMS) in the management monitoring system (WESTEMS) on-line monitoring components subject to management of components to metal fatigue, including NUREG/CR-6260 NUREG/CR-6260 components components for the period of extended extended operation. The The staff requested that the applicant provide staff also requested provide its benchmarking WESTEMS benchmarking results for the WESTEMS software, using relevant transient data and proper 3-D modeling, and justify the use of this software, this software to update the CUF calculation, software monitored or projected transient data (cycles).

calculation, using the monitored In its response response to RAI B.2.27-3, dated July 11, 11, 2007, the applicant stated stated that WESTEMS WESTEMS is pressurizer lower used only in the analysis of the pressurizer lower shell and related components and the surge related components surge pressurizer spray nozzle of Unit 1. The line to hot leg nozzle for both Units 1 and 2 and the pressurizer The applicant continued to describe applicant further stated that the analysis for each location is different and continued describe 3-62 3-62

how WESTEMS is used for aging management management for each of the locations locations listed above, as as requested by the staff.

Westinghouse collaborated on the applicant's applicant's response by providing an explanation explanation of the the methods utilized by the WESTEMS software in performing methods utilized performing the fatigue evaluations evaluations for the the locations locations listed above. In addition, Westinghouse provided provided the applicant applicant with its benchmarking benchmarking results, accompanied several graphs that compared the stress results generated accompanied by several generated from from WESTEMS fatigue analysis WESTEMS analysis software software and those generated generated from the traditional finite element element ANSYS analysis. The staff noted from the graphs graphs provided by Westinghouse that the difference difference between the stress stress results generated WESTEMS and ANSYS, was negligible.

generated by WESTEMS negligible.

Based on its review, the staff finds the applicant's applicant's response response to RAI B.2.27 B.2.27-3-3 acceptable acceptable because because the applicant applicant has provided provided adequate information pertaining to the use of WESTEMS WESTEMS system at Units 1 and 2 and that there difference between the stress results generated by there is a negligible difference WESTEMS WESTEMS and ANSYS. Therefore, the staff's staffs concern concern described described in RAI B.2.27-3 B.2.27-3 is resolved.

resolved.

In LRA Section 4.3.2.2, the applicant indicated indicated that the Metal Fatigue of Reactor Reactor Coolant Coolant Pressure Boundary Boundary Program monitors the transients associated associated with non-regenerative non-regenerative (letdown) heat exchanger, regenerative regenerative heat-exchanger, and RHR heat exchangers. exchangers. However, LRA Section B.2.27 did not indicate that monitoring monitoring of the relevant relevant transients transients will be provided by this this AMP.

In RAI B.2.27 B.2.27-1 0, dated May 28, 2008, the staff requested that the applicant

-10, applicant provide provide a list of the the transients associated with the heat heat exchangers, identify identify which of these transients are monitored by the program, program, and explain what corrective corrective actions are taken when the current analyses analyses areare not bounding bounding for 60 years of operation.

In its response to RAI B.2.27-10, B.2.27-1 0, dated July 11, 11, 2007, the applicant clarified clarified that all auxiliary system heat exchangers, exchangers, which include include letdown heat exchanger, regenerative regenerative heat exchanger exchanger and RHR heatheat exchangers, exchangers, for both Unit 1 and 2 are installed on the Class 2 part of the their their respective systems and the primary side of these auxiliary heat exchangers exchangers were designed in accordance with ASME Code Section III, accordance III, Class 22 requirements.

requirements. The staff noted noted that since these heat exchangers exchangers were designed designed in accordance accordance with ASME Code Section III, III, Class 2 rules, aa fatigue analysis in accordance accordance with the ASME Code Section Section III Class 1 requirements is not applicable. The staff further noted that the expected total number of thermal cycles for the heat exchangers in question will be less than the 7000 thermal cycles required by ASME exchangers ASME Code Class 22 thermal analysis and: thus, monitoringmonitoring or a fatigue re-analysis is not required. The The applicant amended amended LRA Sections 4.3.2.2 and A.3.3.2.2 and associated sub-sections and added sub-sections LRA Section Section A.2.3.2.2 to reflect the discussion above. The staff noted that since these heat heat exchangers are bounded by 7000 equivalent full-temperature full-temperature cycles cycles for 60 years of operation, they will no longer be dispositioned under 10 CFR 54.21(c)(1)(iii),

54.21 (c)( 1)(iii), where the MetalMetal Fatigue of Reactor Coolant Pressure Boundary Reactor Program will be used Boundary Program monitoring; rather, they will be used for monitoring; be dispositioned under under 10 10 CFR 54.21 (c)(1 )(i), where by the TLM TLAA remains valid for the period of extended operation.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.27 B.2.27-1-10 0 acceptable acceptable because the applicant has verified that the heat exchangers in question are designed heat exchangers designed under ASME Code Section III, Class 2 rules, and have been evaluated Section III, evaluated such that they will not exceed the 7000 equivalent full-temperature full-temperature cycles and; thus, will not be monitored under the Metal 3-63 3-63

Fatigue of Reactor Coolant Pressure Boundary Boundary Program. Therefore, Therefore, the staff's concern described described in RAI B.2.27-10 is resolved.

resolved.

Enhancements. Enhancement Enhancements. Enhancement 1 - The staff noted in the LRA that the applicant did not identify its Metal Fatigue of Reactor Coolant Coolant Pressure Pressure Boundary Program as AMP that is consistent with GALL AMP X.M1,X.M1, with enhancement. The staff determined determined that additional information information was was required to complete its review.

required In RAI B.2.27-6, dated May 28,2008, 28, 2008, the staff requested that the applicant provide provide additional information on the components components that are within the scope of the program, program, how how the program monitors for the impact impact of thermal transients on the CUFs for critical critical locations, how the program program is updated to perform periodic periodic updates of the CUF calculations for ASME Code Class 1 components, components, and how the program accounts for environmentallyenvironmentally assisted assisted fatigue on the CUF CUF values for critical critical ASME Code Class 1 locations locations in the RVs and RCS piping.

In its response to RAI B.2.27-6, In B.2.27 -6, dated July 11, 11, 2007, the applicant applicant amended LRA Section Section B.2.27 to provide the program elements of the Metal Fatigue of Reactor program elements Coolant Reactor Coolant Pressure Boundary ProgramProgram and to provide provide the following enhancement enhancement that will affect the the "preventive actions," "parameters monitored/inspected," and "corrective actions" program "preventive actions," "parameters monitored/inspected," and element element of the program:

Add a requirement that fatigue will be managed managed for the NUREG/CR-6260 NUREG/CR-6260 locations. This requirement requirement will provide management is accomplished provide that management accomplished by one one or more of the following:

(1) Further refinement refinement of the fatigue analyses to lower the predicted predicted CUFs to less than 1.0; (2) Management of fatigue at the affected Management affected locations locations by an inspection inspection program that has been reviewed reviewed and approved by the NRC (e.g.

non-destructive examination periodic non-destructive examination of the affected locations locations at intervals to be determined inspection intervals determined by aa method acceptable acceptable to the the NRC); or, (3) replacement of the affected (3) Repair or replacement affected locations.

Add a requirement that provides for reanalysis, repair, or replacement replacement of thethe Unit 2 steam generator generator secondary secondary manway bolts and the steam generator generator tubes tubes such that the design bases of these components are not exceeded exceeded for the period period of extended extended operation.

The staff reviewed reviewed this enhancement, noting that with respect to the applicant's applicant's option to refine refine the CUF analyses analyses to maintain maintain the predicted predicted CUFs to less than a design-basis design-basis CUF limit of 1.0, (a)

(a) the option is consistent consistent with the staff's recommended recommended "preventative actions" program element element in GALL AMP X.M1; (b) (b) the fatigue usage maintained below usage factor will be maintained below the design design code limit, taking into account account the effects of the reactor water environment; and (c) with the water environment; the staff's recommended recommended "detection of aging aging effects," program element in GALL AMP X.M1 will be be used to perform perform periodic updates updates of the CUF calculations.

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respect to the applicant's options to either With respect either refine refine the fatigue analysis analysis for impacted impacted ASME ASME Code Code Class 1 compacts or to repair or replace the the impacted locations, the staff noted that the the applicant's options options are are consistent consistent with the staff's recommended "corrective "corrective actions" program element in GALL AMP X.M1. This GALL AMP states that acceptable corrective actions for these type of AMPs include either repair or replacement activities on the impacted locations or more rigorous analyses of the impacted components to demonstrate demonstrate that the design-basis code limit limit of 1.0 of 1.0 for CUFs will not be exceeded during the extended period of operation. The staff further noted that, since this AMP is credited with acceptance acceptance of the TLAA on environmentally-assisted environmentally-assisted metal fatigue of AMSE Code Class 11 components, the applicant's option to manage the impact impact of environmentally-assisted environmentally-assisted metal fatigue, and to monitor for fatigue-induced fatigue-induced cracking using an inspection-based program, was in accordance accordance with the staff's criterion for accepting TLAAs TLAAs 54.21(c)(1)(iii),

pursuant to 10 CFR 54.21(c)(1 )(iii), where byby the effects of aging will be managed managed for the periodperiod of extended operation.

of The staff verified that the applicant incorporated incorporated this enhancement as part of revised Commitment No. 25 in UFSAR Supplement Table A.4-1 for Unit 1 and revised Commitment Commitment No. 26 in UFSAR Supplement Table A.5-1 for Unit 2.

Based on its review, the staff finds that this aspect of the applicant's enhancement enhancement is acceptable. The staff also finds the applicant's response to RAI B.2.27 B.2.27-6 -6 acceptable acceptable because the applicant has enhanced the Metal Fatigue of Reactor Coolant Pressure Boundary Boundary Program such that itit is consistent consistent with the recommendations provided in the program elements, "preventative actions",

"preventative actions", "detection "detection of of aging effects" and aging effects" and "corrective "corrective actions" actions" ofof GALL AMP X.M1 or with the acceptance acceptance criterion in 10 10 CFR 54.21 (c)(1 )(iii). The staff further finds that the the applicant applicant has reflected reflected this enhancement enhancement in the revised Commitment Commitment No. 25 in UFSAR UFSAR Supplement Table Table A.4-1 for Unit 1 and No. 26 in UFSAR Supplement Table A.5-1 for Unit 2.

Therefore, Therefore, the staff's concern in RAI B.2.27-6 is resolved.

As part of the applicant's response response to RAI 4.3-2, the staff noted that the applicant included, included, as as part of this enhancement enhancement to the Unit 2 Metal Reactor Coolant Pressure Boundary Metal Fatigue of Reactor Program, that the applicant applicant will re-analyze, repair, or replace replace the Unit 2 SG secondary secondary manway bolts and SG tubes for the period of extended extended operation. The staff verified that the applicant applicant has has incorporated incorporated this enhancement enhancement as part of revised Commitment No. 26 for Unit 2, as provided provided in UFSAR Supplement Table A.5-1.

UFSAR Supplement A.5-1. The staff staff also verified verified that this enhancement enhancement for the Unit 2 SG secondary manway bolts and SG tubes is consistent secondary manway consistent with the recommendations recommendations in the the "corrective "corrective actions" actions" program program element element of GALL AMP of GALL AMP X.M1 X.M1 which states states that "acceptable "acceptable corrective corrective actions include repair repair of the component, replacement replacement of the component, or a more more rigorous analysis rigorous analysis of the impacted component to impacted component demonstrate demonstrate that the design code limit will not be exceeded exceeded during the extended extended period of operation."

Based Based on its review, the staff finds that this aspect of the applicant's applicant's enhancement enhancement is acceptable acceptable because it is consistent with the recommendations because recommendations that are are provided in the program elements of program elements GALL AMP X.M1, X.M1, asas described described above, and and because because the applicant applicant has has reflected reflected this this enhancement in revised enhancement in revised CommitmentCommitment No. 26 in UFSAR Supplement UFSAR Supplement Table Table A.5-1 for Unit Unit 2.

Enhancement 22 - The staff Enhancement staff noted noted that in the LRA, the the applicant applicant did did not not identify identify its Metal Metal Fatigue Fatigue of Reactor Reactor Coolant Pressure Pressure Boundary Boundary Program Program as as anan AMP that is consistent consistent with GALL AMP X.M1, X.M1, with enhancement.

enhancement. In its audit audit of the the license license renewal renewal basis document document for the the Metal Metal Fatigue of of Reactor Reactor Coolant Coolant Pressure Pressure Boundary Boundary Program, the staff staff noted that the applicant the applicant 3-65 3-65

stated that the design basis transient monitoring for actuation transient monitoring actuation of the Unit 1 RHR system was not required.

In RAI B.2.27-9, B.2.27 -9, dated May 28, 2008, the staff requested that the applicant provide provide its basis for concluding concluding that actuations of the BVPS Unit 1 RHR system did not require cycle counting when the new 60-year 60-year ASME ASME Code Section III CUF analysis and environmentally-assisted environmentally-assisted fatiguefatigue analysis analysis for the limiting Unit 1 RHR nozzlenozzle was impacted by this transient.

In its response to RAI B.2.27-9, B.2.27 -9, dated July 11, 11, 2008, the applicant amended LRA incorporate this enhancement Section B.2.27 to incorporate enhancement which affects the programprogram element, "parameters monitored/inspected."

monitored/inspected." The enhancement enhancement states the following:

Add a requirement requirement that provides provides for monitoring monitoring of the Unit I RHR Activation Activation transient and establishes establishes an administration administration limit of 600 cycles for the transient.

Add a requirement to monitor Unit I and Unit 2 transients transients where the where the 60-year projected cycles are used in the environmental environmental fatigue evaluations, and establish an administration administration limit that is equal to or less than the 60-year projected projected cycles number.

applicant also stated that itit had to perform The applicant perform aa new 60-year 60-year ASME Code Section Ill-based Section III-based environmentally-assisted fatigue-based CUF analysis because CUF analysis and a new 60-year environmentally-assisted because the component component was designed to ANSI B.31.1 design design standards. The applicant applicant also stated stated that, the new 60-year 60-year ASME ASME code Section Ill-based and environmentally-assisted Section III-based fatigue-based CUF environmentally-assisted fatigue-based CUF calculations were based based on the assumption of 600 cycles of RHR system actuations. The The applicant stated that as a result of the new calculations, calculations, the Metal Fatigue of Reactor Coolant Coolant Pressure Boundary Program Pressure Boundary Program will be amended amended and enhanced to include (a) a new cycle cycle monitoring requirement for the BVPS Unit 1 RHR actuation transient and (b) monitoring (b) a new requirement requirement establish 600 cycles of RHR actuation to establish actuation as the cycle-based cycle-based acceptance acceptance criterion for monitored monitored actuations at BVPS Unit 1.

RHR actuations The staff noted that as part of this enhancement, the applicant is adding a requirement to monitor the Unit 1 RHR activation transient transient where the 60-year projected cycles may approach 60-year projected approach the analyzed number analyzed number of cycles during the period period of extend operation. The staff further noted that for the remaining remaining Unit 1 and 2 transients whose 60-year projection cycles cycles were used in the the fatigue evaluations evaluations of the NUREG/CR-6260 NUREG/CR-6260 recommended recommended locations, the applicant applicant also will monitor with the Metal Fatigue of Reactor Pressure Boundary Reactor Coolant Pressure Boundary Program and will require that an administration administration limit be established established that is equal to or less than the 60-year projected projected cycles number.

The applicant applicant stated that these changes would be reflected in an amendment amendment of the LRA. The The staff verified that the applicant has amended amended LRA Section B.2.27. The staff also verified that thethe incorporated this enhancement applicant has incorporated enhancement to the MetalMetal Fatigue Fatigue of Reactor Coolant PressurePressure Boundary Program in its revision of Commitment No. 25 in UFSAR Boundary Supplement Table A.4-1 for UFSAR Supplement Unit 1 and in its revision of Commitment Commitment No. 26 in UFSAR UFSAR Supplement Supplement Table Table A.5-1 for Unit 2.

Based on its review, the staff finds the applicant's response to RAI B.2.27-9 B.2.27 -9 acceptable because acceptable because the applicant applicant has (a) amended amended the LRA and has committed (Commitment No. 25) that the Unit 1 RHR activation transient will be monitored monitored with the Metal Fatigue of Reactor Coolant Reactor Coolant Pressure 3-66 3-66

Boundary Program Program and (b) (b) set an administration administration limit for the Unit 1 RHR activation transient transient so that corrective actions will be initiated initiated prior to loss of the components intended functions.

Therefore, the staff's concern described in RAJ concern described B.2.27-9 is resolved.

RAI B.2.27-9 Experience. In LRA Section B.2.27, the applicant Operating Experience. applicant stated that the Corrective Corrective Action Action documented concerns Program documented concerns for the overall health of the transient/cycle transient/cycle counting counting program.

Corrective Corrective actions identified identified aa program owner, developed an administration administration program document document and updated it to incorporate incorporate responsibilities, improved cycle counting, counting, and established established aa process for engineering engineering to evaluate plant data. Fatigue monitoring, to date, indicates that the Fatigue monitoring, the number of design design transient events assumedassumed in the original design analysis will be sufficient for aa 60-year operating period. The applicant also stated that the program 60-year operating program hashas remained remained responsive responsive emerging issues and concerns, particularly to emerging particularly the pressurizer pressurizer surge and spray nozzle, hot leg leg surge nozzle, and surge line transients.

For example, the applicant stated stated that in 2002, a Westinghouse Westinghouse evaluation evaluation found that the Unit 2 letdown, charging, and excess excess letdown piping could exceed their design design allowable cycle counts counts for for several design transients; however, further evaluation of existing plant operations operations and the the physical separation separation distance of the letdown and excess letdown piping indicated that no further evaluation of the piping was required for current operationoperation or for the period period of extended operation. A re-analysis of the charging charging piping was required to accountaccount for the appropriate appropriate transients for a 60-year 60-year plant life.

The applicant further stated that this responsiveness to emerging emerging issues and continued continued program improvements prove that the program will remain effective improvements managing cumulative effective in managing cumulative fatigue fatigue damage damage for passive components.

The staff reviewed reviewed the operating experience experience and selected selected condition reports associated associated with thisthis AMP during the onsite audit, and interviewed interviewed the applicant's applicant's technical staff to confirm confirm that thethe effects of aging will be managed managed adequately adequately so that the system and component intended function(s) will be maintained during the period of extended operation. operation. The staff noted noted that thethe indicated a re-analysis LRA indicated re-analysis of the charging piping was required to account account for the appropriate appropriate transients for a 60-year plant life.

B.2.27-8, In RAI B.2.27 -8, dated dated May 28, 2008, the staff requested that the applicant applicant justify the basis for the applicant's applicant's determination determination that no further evaluation letdown or excess letdown piping evaluation of the letdown piping was required and provide results from the re-analysisre-analysis of the charging piping and its environmentally-assisted fatigue evaluation.

environmentally-assisted In its response to RAI B.2.27-8, dated dated July 11, 11, 2007, the applicant provided an explanation applicant provided explanation of the transients transients that are of concern for the Class 1 portion of the Unit 2 charging, letdown letdown and excess letdown systems and how they affect these systems. The applicant applicant stated that the the following three specific transients can affect the above mentioned systems: (1) isolation of letdown flow; (2) isolation of charging flow; and (3) (3) placing placing excess excess letdown letdown in service. The The applicant further stated that based on the Westinghouse Westinghouse count provided provided in WCAP-16173-P, WCAP-16173-P, the the 60-year projection for the Unit 22 charging, charging, letdown and excess letdown letdown transients would exceed the design limit during the period extended extended operation.

operation. As of October 15, 2003, Westinghouse Westinghouse identified there to be approximately identified approximately 1,076 thermal cycles. This concern concern was addressed with the the FENOC corrective actions program, at which which time the applicant stated that follow-up follow-up Westinghouse evaluation investigations had indicated that the Westinghouse evaluation in WCAP-16173-P WCAP-16173-P combined the the 3-67 3-67

three transients listed above above as if they affected all the same components, components, which was was conservative. The staff confirmed that these three transientstransients do not affect the same components components and the applicant applicant provided provided an explanation explanation of how each of the three transients affects the the letdown piping and excess letdown letdown piping.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.27B.2.27-8-8 acceptable acceptable because because the applicant applicant has demonstrated demonstrated that the charging, charging, letdown and excess letdown transients do not affect the same components components and; therefore, therefore, do not require further evaluation. The staff also finds that the applicant applicant has provided provided reasonable reasonable detail as to how these transients transients affect the the letdown and excess letdown piping. The staff further finds that the applicant has committed committed (Commitment No.

(Commitment No.1)1) to perform a re-analysis for the applicable applicable NUREG/CR-6260 NUREG/CR-6260 locations, including the Unit 2 charging piping, and submit the results to staff, with aa summary summary of how the the analysis was performed, no later than October October 15, 2008. Therefore, the staff's staffs concern described in RAI B.2.27-8 B.2.27-8 is resolved.

By letter dated October 2,2008 dated October 2, 2008 the applicant stated it, (a) has completed stated it, completed the re-analysis re-analysis and provided the results and methodology which demonstrateddemonstrated that the CUF, includingincluding environmental NUREG/CR-6260 locations will remain environmental factors for the NUREG/CR-6260 remain below below the code allowable allowable limit of 1.0, except for the Units 1 and 2 pressurizer pressurizer surge surge line to hot leg nozzle; (b) (b) will manage manage the all NUREG/CR-6260 NUREG/CR-6260 locations, including the Units 1 and 2 pressurizer pressurizer surge line to hot leg nozzle, with the Metal Fatigue of ReactorReactor Coolant Pressure Boundary Boundary Program; Program; and (c) calculated calculated the environmental correction life fatigue factor (i.e., Fen) Fen) for stainless steels for thosethose locations requiring re-analysis locations re-analysis in accordance accordance with NUREG/CR-5704.

NUREG/CR-5704.

The staff staff confirmed that the "operating experience" experience" program program element element satisfies the criterion criterion defined defined in the GALL ReportReport and in SRP-LR SRP-LR Section A. 1.2.3.10.

A.1.2.3.1 O. The staff finds this program program element element acceptable.

UFSAR Supplement. In LRA Section Section A.1.27, the applicant provided provided the UFSAR supplement UFSAR supplement summarizing summarizing the Metal Fatigue of Reactor Coolant Boundary Program.

Coolant Pressure Boundary Program. The staff staff reviewed the Section of the UFSAR UFSAR Supplement Supplement and determines determines that itit is an adequate adequate summary description description of the program, as required required by 10 54.21(d).

10 CFR 54.21 (d).

The staff staff reviewed the UFSAR UFSAR Supplement Supplement summary description that was provided in LRA summary description LRA Section Section A.1.27 for the Metal Fatigue of Reactor Reactor Coolant Pressure Boundary Boundary Program. The staff staff verified that the applicant has committed (Commitments No. 25 in LRA Table A.4-1 and No. 26 in LRA Table A.5-11) to implementing Table A.5-1) implementing the enhancements enhancements prior to the period period of extended extended operation.

operation.

Conclusion.

Conclusion. Based Based on its review on its review of the applicant's of the applicant's Metal Fatigue Fatigue of Reactor Reactor Coolant Pressure Boundary Boundary Program, the staff finds all program elements, with the enhancements enhancements discussed above, consistent with the GALL GALL Report. The staff concludes concludes that the applicant has has demonstrated demonstrated that the effects of aging will be adequately adequately managed so that the intended function(s) will be maintained function(s} maintained consistent consistent with the CLB for the period period of extended extended operation, as as required by 10 CFR 54.21(a}(3}.

required 54.21(a)(3). The staff also reviewed the UFSAR supplement supplement for thisthis AMP and concludes concludes that itit provides provides an adequate adequate summary summary description description of the program, as as 54.21(d).

required by 10 CFR 54.21(d}.

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3.0.3.1.16 Welded to the Upper Penetration Nozzles Welded 3.0.3.1.16 Nickel-Alloy Penetration Upper Reactor Reactor Vessel Closure Closure Heads Program Summary of Technical Information in the Application.

Technical Information Section B.2.29, the applicant Application. In LRA Section applicant described described the existing Nickel-Alloy Penetration Penetration Nozzles Welded to the Upper Upper Reactor Vessel Closure Head Program as consistent consistent with GALL AMP XI.M1 1-A, "Nickel-Alloy XI.M11-A, "Nickel-Alloy Penetration Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads Pressurized Water Reactors Heads of Pressurized Reactors (PWRs Only)."

The applicant stated that the Nickel-Alloy Nickel-Alloy Penetration Penetration Nozzles Welded to the Upper Reactor Reactor Vessel Closure Head Program Program is an existing monitoring program designed existing condition monitoring designed to manage manage the effects of primary water water stress-corrosion stress-corrosion cracking (PWSCC) in the nickel-alloy nickel-alloy RV closure closure head penetration penetration nozzles and their associated associated nickel-alloy nickel-alloy pressure boundary boundary welds.

Staff Evaluation. The NRC issued Order EA-03-009, "Issuance of Order Establishing Interim Order Establishing Interim Inspection Requirements for Reactor Pressure Inspection Requirements Pressure Vessel Heads Heads at Pressurized Water Reactors,"

February February 11, 11, 2003, to all holders of PWR operating operating licenses. The order required required specific specific augmented inspections of RV closure augmented closure heads and the associated associated nickel:-alloy nickel-alloy penetration nozzles penetration nozzles in U.S. PWRs. The staff issued First Revised Order Order EA-03-009 on February February 20, 2004, to clarify which locations locations of the PWR vessel head penetration head penetration nozzles were applicable applicable to the Order. All PWR licensees in the U.S. were required to submit 20-day and 60-day 60-day responses responses to Order Order EA-03-009 and to First Revised Order EA-03-009 (henceforth collectively referred EA-03-009 (henceforth referred to in this this evaluation as "the Order, as amended").

The staffs staff's aging management recommendations and program management recommendations program element element criteria for Nickel-Alloy Nickel-Alloy Penetration Penetration Nozzles Welded Welded to the Upper Reactor Vessel Closure Closure Head Programs are found in in GALL AMP XI.M11-A and are based on the program program elements aspects required for compliance compliance with "the Order, as amended The staff reviewed the information in LRA LRA Section B.2.29, the applicant's license renewal basis document for this AMP, and other supporting information and documents documents that pertain to the the implementation controls for this AMP, against the regulatory procedural and implementation regulatory criteria summarized summarized in this section. Based on its review, the staff verified verified that the applicant's program is based on on the augmented augmented inspection requirements in the "Order, as amended."

The staff also verified that the applicant has proceduralized proceduralized the administrative, administrative, regulatory, and technical technical aspects of its program into both FENOC corporate-based and BVPS site-based FENOC corporate-based procedures. The staff verified that the applicant has incorporated incorporated these aspects into the the Nickel-Alloy Penetration program elements for its Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Reactor Vessel Closure Head Program Program and that the program elements for the AMP were consistent consistent with thethe staff's program element element recommendations recommendations in GALL AMP XI.M11-A. XI.M1 1-A.

Based Based on its review, the staff finds that the applicant's acceptable because itit is applicant's program is acceptable based on compliance compliance with the "Order, as amended," and conforms with the staff's program element criteria recommended recommended in GALL AMP XI.M11-A. XI.M1 1-A.

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Consistent Consistent with the staff's statement on page 52743 of the staff's Statement of Consideration Consideration on on FederalRegister Federal Register Notice Volume 73, No. 176, "10 CFR 50; Industry Codes and Standards; Requirements; Final Rule," the applicant Amended Requirements; applicant may update its program elements for the the Nickel-Alloy Penetration Penetration Nozzles Welded Welded to the UpperUpper Reactor Vessel Closure Head Program Program to reflect implementation implementation of the new augmented inspection requirements requirements in 10 CFR 50.55a(g)(6)(ii)(D) 50.55a(g)(6)(ii)(D) and ASME Code Case N-729-1 for nickel-alloy nickel-alloy upper RV closureclosure head head penetration nozzle and their associated nickel-alloy welds without having to take an exception to penetration the program recommended in GALL AMP XI.M1 program elements recommended XI.M11-A. 1-A.

Operatingq Experience. The program description Operating description in GALL GALL AMP XI.M11-A provides a sufficient XI. M 11-A provides sufficient description description of the GL and Bulletins Bulletins that formed the basis of the "Order, as amended." The The NRC-issued documents NRC-issued documents contain an adequate description adequate description of industry operating experience experience on upper RV closure closure head penetration penetration nozzle cracking. operating experience cracking. The operating experience discussion discussion in these NRC-issued NRC-issued generic generic communications communications and in the "Order, as amended," represents the the relevant operating experience experience for this AMP. Relevant industry-wide operating experience Relevant industry-wide experience from nuclear utility inspections industry-wide nuclear inspections pursuant pursuant to the "Order, as amended," confirmed that the the "Order, as amended" was necessary. These additional industry operating events industry operating events need not be be cited by the applicant applicant to justify the existence existence of the applicant's applicant's Nickel-Alloy Penetration Nozzles Nickel-Alloy Penetration Nozzles Welded Welded to the Upper Reactor Upper Reactor VesselVessel Closure Head Program Program and its program elements elements because because the NRC's issuance NRC's issuance of the "Order, as amended," already achieves already achieves that objective.

objective.

The applicant's "operating program" program element discussion for the AMP identified element discussion identified that the the implemented pursuant to the "Order, as amended." The applicant identified program is being implemented identified that in March March 2006, it had replaced the upper upper RV closure closure head for Unit Unit 1 with an RV closure closure head fabricated from Alloy 690 materials. The applicant applicant stated that this puts the Unit 1 RV closure head in the "replaced" ranking category of the "Order, as amended." The staff confirms confirms that the applicant's applicant's actions are in compliance with the requirements requirements of the "Order, as amended,"

and that they conform conform with the staffs recommended recommended "detection of aging effects," and "monitoring program element and trending" program element criteria in GALL AMP XI.M1 XI.M11-A 1-A and; therefore, are acceptable.

acceptable.

The applicant also identified that it had performed performed ultrasonic ultrasonic testing (UT) (UT) examinations examinations of the the upper RV closure closure head penetration penetration nozzles nozzles at Unit 2 during during RFO 12 (2006). The applicant applicant stated stated that the UT examinations examinations detected relevant flaw indications indications in a number of the unit's RV closure head penetration closure head penetration nozzles nozzles and that the impacted impacted penetrations repaired in penetrations were repaired accordance accordance with accepted accepted industry practices, and that followup examinations examinations of the repaired nozzles nozzles passed the applicant's applicant's acceptance acceptance criteria.

The staff noted that from its review of the program evaluation evaluation document document for this AMP, the the applicant indicated that the current susceptibility applicant has indicated susceptibility ranking for the Unit 2 RV closure head head has has been placed on the "high" susceptibility ranking. The applicant stated that subsequent subsequent required inspections of the Unit 2 RV closure head and its nozzles will be done in accordance accordance with the the NRC's inspection inspection requirements for "high" susceptibility ranked RV closure heads. The staff also noted noted that the applicant has stated stated that itit applies the acceptance acceptance criteria in the NRC's letter letter (i.e.,

letter letter from R. Barrett [NRC] to Alex Marion [NEI], [NEI], April 11,11, 2003) as the basis for evaluating any relevant relevant flaw indications indications detected through the applicant's applicant's implementation implementation of this program. The The staff further noted noted that the applicant applicant has indicated that it implements any required nozzle repairs repairs or replacements replacements in accordance accordance with the repair/replacement repair/replacement requirements requirements of ASME ASME Code Section XI. XI. Finally, the staff noted that the applicant's basis for inspecting the Unit 2 3-70

nozzle in accordance nozzle inspection criteria for "high" susceptible RV closure heads is accordance with the inspection consistent with the applicant's consistent inspection findings on the Unit 2 RV closure head applicant's last inspection head and its penetration nozzles.

penetration The staff confirms that the applicant's acceptance criteria and corrective applicant's acceptance corrective actions comply with the the corrective actions specified corrective specified in the "Order, as amended,"

amended," and conform with the respective respective "acceptance criteria" and "acceptance criteria" and "corrective actions" program "corrective actions" program elements elements recommended recommended in GALL AMP XI.M11-1 XI.M1 1-1 and; therefore, are acceptable.

acceptable. Based on this assessment, the staff concludes concludes that the applicant has correctly relevant indications detected in the Unit 2 RV correctly addressed the relevant head nozzles.

closure head Based on its review, the staff concludes that the "operating experience" program element for program element this AMP has been adequately adequately addressed addressed and is acceptable acceptable because because the applicant has has implemented a required implemented required AMP to address address the relevant relevant generic generic and BVPS-specific operating BVPS-specific operating experience experience on nickel-alloy nickel-alloy component cracking cracking in upper upper RV closure head penetration penetration nozzles nozzles and welds.

UFSAR Supplement. The applicant applicant provided the UFSAR supplement supplement summary summary description for description for its Nickel-Alloy Nickel-Alloy Penetration Nozzles Welded Welded to the Upper Upper Reactor Vessel Closure Head Head Program Program in LRA Section A.1.29. The staff staff verified that, in LRA Section A.1.29, the applicant has applicant has identified that the scope of the program is applicable clearly identified applicable to the upper upper RV closure closure head, thethe upper penetration nozzles upper RV closure head penetration nozzles and any applicable nickel-alloy pressure applicable nickel-alloy pressure boundary welds that are associated associated with these components.

components. The staff confirms that this is consistent consistent with the "scope of program" programprogram element element in GALL GALL AMP XI.M1 1-A, and is acceptable. The staff XI.M11-A, staff also confirms confirms that the applicant has provided provided an acceptable summary of the Nickel-Alloy acceptable summary Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Head Program, which is Penetration designed designed to comply with the "Order, as amended," amended," and to implement the inspections inspections that are mandated mandated in the "Order, "Order, as amended."

Based Based on its review, the staff concludes Supplement A.

concludes that UFSAR Supplement 1.29 provides an acceptable A.1.29 acceptable summary description description for the applicant's applicant's Nickel-Alloy Penetration Nozzles Welded to the Upper Nickel-Alloy Penetration Upper Reactor Vessel Closure Reactor Closure Head Program. The staff reviewed this Section and determines that the the information information in the UFSAR supplement UFSAR supplement is an adequate summary description adequate summary description of the program, as as required by 10 CFR 54.21(d).

Conclusion. Based Conclusion. Based on its review of the applicant's Nickel-Alloy Penetration Nozzles Nickel-Alloy Penetration Nozzles Welded Welded to the Upper Reactor Reactor Vessel Closure Head Head Program, the staff concludes that the applicantapplicant has has demonstrated that effects demonstrated effects of aging will be adequately adequately managed so that the intended function(s) function(s) will be maintained maintained consistent with the CLB for the period period of extended extended operation, as required required by 54.21 (a)(3). The staff also reviewed the UFSAR supplement 10 CFR 54.21(a)(3). supplement for this AMP and concludes that itit provides an adequate concludes adequate summary summary description required by description of the program, as required by 10 10 CFR 54.21(d).

3.0.3.1.17 One-Time Inspection Program One-Time Inspection Summary of Technical Information in the Application. In LRA Section Technical Information Section B.2.30, the applicant applicant described the new One-Time InspectionInspection Program as consistent consistent with GALL AMP XI.M32, "One-Time Inspection."

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The applicant stated that it will implement implement the new One-Time Inspection Program prior to the One-Time Inspection the period of extended operation. This program will require one-time one-time inspections to verify effectiveness of the Water Chemistry Program, the Fuel Oil Chemistry Program, and the effectiveness the Lubricating Oil Analysis Program. One-time inspections Lubricating inspections may be needed to address concerns concerns for certain aging effects effects on SCs for potentially incubation periods. There potentially long incubation There are cases where where either (a) an aging effect is not likely to occur occur but there is insufficient insufficient data data to rule it out out completely completely or (b) an aging effect is likely to progress very slowly. For these cases, the applicant applicant stated that itit will confirm that either the aging effect has not occurred occurred or has occurred occurred so slowly as not to affect any component component or structure structure intended intended function during during the period of extended operation. inspections will add assurance that either operation. The one-time inspections either aging has not occurred or is so insignificant insignificant that no AMP is warranted.

warranted.

The applicant further stated that the elements elements of the program will include:

Determination of a representative Determination representative sample size basedbased on an assessment of materials materials of fabrication, fabrication, environment, plausible aging effects, and operating experienceexperience Determination of the inspection locations Determination locations in the system or component component based on the the aging effect or areas susceptible to concentration concentration of agents that promote certain aging aging effects effects Determination of the examination Determination acceptance criteria that would be examination technique, including acceptance be effective in managing managing the aging effect for which the component component is examined Evaluation Evaluation of the need for follow-up examinations examinations to monitor any aging aging degradation.

degradation.

In addition In addition to verifying program effectiveness, the program verifies aging effects effects are not occurring in the following components:

occurring

• Loss of material of the steam generator generator feedwater ring feedwater ring

• material of selected bottoms of tanks that sit on concrete pads (by Loss of material volumetric (by volumetric examination) examination)

Cracking Cracking of aluminum alloy moisture moisture separators separators associated with the Unit 1 Emergency Emergency Diesel Generator Generator Air Start System When aa one-time one-time inspection reveals evidence of an aging effect, routine evaluation of the reveals evidence the inspection results will indicate appropriate appropriate corrective corrective actions.

Staff Evaluation. In LRA Section B.2.30, the applicant stated stated that the One-Time Inspection Inspection Program is a new programprogram that is consistent consistent with GALL Report Report AMP XI.M32.

The staff reviewed those portions of the applicant's One-Time One-Time Inspection Inspection Program Program for which thethe applicant consistency with GALL applicant claimed consistency GALL AMP XI.M32 XI.M32 and found they are consistent with this this GALL AMP. The staff also confirmedconfirmed that the plant program contains all of the elements elements of the the referenced GALL referenced GALL program and that the conditions conditions at the plant are bounded by the conditions for which the GALL Report is evaluated.

evaluated. The staff also held onsite interviews with the applicant's applicant's personnel to confirm these results.

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The staff finds the applicant's One-Time One-Time Inspection Program acceptable acceptable because because it conforms to the recommended GALL GALL AMP XI.M32, One-Time One-Time Inspection.

Inspection.

Experience. In LRA B.2.30, the applicant Operating Experience. operating experience applicant provided the following operating experience evaluation for BVPS:

evaluation The One-Time One-Time Inspection Program is a new program; therefore, there is no Inspection Program no plant-specific program plant-specific program operating experience experience for program effectiveness.

effectiveness. Industry operating experience operating experience that forms the basis for the program is described described in the the operating operating experience experience element element of the NUREG-1801 description.

NUREG-1801 program description.

Industry Industry and plant-specific plant-specific experience evaluated in the development experience will be evaluated development and implementation implementation of this program. experience is obtained, program. As additional operating experience learned will be appropriately incorporated lessons learned incorporated into the program.

The staff reviewed aa sample of condition reports that contained mechanical mechanical components components in applicant proposed to manage with the One-Time environments that the applicant environments Inspection Program One-Time Inspection and interviewed the applicant's technical staff to confirm that the plant-specific operating applicant's technical experience experience did not reveal any aging aging effects effects not bounded by the GALL Report. Although the the stated that there is no plant-specific application stated application plant-specific operating experience for program effectiveness operating experience effectiveness because itit is a new determined that additional information was required new program, the staff determined required to complete its review.

complete B.2-1, Part 1, dated May 22, 2008, the staff requested In generic RAI B.2-1, requested that the applicant discuss applicant discuss recently degradation during observed material degradation recently observed during the implementation activities that implementation of other existing activities relate to the aging effects that will be managedmanaged by the new program and provide the results in in the "operating experience" element for that new program. Additionally, the staff requested that applicant include a commitment to provide the applicant experience in the future for new operating experience provide operating programs to confirm their effectiveness, as stated in SRP-LR, Appendix Appendix A. 1.2.3.10.2.

A.1.2.3.1 0.2.

In its response to Part 1 of RAI B.2-1, applicant stated that the One-B.2-1, dated August 22, 2008, the applicant Time Inspection Program Program will require one-time inspections inspections to verify effectiveness of the Water effectiveness Water Chemistry Program (LRA Section B.2.42), the Fuel Oil Chemistry (LRA Section Chemistry Program (LRA Section B.2.20), and the Lubricating Oil Analysis Program (LRA Section B.2.24). The applicant Program (LRA applicant further explained that the Water Chemistry Program analysis Program is an existing sampling and analysis conformance to procedural program and that conformance requirements and industry guidelines, and procedural requirements and experience reports, provide reasonable assurance sensitivity to operating experience assurance that the Water Chemistry Program will effectively Chemistry effectively manage material, cracking, and reduction manage loss of material, heat reduction of heat transfer for in-scope components during the period of extended in-scope components extended operation.

applicant also stated that the Fuel Oil Chemistry Program The applicant Program is an existing program that utilizes sampling and analysis utilizes adequate diesel fuel quality analysis to ensure that adequate maintained to quality is maintained to prevent material and fouling in the various in-scope fuel oil systems. The applicant prevent loss of material applicant exposure of fuel oil to contaminants such as water and particulates further stated that exposure particulates is also accumulated water, tank interior cleaning, and by verifying the minimized by periodic draining of accumulated minimized the quality of new oil before it is introduced before it introduced into the storage tanks. The applicant added added that the the Lubricating Oil Analysis Program has been effective at Lubricating managing aging at managing periodically aging effects by periodically sampling and analyzing lubricating oil from these in-scope components.

analyzing lubricating 3-73

The applicant verified that The that aa search of recent BVPS plant-specific plant-specific operating experience experience diddid not not identify any significant aging relatedrelated degradation associated associated with the components that will be managed by managed by the One-Time Inspection Program and and the Water Chemistry Program (See (See SER Section 3.0.3.2.14), the Fuel Oil Chemistry Program (See SER Section 3.0.3.2.8), or the the Lubricating OilOil Analysis Program (See SER Section 3.0.3.1.13). The applicant said that one-time inspections will provide additional assurance that aging does not occur, or aging is is so warranted. The applicant insignificant that an AMP is not warranted: applicant re-confirmed that the BVPS LRA LRA states that:

Industry and plant-specific Industry plant-specific operating experience will be evaluated in in the the development and implementation development implementation of this program. As additional operating experience is obtained, lessons learned experience learned will be appropriately appropriately incorporated incorporated into the program.

In its response to Part 2 of RAJ In RAI B.2-1, B.2-1, the applicant applicant amended the LRA to include a new Commitment No. 29 in LRA Table A.4-1 for Unit 1 and Commitment Commitment Commitment No. 28 in LRA Table A.5-1 for Unit 2, to perform self-assessment of all new license renewal AMPs, for perform a program self-assessment completion within five years after entering the period of extended operation.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2-1 acceptable acceptable because because the applicant has verified that the One-Time Inspection Program Program will be used to determine determine the the effectiveness of the existing AMPs, Water Chemistry Program, Fuel Oil Chemistry Program, and effectiveness the Lubricating Oil Analysis Program and that the One-Time Inspection Program has the the flexibility to incorporate incorporate additional additional operating experience experience into its requirements. The staff confirms confirms that the applicant has amended amended the LRA to include a new commitment to validate the the effectiveness effectiveness of the new license renewal AMPs based on the incorporation incorporation of operating experience. Therefore, experience. Therefore, the staffs staff's concerns described in RAI B.2-1 are resolved.

resolved.

The staff finds the applicant's applicant's One-Time Inspection Inspection Program acceptable managing the aging acceptable for managing effects for which proposed for in-scope which the program is proposed in-scope mechanical mechanical components. Further, the the staff finds that the One-Time Inspection Inspection Program Program will be effective in maintaining the the components' intended functions components' intended functions consistent with the CLB for the period of extended extended operation.

UFSAR UFSAR Supplement. The The applicant provided provided the UFSAR supplement for the One-Time UFSAR supplement One-Time Inspection Program.

Inspection Program. The staff verified verified that the UFSAR supplement summary UFSAR supplement summary description description for the the One-Time Inspection One-Time Inspection Program conforms to the staff's Program conforms staffs recommended recommended UFSARUFSAR Supplement Supplement for for these types of programs programs in SRP-LR 3.3.-2. The staff also verified SRP-LR Table 3.3.':2. verified that applicant hashas committed (Commitment committed (Commitment No. 16 16 in UFSAR UFSAR Supplement Supplement TableTable A.4-1 and Commitment No. 18 and Commitment 18 inin UFSAR Supplement Table UFSAR Supplement Table A.5-1)

A.5-1) to implement implement its new One-Time Inspection new One-Time Inspection Program.

Based Based on this review, the staff staff finds that UFSAR Supplement Supplement Section Section A.1.30 A.1.30 provides provides an acceptable acceptable UFSAR UFSAR Supplement Supplement summary summary description description of the applicant's applicant's One-Time Inspection One-Time Inspection Program Program because because itit is consistent consistent with those those UFSAR Supplement summary UFSAR Supplement description in the summary description the SRP-LR SRP-LR for One-Time One-Time Inspection Program.

Inspection Program.

Conclusion.

Conclusion. The staff staff finds the applicant's applicant's One-Time One-Time Inspection Inspection Program Program acceptable acceptable because because it is consistent consistent with with the GALL GALL Report and and the plant is bounded bounded by the conditions conditions set forth in thethe GALL GALL Report for this this AMP. Based Based on its review, the staff concludes that the applicant's applicant's One-Time Inspection Program One-Time Inspection Program will adequately adequately manage manage the agingaging effects effects so that the intended intended 3-74 3-74

functions will be maintained maintained consistent with the CLB for the period of extendedextended operation, as as required by by10 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement supplement for this this AMP and finds that it provides an adequateadequate summary description description of the program, as required required byby 10 CFR 54.21(d).

3.0.3.1.18 One-Time 3.0.3.1.18 Inspection of ASME Code Class 1 Small Bore Piping Program One-Time Inspection Summary Summary of Technical Technical Information in the Application. B.2.31, the applicant Application. In LRA Section B.2.31, applicant described described the One-Time One-Time Inspection Inspection of ASME Code Class 1 Small Bore Piping Program. Program.

The applicant stated that the One-Time One-Time Inspection Inspection of ASME Code Class 1 Small-Bore Small-Bore Piping Piping Program manages the cracking of small bore stainless stainless steel piping less than 4-inches in diameter. This program program will involve the use of volumetric volumetric inspections inspections on a sample of small-bore butt welds. If evidence evidence is discovered discovered that there is significant small-bore significant aging of small-bore program, aa periodic piping during this program, periodic inspection program program will be proposed proposed that will be plant-specific.

Inspection of ASME Code Class 1 Small-Bore The One-Time Inspection Small-Bore Piping Program Program will bebe implemented within 10 years of the beginning of the period of extended implemented extended operation.

Staff Evaluation. In In the LRA, the applicant applicant stated that the One-Time One-Time Inspection Inspection of ASME ASME Code Class 1 Small Bore Piping Piping Program Program is aa new program that is consistent with GALL AMP XI.M35, XI,M35, "One-Time Inspection Inspection of ASME ASME Class 1 Small Bore Piping."

During its audit, the staff reviewed the applicant's onsite documentation supporting onsite documentation supporting the the applicant's conclusion that the program program elements elements are consistent with the elements in the GALL Report.

The staff reviewed reviewed those portions of the applicants One-TimeOne-Time Inspection Inspection of ASME ASME Code Code Class 1 Small-Bore Piping Program Small-Bore Program that the applicant claimed consistency consistency with GALL AMP XI.M35 XI,M35 and found they are consistent consistent with this GALL AMP. The staff staff also held onsite interviews interviews with thethe applicant's technical technical staff to confirm the results.

Based on its review, the staff concluded concluded that the applicant's One-Time One-Time Inspection of ASME ASME Code Class 1 Small Bore Piping Piping Program assurance that either the aging effect is provides assurance indeed not occurring, occurring, or that the aging effect is occurring occurring very slowly as not to affect the the intended function of the component or structure. The staff finds the applicant's intended applicant's One-Time One-Time Inspection of ASME Code Class 1 Small Inspection Small Bore Piping Program Program acceptable conforms acceptable because it conforms to the recommended recommended GALL AMP XI.M35. XI,M35.

B.2.31-1, dated April 3, 2008, the staff requested In RAI B.2.31-1, requested that the applicant confirm whether there were any socket welds classified as high-safety high-safety significant, as part of the risk-informed inservice inservice inspection (ISI) program.

(lSI) program. The staff noted that these small bore socket socket welds should be given special significance. The staff also requested that the applicant document how itit will handle applicant document handle high-safety significant significant socket welds.

In its response to RAI B.2.31-1, B.2.31-1, dated dated May 5, 2008, the applicant applicant stated stated that there are six UnitUnit 1 and two Unit 2 ASMEASME Code Class 1 socket welds classified high-safety significance. There classified as high-safety are three two-inch two-inch diameter diameter socket welds classified as high-safety high-safety significance significance for seal injection injection 3-75 3-75

to the RCPs in the CVCS, and three two-inch two-inch diameter socket welds in the hot leg of the the high-head safety injection supply line at Unit 1. There are two 0.75-inch diameter socket welds 0.75-inch diameter welds on lines that connect connect to the flow element element in the reactor coolant. These socket welds are visually visually inspected (VT ~2) at operating temperature (VT-2) temperature and pressure at each RFO (every 18 months).

The staff noted that itit had previously accepted accepted visual inspection inspection of socket socket welds because there is no approved method for volumetrically inspecting inspecting socket welds.

welds.

Based Based on its review, the staff finds the applicant's applicant's response response to RAI B.2.31-1 acceptable because acceptable because demonstrated that the treatment of these high-safety significant the applicant has demonstrated welds significant socket welds is adequate. The staff confirms that because there is no accepted method to volumetrically accepted method volumetrically inspect inspect these welds, itit has accepted inspection of socket accepted visual inspection socket welds and notes that any cracks cracks that form in these welds would initiate from the inside diameter, which would be very difficult difficult to detect using using a volumetric technique technique due to the configuration configuration of the socket welds. The staff staff concludes concludes that a visual inspection inspection at operating operating temperature temperature and pressure is the the only practical method method for inspecting inspecting these welds. Therefore, the staffs described in RAI B.2.31-1 is staffs concern described acceptable.

acceptable.

Operatingq Operating Experience. The staff also reviewed operating operating experience, including selected condition reports, and interviewed interviewed the applicant's technical staff to confirm that the plant-specific plant-specific operating experience did not reveal any degradation operating experience experience. In the degradation not bounded by industry experience. the LRA, the applicant applicant stated that there is no operating experience for the effectiveness operating experience effectiveness of the One-Time Inspection of ASME ASME Code Class 1 Small Bore Piping Program because it is a new program. The staff determined determined that additional information was required additional information required to complete its review of this program.

In RAI B.2-1, B.2-1, dated 22, 2008, the staff requested that the applicant dated May 22,2008, applicant provide operating provide operating experience information in support of the One-Time Inspection Inspection of ASME Code Class 1 Small-Bore Piping Program.

In its response to RAI B.2-1, B.2-1, dated August 22, 2008, the applicant stated the following:

The existing existing license license renewal future commitment for each new new aging management management program made by FENOC in the BVPS LRA, Appendix A, Table A.4-1 (Unit (Unit 1) and Table Table A.5-1 (Unit (Unit 2), as applicable, applicable, meets the intent of the recommendation recommendation of NUREG-1800, NUREG-1800, "Standard Review Review Plan for Review of License Renewal Applications Applications for Nuclear Power Plants," Appendix A, Section A.1.2.3.10.2.

Section A.1.2.3.1 0.2. For each new each new program credited credited by FENOC for aging management management during the period of extended operation, renewal future commitment operation, a license renewal commitment is included to to implement the program prior to the period of extended extended operation "as described operation "as in" the corresponding corresponding Section of Appendix Appendix B. The Appendix Appendix B Operating Operating Experience element for each new Experience new program program includes aa statement that industry and plant-specific operating experience plant-specific operating experience will be incorporated incorporated into the program.

program.

Therefore, aa license renewal renewal commitment to consider and incorporate feedback incorporate from operating experience into new aging management operating experience management programs is included by reference reference in the LRA, Appendix A, Tables A.4-1 AA-1 (Unit 1) and Table A.5-1 (Unit (Unit 2).

In addition, the FENOC In Corrective Action Program is relied upon to document FENOC Corrective document operating experience experience that indicates indicates a lack of program program effectiveness effectiveness and initiate initiate corrective actions such that recurrence corrective recurrence of significant significant conditions is prevented.

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These Corrective Corrective Action Program activities activities are applicable programs applicable to all programs following implementation.

implementation. However, to confirm the effectivenesseffectiveness of the new license renewal management programs renewal aging management programs based on the incorporation incorporation of experience, the BVPS LRA is revised to include operating experience, include a new license renewal future commitment commitment to perform a program program self-assessment self-assessment of all new license license renewal renewal aging management management programs, to be completed five (5) years after entering the period of extended operation.

entering The staff verified that the applicant applicant has committed committed (Commitments (Commitments No. 29 on UFSAR Supplement Table A.4-1 for Unit 1 and No. 28 in UFSAR Supplement Supplement Supplement Table A.5-1 for Unit 2.

staffs concern for the Thermal Therefore, the staff's Thermal Aging Embrittlement Embrittlement of Cast Austenitic Stainless Stainless Steel (CASS) ProgramProgram as described described in RAI B.2-1 is resolved.

UFSAR UFSAR Supplement. In LRA Section A.1.31, A.1.31, the applicant provided the UFSAR supplement supplement forfor the One-Time Inspection of ASME Code Class 1 Small-Bore Small-Bore Piping Program. The staff staff reviewed reviewed this Section and determines that the information information in the UFSAR supplement supplement is an adequate summary description adequate description of the program, as required by 10 CFR 54.21 54.21(d).

(d).

Conclusion.

Conclusion. The staff finds the applicant's applicant's One-Time Inspection of ASME Code Class 1 Small One-Time Inspection Bore Piping Piping Program Program acceptable because it is consistent acceptable because consistent with the GALL Report and the plant is bounded by the conditions conditions set forth in the GALL Report Report for this AMP. Based on its review, the the staff finds that the program program will adequately adequately manage the aging effects effects so that the intended intended functions functionswill will be maintained maintained consistent consistent with the CLB for the period period of extended extended operation, operation, as required by 10 CFR 54.21(a)(3).

54.21 (a)(3). The staff also reviewed the UFSAR supplement supplement for thisthis AMP and finds that it providesprovides an adequate adequate summary summary description description of the program, as required by by 10 CFR 54.21(d).

3.0.3.1.19 Open-Cycle 3.0.3.1.19 Open-Cycle Cooling Water System Program Summary of Technical Technical Information in the Application. In LRA Section B.2.32, the applicant described described the existing Open-Cycle Cooling Water System existing Open-Cycle System Program as consistent with GALL AMP XI.M20, "Open-Cycle Cooling Cooling Water System."

The Open-Cycle Open-Cycle Cooling Water System Program implements implements commitments commitments to GL 89-13, "Service Water System Problems Problems Affecting Safety-Related Equipment,"

Affecting Safety-Related Equipment," including including Supplement 1. 1. This program program manages the aging effects effects on the open-cycle cooling water open-cycle cooling systems (CWSs)

I (CWSs) to ensure that the systems will perform intended perform intended functions during the period of of extended extended operation.

operation. The program has surveillance surveillance and control techniques techniques to manage aging effects caused caused by biofouling, corrosion, erosion, protective coating failures, and silting in the the river water river water (Unit (Unit 1) and service

1) and water (Unit service water 2) systems (Unit 2) systems or SCs SCs serviced serviced by the systems.

Staff Evaluation. In LRA Section Section B.2.32, the applicant stated that the Open-Cycle Cooing Water Water System System Program is an existing program program that is consistent with GALL AMP XI.M20, "Open-Cycle "Open-Cycle Cooling Water System," with enhancements enhancements and exceptions.

The staff reviewed those portions of the applicant's Open-Cycle Cooling Water System Program applicant's Open-Cycle that the applicant applicant claimed consistency consistency with GALL AMP XI.M20 and found they are consistent consistent with this with this GALL GALL AMP.AMP. TheThe staff staff also confirmed confirmed that the plant program contains all of the the elements of elements the referenced of the referenced GALLGALL program program andand the conditions at the conditions at the the plant plant are are bounded bounded by the the 3-77 3-77

conditions for which the GALL GALL Report is evaluated.

evaluated. The staff conducted onsite interviewsinterviews with the applicant's applicant's technical personnel personnel to confirm these results.

As a result of the staffs IP-71 IP-71002 inspections during the weeks of June 23 and July 14, 2008, 002 inspections the applicant applicant identified revisions to the LRA which include exceptions and include new program exceptions enhancements.

enhancements. The applicant applicant provided the program changes changes in its letter (L-08-262)

(L-08-262) to the staff, dated September September 9, 2008, which includes LRA Amendment which includes Amendment No. 23. The staff's review of the the enhancements enhancements and exceptions to this AMP that the applicant applicant has taken against the program program elements in GALL AMP XI.M20 evaluated in the subsections XLM20 are evaluated subsections that follow.

Enhancements. In letter Amendment No. 23, dated September letter L-08-262, Amendment September 9, 2008, the applicant applicant identifies enhancements to the "Scope of Program" and "Detection of Aging identifies the following enhancements Effects" elements.

(1) The "Scope of Program" will be expanded expanded to include aa Unit 1 post-accident post-accident sampling system heat exchanger (PAS-E-1) credited with aa leakage exchanger (PAS-E-1) leakage boundary boundary function.

(2)

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

The staff reviewed the applicant's applicant's program program enhancements enhancements and compared compared the changes with the the GALL GALL AMP XI.M20 recommendations for the enhanced XLM20 recommendations enhanced elements.

elements. The staff verified verified that the the applicant incorporated these enhancements applicant has incorporated enhancements to the Open-Cycle Open-Cycle Cooling Water System Program in Commitment No. 30 of UFSAR UFSAR Supplement Table A.4-1 for Unit 1 and in Commitment No. 31 of UFSAR UFSAR Supplement Supplement Table A.5-1 for Unit 2.

The staff finds the applicant's applicant's Open-Cycle Cooling Water System Program Program acceptable acceptable because because itit conforms conforms to the recommended recommended GALL AMP XLM20. XI.M20. and notes that implementation implementation of these enhancements enhancements and commitments commitments will make the applicant's Open-Cycle Cooling Water Systems applicant's Open-Cycle Systems consistent consistent with the GALL GALL AMP XI.M20.

Based on its review, the staff finds the applicant's enhancements to the Open-Cycle applicant's enhancements Open-Cycle Cooling Cooling Water System Program acceptable acceptable because they will make the "scope of program" and "detection of aging effects" program elements of the AMP consistent with the staffs staffs recommendations recommendations in the "scope of program" and "detection of aging effects" program elements elements in GALL AMP in GALL AMP XLM20 .XI.M20.

..Exception.

Exception. In letter L-08-262, L-08-262, Amendment No. 23, dated September September 9, 2008, the applicant applicant identifies the following exception exception to the "Preventive Actions" element:

River Water / Service Service Water Water lines supplying backup backup water sources to the the Auxiliary Feedwater Systems Feedwater Systems and to the Spent Fuel Pools will not be periodically periodically flushed. ItIt is undesirable undesirable to contaminate contaminate the Auxiliary Feedwater Feedwater System and Spent Fuel Pool with raw water, and the configuration configuration of these piping sections sections precludes precludes concerns concerns for silt and sediment buildup. buildup.

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The staff noted that the "preventive actions" program program element in GALL GALL AMP XI,M20 XI.M20 recommends periodic recommends open-cycle CWSs (e.g.,

periodic flushing of open-cycle uncontrolled raw water or SWSs), if (e.g., uncontrolled the systems are infrequently infrequently used.

reviewed the license The staff reviewed license renewal drawings and design renewal drawings design documents documents for the river water and service water systems and noted noted that these systems are normally normally in service service during plant power power operations, plant shutdowns, and operations operations, operations during anticipated operational operational transients.

Based on its review, the staffstaff finds the applicant's recommendation in GALL applicant's exception to the recommendation AMP XI.M20 acceptable because:

XI,M20 acceptable because: (a) the applicant has explained that periodic periodic flushing of the the backup backup river water and service water supply lines to the AFW and SFP systems from the river water and SWSs within the Open-Cycle Open-Cycle Cooling Water Program Program would contaminate the the aforementioned systems, due to their design aforementioned configurations; (b) the river water design configurations; water and service service water systems are generally generally in service, and the design flows in these systems will minimize minimize thethe occurrence of silting and sediment occurrence sediment in the systems during plant operations; (c) the applicant applicant implements the addition of biocides to the raw water in order to preclude preclude biological organisms organisms from from growing growing in these raw waterwater systems and; (d) (d) the applicant implements the remaining recommendations of GL 89-13 recommendations 89-13 for these systems.

The staff further finds that the applicant's applicant's program elements elements provide an acceptable acceptable basis for managing managing loss of material, loss of heat transfer function and cracking cracking in the systems containing containing uncontrolled uncontrolled raw water because because the staff has verified that, with the exception taken taken on performing periodic flushing of the systems, the program elements for the AMP are consistent performing consistent with the program element criteria recommended criteria recommended in GALL AMP XI.M20.

XI,M20. The staff staff also finds that the applicant applicant has provided a valid basis for concluding concluding that the recommendation recommendation for periodic periodic flushing of the systems in GALL AMP XI,M20 XI.M20 need not be implemented.

implemented. Therefore, Therefore, the staff staff concludes that the applicant's enhancements of the Open-Cycle applicant's enhancements Open-Cycle Cooling Water Water Program to include the Unit 1 post-accident sampling include exchanger (PAS-E-1) sampling system heat exchanger (PAS-E-1) within the scope of the AMP and update of the program to describe describe that the internal internal condition condition of buried piping will be assessed assessed by opportunistic opportunistic inspections of header header piping internals, internals, during removal activities for expansion joints and inline raw water header valves, are acceptable acceptable because because the enhancements enhancements will make the program elements for this AMP consistent with GALL AMP XI.M20. XI,M20.

Operatingq Experience. In LRA AMP B.2.32, the applicant Operating applicant provided the following following operating operating experience evaluation for BVPS:

experience Microbiologically influenced Microbiologically influenced corrosion (MIC)(MIC) and macro-fouling macro-fouling have occurred occurred on occasion at BVPS within the River and Service Service Water Water systems and other heat exchangers which reject heat directly exchangers directly to the river. Those Those systems using water water from the Ohio River as a heat sink are collectively collectively referred to as the Open Cycle Cycle Cooling Water (OCCW) system.

MIC can result in pipe and component wall thinning, which if left unchecked, unchecked, can cause failure of the affected affected component. Macro-fouling Macro-fouling and MIC also produceproduce silting, which can lead to a decrease decrease in system flow and a subsequent reduction in heat removal. The OCCW program is designed designed for timely identification identification of the the macro-fouling which will allow corrective actions, such as symptoms of MIC and macro-fouling as component replacement, to be taken.

cleaning, chemical addition, or component 3-79

Quality Assurance audits of of the OCCW and river river water chemistry control control programs evaluate the BVPS compliance with NRC guidance (Generic programs (Generic Letter 89-

13) for MIC and macro-fouling control within OCCW system components. The most recent audit was completed in December December of 2004, the result result of which revealed that BVPS satisfies staff and industry guidelines for OCCW system macro-fouling. However, areas for chemistry control and regulation of MIC and macro-fouling.

improvement were identified and documented documented within the Corrective Corrective Action Program. The auditaudit showed that a sufficient number of parameters are measured to detect measured detect abnormal conditions which could be indicative of MIC, MIC, macro-fouling, or silting. Biocide concentrations were maintained macro-fouling, maintained within specified bands, and associated systems were found to be treated and controlled to acceptable levels consistent with industry and NRC NRC guidelines. Adherence Adherence to specifications and regular monitoring recommended chemistry specifications monitoring of key system system flow parameters parameters provide reasonable reasonable assurance that the OCCW program will manage loss of material and reduction of heat transfer for in-scope effectively manage in-scope OCCW components.

The OCCW system program at BVPS satisfies GL 89-13 commitments commitments for managing managing aging effects due to biofouling, biofouling, corrosion, protective protective coating failures, and silting within system components. In October, 2004, an NRC audit was was conducted on the implementation implementation of Generic Letter, GL 89-13. The audit did not reveal any findings, however, suggested improvements were identified to further suggested improvements strengthen the OCCW system program. program. For example, a recommendation recommendation was made made to increase inspection and cleaning frequencies increase the inspection frequencies of OCCW system components components which would allow the program program to sooner identify a component in in the early early stages of material loss. The recommended recommended improvement, improvement, to modify the the monitoring program administrative monitoring program administrative procedure, was documenteddocumented within the the Corrective Corrective Action Program and incorporated incorporated into the program.

program.

Performance Testing of River/Service Thermal Performance River/Service water cooled heat exchangers, a Generic Generic Letter 89-13 requirement, also provides valuable data on the internal condition of OCCW components. The 2005 Ultimate Heat Sink Biennial Inspection, Inspection, which which included included evaluation evaluation of the Thermal Performance Performance Testing

program, program, was completed December with no findings. As part of this completed in December this inspection, BVPS inspection, BVPS completed three three thermal performance tests on River/Service thermal performance River/Service Water cooled exchangers. Specifically, cooled heat exchangers. Specifically, the Unit 1 andand Unit Unit 2 charging charging pumppump lube oil coolers and Unit 1 diesel generator jacket diesel generator jacket water cooler cooler were were evaluated.

All heat exchanger exchanger thermal thermal performance performance test results were satisfactory.

An important element of OCCW system program evaluation evaluation is benchmarking benchmarking trips to other facilities facilities to assess comparable systems comparable systems and learnlearn from and apply actions which may be applicable applicable to BVPS. Such Such aa trip was taken taken to the North North Anna Anna Station in 2002, which which was documented documented in in the Corrective Action Program.

Program.

Valuable examples of operating Valuable examples operating experience experience were identified and evaluated were identified evaluated forfor applicability applicability at BVPS usingusing the the Corrective Corrective Action Program.

Program. Specific Specific examples examples include include use of more accurate flow measuring more accurate measuring instrumentation instrumentation to assess assess performance changes performance changes within the River/Service the River/Service Water systems, and aa program program in which which large-bore large-bore pipes and and heat heat exchanger exchanger end bells bells are hydro-lazed hydro-lazed and and lined lined with an an epoxy resin.

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Program audits, thermal performance performance testing, and benchmarking benchmarking other facilities facilities provide reasonable assurance assurance that the OCCW program will effectively effectively manage manage loss of material and reduction of heat transfer transfer for in-scope OCCW components.

The staff reviewed the operating experience provided by the applicant in the LRA and experience provided interviewed interviewed the applicant's applicant's technical personnel personnel to confirm that the plant-specific plant-specific operating operating experience did not reveal any aging effects not bounded bounded by the GALL Report. The staff noted that the applicant's Open-Cycle Open-Cycle Cooling Water Program is periodically periodically evaluated enhanced evaluated and enhanced to include include industry experience and plant-specific industry experience plant-specific experience. The staff confirmsconfirms that the the applicant has evaluated evaluated applicable industry and plant-specific applicable aging effects and industry plant-specific operating operating experience experience and has addressed the generic generic and plant-specific plant-specific operating experience experience related to raw water water system fouling. The staff further confirms that the applicant is implementing implementing its commitments in response to GL 89-13 and the generic commitments generic operating experience experience discussed discussed therein.

Based on its assessment, the staff finds that the applicant's Open-Cycle Cooling Water System Based Program Program has been effective and will continue to be effective in monitoring, been effective monitoring, controlling, and correcting correcting the aging effects of components within the scope of this program program because the the applicant incorporates applicant incorporates the results of relevant operating experience into the scope of AMP and and adjusts the program elements elements in accordance accordance with this operating experience, and because because the the applicant implemented and will continue to implement applicant has implemented implement its commitments commitments made in response response to GL 89-13, during the period of extended operation.

extended operation.

UFSAR UFSAR Supplement. In LRA Section A.1.32, the applicant applicant provided provided the UFSAR supplement for the Open-Cycle Cooling Water System Program. The staff reviewed reviewed this Section and determines determines that the information information provided provided by the applicant in the UFSAR Supplement is an UFSAR Supplement adequate summary description adequate description of the program, program, as required by 10 CFR 54.21 (d).

54.21(d).

The staff confirms that the applicant has provided the program changes changes in letter L-08-262, Amendment Amendment No. 23, dated SeptemberSeptember 8, 2008, which includesincludes the addition of the new enhancements to LRA Table A.4-1 (Commitment enhancements (Commitment No. 30 for Unit 1) and LRA Table A.5-1 (Commitment (Commitment No. 31 for Unit 2).

Conclusion.

Conclusion. The staff finds the applicant's applicant's Open-Cycle Open-Cycle Cooling Water Water System System Program acceptable acceptable because because it is consistent with the GALL Report Report and the plant is bounded by the the conditions conditions set forth in the GALL ReportReport for this AMP. Based on its review, the staff finds that the the Open-Cycle Open-Cycle Cooling Water System System Program Program will adequately adequately manage manage the aging effects so that the intended intended functions will be maintained maintained consistent with the CLB for the period period of extended extended operation, operation, as required by 10 CFR 54.21(a)(3).

54.21(a)(3). The staff also reviewed the UFSAR supplement supplement for this AMP and finds that it provides adequate summary description provides an adequate description of the program, as as required by 10 CFR 54.21(d).

3.0.3.1.20 3.0.3.1.20 PWR Vessel Vessel Internals Program Summary of Technical Information Summary Information in the Application. In LRA Section B.2.33, the applicant applicant described the PWR Vessel Internals described Internals Program Program as a new condition monitoring monitoring program program designed designed to manage the effects of effects agingaging in RV internals components for the Units 1 and 2.

Staff Evaluation. The staff noted that the GALL Report does not have a recommended recommended AMP (other than perhaps perhaps the WaterWater Chemistry Chemistry Program Program or the ASME Section or.the Section XI, 3-81

Subsection IWB, IWC, and IWD Program) for the management management of postulated aging aging effects that potentially occur in the RV internals may potentially PWR-designed reactors. Instead, internals of PWR-designed Instead, the staff has has provided the following statement in the AMP program columns of AMRs in GALL provided GALL Report Tables IV.B2, IV.B3, and IV.B4 plant-specific activities IV.B4 that credit plant-specific activities for management management of RV internals internals components components for PWRs:

No further aging management review is necessary aging management necessary ifif the applicant provides provides a commitment commitment in the UFSAR supplement supplement to (1) participate in the industry programs programs for investigating investigating and managing managing aging effects on reactor internals; (2) evaluate (2) evaluate and implement the results of the industry programs as applicableapplicable to the reactor internals; and (3) upon completion of these programs, programs, but not less than 24 24 months before extended operation, submit an inspection before entering the period of extended plan for reactor internals internals to the NRC for review and approval.

This approach to aging management management conforms conforms to the staff's staffs recommended aging management guidelines guidelines provided in the following sections of the SRP-LR:

Section 3.1.2.2.6 - Loss of Fracture Toughness due to Neutron Irradaition Embrittlement

. Section 3.1.2.2.6 - Loss of Fracture Toughness due to Neutron Irradaition Embrittlement and Void Swelling Swelling

• Section 3.1.2.2.9 - Loss of Preload Preload due to Stress Relaxation Relaxation

• Section 3.1.2.2.12 - Cracking Cracking due to Stress Corrosion Irradiation-Assisted Corrosion Cracking and Irradiation-Assisted Stress Corrosion Corrosion Cracking (IASCC)

Cracking (IASCC) .

• Section 3.1.2.2.15 - Changes Changes in Dimensions due to Void SwellingSwelling

• Section 3.1.2.2.17 - Cracking Cracking due to Stress Corrosion toStress Corrosion Cracking, Primary Water Stress Stress Corrosion Cracking, and Irradiation-Assisted Corrosion Irradiation-Assisted Stress Corrosion Corrosion Cracking Cracking (IASCC)

(IASCC) examination categories ASME Code The following examination Code Section XI, Table IWB-2500-1 ,"Examination IWB-2500-1,"Examination Categories," also maymay be applicable as condition monitoring monitoring programs for RV internals internals components in PWRs, dependant applicant's RV design dependant upon whether an applicant's design includes includes these type of internal component internal component commodity groups, and an applicant applicant has included these examination examination categories within the scope of its PWR Vessel Internals Program categories Program or its ASME SectionSection XI, Subsection IWB, IWC, and IWD Program:

Subsection

• B-N Interior of the Reactor Vessel

• B-N Integrally Welded Core Support Structures Structures and Interior Attachments Attachments to Reactor Reactor Vessel B-N Removable Removable Core Support Structures Support Structures The applicant's PWR Vessel Internals Program Program is the AMP that incorporates incorporates the commitment commitment recommended in the GALL Report recommended Report Table IV.B2 IV.B2 for the majority majority of the RV internals components internals components in Westinghouse Westinghouse designed designed PWRs. The staff reviewed the information that the applicant applicant provided in the LRA Section B.2.33, the applicant's license license renewal basis document document for this AMP, and other supporting information and documents supporting information documents that pertain to the applicant's applicant's procedural and implementation controls for this AMP.

implementation The staff reviewed reviewed this information against against the regulatory criteria criteria summarized summarized above.

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The staff noted that in LRA Table 3.1.2-2, the applicant applicant credits its PWR Vessel Internals Internals Program Program as the basis for managing managing applicable aging effects effects for a significant number number of RV internals component internals component commodity commodity groupsgroups at Units 1 and 2. The staff also noted applicant noted that the applicant has committed committed (Commitment (Commitment No. 18 in LRA Table LRA Table AA-1 A.4-1 for Unit 1 and Commitment Commitment No. 20 in LRA Table A.5-1 for Unit 2) 2) to implementing the following following actions and activities for the RV internals internals that are managed in accordance accordance with its PWR Vessel Internals Internals Program:

Commitment No. 18 for Unit 1:

Commitment For the PWR Vessel Internals Internals Program, regarding activities for managing the the aging of Reactor Vessel internal internal components components and structures, BVPS commits to:

1. Participate in the industry programs applicable to BVPS Unit 1 for programs applicable investigating and managing aging effects investigating effects on reactor reactor internals; 2. Evaluate Evaluate and implement the results of the industry programsprograms as applicable to the BVPS Unit 1 reactor internals; internals; and, 3. Upon completion of these programs, but not less than 24 months months before entering the period of extendedextended operation, submit an inspection plan for the BVPS Unit 1 reactor internals internals to the NRC for review and approval.

Commitment Commitment No. 20 for Unit 2:

For the PWR PWR Vessel Internals Program, regarding regarding activities for managing managing thethe aging of ReactorVessel Reactor Vessel internal components and structures, BVPS commits to:

1. Participate Participate in the industry programs applicable applicable to BVPS Unit 2 for investigating investigating and managing managing aging effects on reactor internals; internals; 2. Evaluate and implement implement the results of the industry programs as applicable applicable to the BVPS Unit 2 reactor internals; internals; and, 3. Upon completion of these programs, but not less than 24 months before before entering the period of extended extended operation, operation, submit submit an inspection inspection plan for the BVPS Unit 2 reactor internals to the NRC for review and approval.

approval.

The staff verified that the provisions provisions in Commitments Commitments No. 18 for Unit 1 and No. 20 for Unit 2 conform to the commitment recommendations discussed above. The staff also verified commitment criteria recommendations that in LRA Table Table A.4-1, A.4-1, the applicant applicant has scheduled scheduled to implement Commitment Commitment No. 18 for 29, 2014, and Commitment No. 20 for Unit 2, by May 27, Unit 1 by January 29,2014, 2025. The operating 27,2025. operating license for Unit 1 will expire January 29, 2016, according to Operating License No. DPR-66, expire on January Clause 2.F. The operating operating license for Unit 2 will expire expire on May 27,2027, 27, 2027, according according to Operating Operating License No. NPF-73, Clause NPF-73, Clause 2.1. Based on this information, information, the staff also verified that the the applicant's implementation milestones for these commitments applicant's implementation commitments conform with the staffs staff's recommendation that licensee's submit inspection plans for the RV internals for staff review and recommendation approval approval at least two at least two years years prior prior to entering the to entering the period period of extended extended operation.

Although the staff verified that the applicant's applicant's commitments for aging management management of its RV internals were consistent with the guidance guidance in the SRP-LR and the GALL Report, the staff staff determined determined that additional additional information was required to complete its review, specifically noting noting discrepancies remained between that discrepancies between the AMR items for these components components and the applicant's applicant's commitments to ensure commitments adequate aging management ensure adequate management of the components. The staff further noted that the applicant's applicant's PWR Vessel Internals Internals Program does not have have aa specific specific 3-83 3-83

corresponding program corresponding program in the GALLGALL Report Volume Volume 2, Chapter Chapter XI and that if if the applicant applicant intended on tying the basis for aging management intended management to its PWR PWR Vessel Internals Internals Program, then the AMP should be defined plant-specific in the LRA.

defined as plant-specific In RAI B.2.33-1, B.2.33-1, dated JuneJune 5, 2008, the staff requested that the applicantapplicant justify why the PWR PWR Vessel Vessel Internals Program had not been identified as a plant-specific a plant-specific AMP in the LRA and the the program elements program elements for this AMP omitted from the application.

application.

In its response to RAI B.2.33-1, B.2.33-1, dated July 21, 21, 2008, the applicant applicant stated that the intent of LRA Section Section B.2.33 B.2.33 was not to define an AMP with 10 elements. The applicant confirmed confirmed that the the intent of LRA Section B.2.33 B.2.33 was to identify a commitment, as specified in the GALL Report Report and stated that the commitment wording commitment wording was included in LRA Appendix B as a a pointer and for ease of review. The applicant clarified clarified the issue and revised LRA Sections A.1.33 and B.2.33 B.2.33 to delete the misleading misleading text, further stating that other sections of the LRA are also revised to delete references references to the AMP, and to include include references references to the commitments commitments (Commitment (Commitment No. 18 18 and Commitment Commitment No. 20) provided in LRA Tables Tables A.4-1 (Unit (Unit 1) A.5-1 (Unit (Unit 2),

respectively. The staff reviewed the applicant's applicant's response and verified that the applicant applicant has has amended amended the LRA as noted above. The staff noted that the amendments amendments are consistent consistent with with Westinghouse-designed Westinghouse-designed RV internals internals components found in the GALL Report, Table IV.B2.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.33-1 acceptable because because amended the AMRs on management the applicant has amended management of cracking, loss of fracture fracture toughness, changes changes in dimension, and loss of preload of the RV internals components components for Units 1 and 2 to be consistent with their corresponding AMRs in the GALL Report, Table IV.B2. The staff further finds that the applicant (Commitments No. 18 and No. 20) to develop applicant has committed (Commitments develop a plant-specific plant-specific PWR Vessel Internals Monitoring AMP that will implement activities from industry investigations (including operating experience), as applicable investigations (including managing aging applicable to BVPS, for managing effects on reactor internals, prior to the period of extended extended operation. Therefore, the staff's staff's concern concern described in RAI B.2.33-1 is resolved.

The staff also noted that in the GALL Report, Table IV.B2, the staff recommends that the type of commitment commitment discussed discussed in the Staff Evaluation Evaluation be credited for aging management management of the RV internals in Westinghouse-designed Westinghouse-designed PWRs. The staff reviewed the technical technical and regulatory information in the applicant's applicant's PWR Vessel InternalsInternals Program. The staff noted that although the the applicant applicant had provided provided the appropriate appropriate commitment (Commitments (Commitments No. 18 in LRA Table A.4-1 for Unit 1 and No. 20 in LRA Table A.5-1 for Unit 2) 2) for its RV internals components, components, the the applicant applicant did not identify identify which RV internals internals components commodity at Units 1 and 2 were were within the scope of the PWR Vessel Internals Program Program and the regulatory regulatory commitments.

In RAI B.2.33-2, dated June June 5, 2008, the staff requested requested that the applicant applicant clarify clarify which PWR PWR internals components RV internals components at Units 1 and 2 are within the scope of the PWR Vessel Internals Internals Program and LRA Commitments No. 18 for Unit 1 and No. 20 for Unit 2.

In its response to RAI B.2.33-2, dated July 21, 21, 2008, the applicant stated that, consistent consistent with its response response to RAI-B.2.33-1, RAI-B.2.33-1, it has amended amended LRA B.2.33 and A.1.33 to delete the misleading misleading text.

Additionally, the applicant applicant has updated AMR AMR items in LRA Table Table 3.1.2-2 to delete the reference reference to the PWR Vessel Internals Program, in favor of references references to its commitments commitments provided for the the components components in LRA Tables Tables A.4-1 and A.5-1 (Commitments No. 18 18 for Unit 1, and No. 20 for for Unit 2).

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managed in the AMRs by these commitments components now managed The applicant clarified that the components commitments are as follows:

• baffle/former assembly Core baffle/former plates assembly bolts and plates

• Core barrel shells, rings, flanges, nozzles, and thermal shields and pads pads

" Core barrel assembly assembly bolts bolts

" Instrumentation Instrumentation support support structure structure flux thimble guide tubes and thermocouple thermocouple conduits conduits

• Lower Lower internals internals assembly assembly clevis inserts inserts and clevis insert bolts insert bolts

• Lower Lower internals internals assembly assembly core support support forgings and lower support columns columns

• Lower Lower internals assembly assembly lower core plates, support alignment pins, support column bolts, fuel alignment keys radial keys

• • Lower Lower internals assembly secondary secondary core supports, head/vessel head/vessel alignment pins, and head cooling spray nozzles nozzles

" Lower internals assembly assembly Unit 1 diffuser plate and Unit 1 lower lower support column casting

• RCCA guide tube assembly bolts, guide guide tubes and support pins pins

• internals assembly core plate alignment pins, fuel alignment Upper internals alignment pins, hold-down hold-down springs, support support column mixer mixer bases, and support support columns columns

• internals assembly Upper internals assembly upper core plates, upper upper support plates, support assemblies assemblies and support column bolts The staff noted noted that list of components components above is consistent consistent with the list of components in GALL IV.B2, for which these types of commitments Report, Table IV.B2, commitments are credited credited for aging management.

Based on its review, the staff finds the applicant's response response to RAI B.2.33-2 B.2.33-2 acceptable acceptable because because the applicant applicant has appropriately appropriately identified identified the RV internals components components that are within the scopescope of Commitment Commitment No. 18 for Unit 1 and Commitment Commitment No. 20 for Unit 2, and because the because the applicant's applicant's list of components components is consistent consistent with those in the GALLGALL Report, Table IV.B2, IV.B2, for which which these commitments commitments are credited.

credited. Therefore, the staffs staff's concern B.2.33-2 concern described in RAI B.2.33-2 is resolved.

In RAI B.2.33-3, dated dated June June 5, 2008, the staff requested that the applicant applicant clarify whether whether or not the examination examination requirements requirements in ASME Code Section XI, Examination Examination Categories Categories B-N-1, B-N-i, B-N-2, or B-N-3 are applicable applicable to the RV internals components components at Units 1 and 2 and ifif so, whether the whether the applicant applicant is crediting the applicable examination requirements for aging management examination category requirements management either either under the ASME Section XI, Xl, Subsection IWB, IWB, IWB, and IWD Program or the PWR Vessel Internals Program.

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In In its response B.2.33-3, dated response to RAI B.2.33-3, dated July July 21, 2008, the applicant 21,2008, identified the following ISIs applicant identified ISis of of internals at Units 1 and 2, as the RV internals as required required by 10 10 CFR 50.55a 50.55a andand the the ASME ASME Code Section XI:

Code XI:

" Inspections Inspections of the interior interior of the reactor vessels vessels (RVs) Examination Category (RVs) -- Examination Category B-N-1 B-N-1

" Inspections Inspections of the integrally integrally welded welded core core support support structures structures andand interior interior attachments attachments to Examination Category the RV - Examination B-N-2 Category B-N-2

• Inspections Inspections of removable removable core core support support structures Examination Category structures Examination Category B-N-3 B-N-3 The The applicant clarified that the applicant clarified the inspections performed under inspections performed under these examination categories are examination categories are scheduled scheduled and performed in and performed in accordance accordance with with the ASME ASME Boiler Boiler and Pressure Vessel and Pressure Vessel Code,Section XI, Table Table IWB-2500-1, IWB-2500-1, under under the BVPS ASME Section XI, Inservice Inservice Inspection Inspection Program, limitations and modifications Program, subject to the limitations modifications of 10 10 CFR 50.55a. The applicant applicant stated recommendations in the GALL that, consistent with the recommendations IV.1B2-26 and IV.B2-34, GALL Report, Items IV.B2-26 IV.B2-34, only three AMRs AMRs for RV internals components in LRA Table 3.1.2-2 credit the ASME internals components ASME Code Code Section XI, Inservice Inspection, XI, Inservice Subsections IWB, Inspection, Subsections IWB, IWC, and IWD ProgramProgram (LRA Section B.2.2) for aging management. The applicant further clarified internals clarified that the RV internals components within the scope of these components these ASME inspections are ASME Section XI inspections are the clevis inserts, core core plate alignment alignment pins, and located in the RV lower and radial keys, located internal assembly. The applicant lower internal applicant inservice inspections stated that inservice inspections for these components implemented as part of the components are implemented the applicant's AMSE applicant's AMSE Section XI Inservice Subsection IWB, IWC, and IWD Program.

Inspection, Subsection Inservice Inspection, Program.

The applicant applicant also clarified that the inservice inspections inspections of these components are not within the the scope of the commitments for the RV internals because because the commitments commitments covercover the augmented augmented inspection activities that will be implemented for the RV internals, which go beyond inspection beyond the inservice inservice inspections inspections required by the ASME Code Section XI examination categories. categories.

The staff noted that the applicant's applicant's commitments (Commitments No. 18 in LRA Table A.4-1 commitments (Commitments AA-1 for Unit 1 and No. 20 in LRA LRA Table A.5-1 for Unit 2) for the RV internals internals pertain to the development development of an augmented augmented inspection inspection for the RV internals. These commitments are based on industry internals. These initiatives initiatives of the EPRI MRP task group on RV internals component degradation and goes component degradation inservice inspections pursuant to ASME Code Section XI, beyond the required inservice beyond Examination XI, Examination Categories B-N-1, Categories B-N-i, B-N-2, and B-N-3.

Based on its review, the staff finds the applicant's response to RAI B.2.33-3 acceptable because because the applicant has clarified that the required ASME Code Section XI inservice inspections for the the applicable to the clevis inserts, core plate alignment RV internals are applicable alignment pins, and radial keys located located in the RV lower internal assembly and that these ISis internal assembly ISIs are implemented implemented as part of the the applicant's AMSE Code Section XI Inservice applicant's Inservice Inspection, Subsection IWB, IWC, and IWD IWD Program. Therefore, the staff's concern concern described in RAI B.2.33-3 is resolved.

staffs review, and the applicant's Based on the staff's RAIs B.2.33-1, applicant's resolution of RAls staff B.2.33-1, -2, and -3, the staff commitments (Commitments No.

applicant's commitments concludes that the applicant's No. 18 for Unit 1 and No. No. 20 for.

for management because acceptable for aging management Unit 2) are acceptable because these commitments conform to the the staff's commitment criteria specified in the GALL Report, Volume 2, Table IV.B2. Additionally, the staff concludes that the applicant's implementation commitments implementation schedule for these commitments recommendation that the applicant submit inspection plans conforms to the staff's commitment recommendation plans 3-86

for the RV internals to the staff for review and approval at least two years prior to entering the entering the extended operation.

period of extended Since the staff has accepted accepted the applicant's basis for deleting this AMP from the LRA, the staff staff finds that there is no reason to performperform a program element evaluation of the PWR Vessel Internals Program Internals Program that was originally docketed docketed in the LRA.

Operatingq Experience. The applicant's PWR Vessel Internals Operating Internals Program is a new program that will be implemented implemented at least two years prior to entering entering the period of extended extended operation.

operation. As As such, there is no relevant operating operating experience, to date, because the AMP has yet to be be implemented.

implemented. In SRP-LR Section A.1.2.310, A.1.2.31 OJ Item Item 2, the staff states that an "applicant may have have to commit to providing providing operating operating experience in the future for new programs programs to confirm their their effectiveness."

In RAI B.2-1, B.2-1, dated May May 22, 2008, the staff requested 22,2008, requested that the applicant make a commitment commitment for the new programs in order to bring these AMPs into conformance conformance with the guidance guidance for new AMPs found in staff's "operating experience" criterion in SRP-LR Section A.1.2.310. A.1.2.31 O.

In its response to RAI B.2-1, B.2-1, dated August 22, 2008, the applicant applicant clarified that the existing license renewal future commitment commitment for each management program made each new aging management made by FENOC FENOC in LRA, Appendix A, Table A.4-1 (Unit 1) and Table A.5-1 (Unit (Unit 2), as applicable, meets meets the the intent of the recommendation recommendation of SRP-LR SRP-LR Section A. 1.2.3.10.2.

A.1.2.3.1 0.2. The applicant further clarified clarified that, for each new program credited by FENOC FENOC for aging management management during the period of extended extended operation, a a license renewal renewal future commitment commitment is included included to implement the program prior to the period of extended operation, as described described in the corresponding corresponding Section of LRA Appendix Appendix B, and that the "operating experience" program element for each new program includes aa statement that relevant industry plant-specific operating industry and plant-specific operating experience experience will be be incorporated into the program.

incorporated The applicant also clarified clarified that aa license renewal renewal commitment to consider consider and incorporate incorporate feedback feedback from operating experience operating experience into new new AMPs is included in LRA Tables A.4-1 (Unit 1)

(Unit and Table A.5-1 (Unit(Unit 2). Also, the applicant applicant clarified clarified that the FENOC Corrective Action Program Program is relied upon to document document any operating operating experience that indicates a lack lack of program effectiveness effectiveness and to initiate corrective corrective actions such that recurrence recurrence of significant conditions conditions is prevented. The applicant applicant clarified that the Corrective Corrective Action Program Program activities are applicable applicable to programs following implementation. However, to confirm the effectiveness all programs effectiveness of the new license license renewal AMPs based on the incorporation incorporation of operating operating experience, experience, the applicant applicant amended amended the the LRA for BVPS to include a new license license renewal future commitment commitment to complete complete aa program program self-assessment of all new license self-assessment license renewal AMPs within five years years after entering the period of extended operation.

operation. The staff verified that the applicant incorporated this commitment applicant has incorporated commitment for programs in its August 22, 2008, response to staff.

new programs Based on its review, the staff finds the applicant's applicant's response to RAI B.2-1 acceptable acceptable because because the applicant applicant has: (a) committed to develop develop an inspection plan and program program for these internal components and to submitsubmit them for staff review and approval at least two years prior to entering entering the period of extended operation; (b) (b) committed to implement implement this program during the period of extended operation; and (c) placed extended placed a commitment commitment on the program program to incorporate incorporate the lessons lessons learned from any relevant relevant operating experience experience that results from the inspections of the RV 3-87 3-87

internals components internals components for Units Units 1 and 2. Therefore, the staff's concern concern described described in in RAI B.2-1 is resolved.

UFSAR UFSAR Supplement. The applicant applicant provided a UFSAR UFSAR supplement supplement of its PWR Vessel Internals Internals Program in LRA Section Section A.1.33. The staff verified that the applicant has provided acceptable provided an acceptable summary description of commitments summary description commitments that have been credited credited for aging management management of the RV internals for Units 1 and 2.

These These commitments commitments have have been identified in the Staff Evaluation section. The staff also verified verified that the applicant applicant has included the commitments commitments (Commitments (Commitments No. 18 18 and No.20) in LRA Tables Tables A.4-1 and A.5-1 for Unit 1 and Unit 2, respectively.

In RAI B.2-1, B.2-1, the staff requested that the applicant commit in the LRA to provide future experience for new AMPs in order to confirm their effectiveness operating experience effectiveness and to bring the the applicant's "operating experience" program elementelement for new AMPs into conformance conformance with the the "operating experience" program element criterion in SRP-LR Section A. 1.2.310, Item 2. This "operating experience" program element criterion in SRP-LR A.1.2.31 0, This RAI is relevant relevant to the staffs approval approval of the applicant's UFSAR UFSAR supplement for the PWR Vessel Internals Internals Program Program because this is aa new program that has not been approved approved by the staff and implemented at the BVPS facility.

In RAI B.2.33-2, the staff requested that the applicant applicant clarify which PWR RV internalsinternals components components at UnitsUnits 1 and 2 are within the scope of the applicant's PWR Internals Internals Program and LRA Commitments Commitments No. 18 for Unit 1 and No. 20 for Unit 2. This RAI is relevant relevant to the staffs staffs approval of the applicant's UFSAR UFSAR supplement supplement for the PWR Vessel Internals Internals Program Program because because the staff's approval of this program program depends on the RV internals components components that the applicant applicant has identified as being within the scope scope of program.

As discussed in the Staff Evaluation Evaluation Section above, the staff determined determined that the applicant has applicant has provided an acceptable acceptable basis for resolving RAlsRAIs B.2-1 and B.2.33-2 because the applicant has applicant has identified those RV internals components components within the scope of Commitment Commitment No. 18 (LRA Table Table A.4-1 for Unit 1) and Commitment No. 20 (LRA Table A.5-1 for Unit 2) and has amended the LRA to include include aa commitment commitment that after the plan and program has been developed, developed, approved by the staff, and implemented, implemented, the applicant will incorporate incorporate any lessons learned from from the relevant operating experience resulting from the inspections relevant operating inspections of the RV internals components components at Units 1 and 2.

Based on its review, the staff finds that the UFSAR UFSAR supplement acceptable because supplement is acceptable because itit includes Commitments Commitments No. 18 (LRA Table A.4-1) 18 (LRA AA-1) and No. 20 (LRA (LRA Table A.5-1), and and a new commitment to incorporate incorporate lesson learned from future operating experience operating experience into the RV internals inspection plan. The staff further finds that the applicant's applicant's PWR Internals Inspection Internals Inspection Program will be developed, implemented during the period of developed, approved by the staff, and implemented extended extended operation.

Conclusion. Based on its review of the applicant's applicant's PWR Vessel Internals Internals Program, Program, the staff staff concludes concludes that the applicant applicant has demonstrated demonstrated that effects of aging will be adequately adequately managed so that the intended intended function(s) function( s) will be maintained maintained consistent consistent with the CLB for the period period of extended extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed reviewed the UFSAR supplement supplement for this AMP and concludes concludes that it provides an adequate adequate summary description description of thethe

program, program, as required required by 10 10 CFR 54.21(d).

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3.0.3.1.21 Steam Generator 3.0.3.1.21 Integrity Program Generator Tube Integrity Program Information in the Application.

Summary of Technical Information Summary Application. In LRA Section B.2.38, the applicant described described the existing Steam Steam Generator Integrity Program as consistent with GALL Generator Tube Integrity XI.M19, "Steam Generator AMP XI.M19, Generator Tube fntegrity."

Integrity."

The applicant stated that the Steam Generator Generator Tube Integrity Program is based based on NEI 97-06, "Steam Generator Generator Program Guidelines." The applicant credits the Steam Generator Generator Tube Tube Integrity Integrity Program for aging management management of the tubes, tube plugs, tube supports, and the the secondary-side internal secondary-side internal components failure of which could prevent prevent the SG from performing performing itsits intended intended safety function. The program program has performance performance criteria for assurance assurance of SG tubetube integrity maintenance consistent with the CLB and guides monitoring integrity maintenance monitoring andand tube maintenance maintenance for assurance that performance assurance performance criteria is met at all times between scheduled scheduled tube inspections.

The applicant applicant also stated that the Steam GeneratorGenerator Tube Integrity Program inspectionsinspections detect flaws in tubes, plugs, tube supports, and secondary-side secondary-side internal components needed to maintain assessments detect both potential and actual maintain tube integrity. Degradation assessments actual degradation degradation mechanisms.

mechanisms. ISisISIs (i.e.,

(i.e., eddy current testing, UT, and visual inspections) detect flaws. Condition visual inspections) Condition compares the inspection monitoring compares inspection results against performance criteria, and an operational against performance assessment assessment predicts tube conditions conditions so performance performance criteria criteria will not be exceeded during the during the next operating operating cycle. The program continually monitors continually monitors primary to secondary leakage during during operation.

operation.

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

The staff reviewed those portions of the applicant's applicant's Steam Generator Tube Integrity Integrity Program that the applicant consistency with GALL applicant claimed consistency GALL AMP XI.M19 and found they are consistent with this GALL GALL AMP. The staff also confirmed confirmed that the plant programprogram contains all of the the elements of the referenced referenced GALL program program and the conditions at the plant are bounded by the the conditions for which the GALL Report conditions Report is evaluated.

evaluated. The staff reviewed the applicant's Program Evaluation Document Document and confirmed that the program program scope includes all in-scopein-scope mechanical components components whose failure could prevent the SG from fulfilling its intended intended safety function (i.e.,

tubes, tube plugs, tube supports, and the secondary-side secondary-side internal internal components). The staff staff conducted conducted onsite interviews interviews with the applicant's applicant's technical personnel to confirm confirm these results.

The staff finds the applicant's applicant's Steam Generator Generator Tube Integrity Program acceptable Integrity Program acceptable because because it conforms to the recommended conforms recommended GALL GALL AMP XI.M19.XI.M19.

Operatingq Experience.

Operating Experience. In LRA AMP B.2.38, the applicant provided the following following operating experience evaluation experience evaluation for BVPS:

BVPS Unit 1 steam generators generators (SGs) were replaced replaced during the Unit 1 Cycle 17 Refueling Outage (February Outage (February - April 2006), and the plant achieved achieved full, uprated uprated core thermal power in January of 2007. BVPS Unit 2 continues to operate operate with its original steam generators generators and has partially uprated uprated its core thermal power output.

Unit 2 is expected to achieve its full, full, uprated uprated power power after future plant modifications.

modifications.

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During During each refueling outage, SG degradation degradation assessments assessments are performed performed in in accordance accordance with the provisions of NEI 97-06 and Section Section 5.2 of the EPRI PWRPWR SG examination examination guidelines. These industry guidelines are based in part on operating operating experience experience and and inspection inspection results from other operating operating PWRs.

Incorporation Incorporation of plant and industry operating experience operating experience and use of industry guidance documents guidance documents in the development of an inspection inspection program provide program provide assurance assurance that the SG tube integrity program will continue to effectively manage effectively manage aging effects of these passive components. Results Results of recent degradation degradation assessments performedperformed during the Unit 1 Cycle 16 Refueling Outage (October -

Outage (October-November 2004) and the Unit 2 Cycle 11 Refueling Outage November Outage (April (April 2005) are summarized in SG degradation summarized assessment reports. Topics covered in the degradation assessment the reports include include SG tube degradation mechanisms, inspection degradation mechanisms, inspection & expansion & expansion requirements, tube repair criteria, structural limits, guidelines for testing, and chemical cleaning cleaning provisions. As a result of the Unit Unit 1 Cycle 16 Refueling Refueling Outage Outage inspections at Unit 1, 196 196 SG tubes were plugged. As with all previous previous inspections, the condition condition of the Unit 1 SGs (with the degraded degraded tubes plugged) met industry and regulatory structural structural and leakage integrity guidance, and were expected to meet these criteria criteria following following the outage inspection. The outcome of the Unit 2 Cycle 11 11 Refueling Outage Outage SG inspections inspections necessitated necessitated that 55 tubes tubes be plugged.

plugged. The condition of the three three SGs (with the degraded degraded tubes plugged) met industry industry and regulatory structural and leakage leakage integrity guidance, and the the SGs were expected expected to meet these criteria criteria following the outage inspection.

inspection. TheThe degradation degradation assessments assessments also include discussionsdiscussions of specific specific and recent industry events (Section (Section 4.7 of the Unit 1 Cycle 16 Refueling Refueling Outage report and Section Section 3.7 of the Unit 2 Cycle 11 Refueling Refueling Outage report). For example, example, lessons learned learned from false indications indications of eddy current testing at the Comanche Comanche Peak station resulted in changes to the BVPS bobbin analysis analysis method. At the the Shearon Shearon Harris plant, low level primary-to-secondary leakage primary-to-secondary leakage was determined determined to be caused by foreign object wear just above above the top of the cold leg side of the the tubesheet. The inspection inspection of the affected affected tube during the previous previous outage did not identify identify any flaw, however, subsequent subsequent manual reanalysis reanalysis of the data data suggested that flaw was present when the affected affected tube was tested. The failure to identify the flaw in the affected affected tube was attributed to a "sorting logic" gap that resulted in in Y2 1/2 inch Section of tube which which was not analyzed.

analyzed. The flaw was located within this this unanalyzed unanalyzed 1/2 Y2 inch Section of tube. As a result of this event, BVPS evaluated the the sorting logic to verify that the logic did not contain similar gaps. Using the the accepted accepted industry approach to testing and evaluation, and incorporation industry approach incorporation of pertinent industry industry operating experience, insures that the steam generator generator tube tube program manages the effects integrity program component aging such that the steam effects of component generators generators will continue to perform their intended functions, consistent consistent with the the CLB, during the period period of extended extended operation.

The staff reviewed reviewed the applicant's applicant's operating operating experience experience provided provided in the LRA and interviewed interviewed the the applicant's applicant's technical personnel personnel to confirm that the plant-specific plant-specific operating experience experience did not reveal any aging effects not bounded by the GALL Report. The staff also confirmed that applicable applicable aging effects and industry and plant-specificplant-specific operating experience experience have been evaluated incorporated into the Steam Generator Tube Integrity evaluated and incorporated Integrity Program Program for BVPS. The The applicant applicant used an example example of industry industry operating experience experience to alter the BVPS Program that that 3-90

included changing changing the bobbin analysis method due to false indications indications experienced experienced at Comanche Comanche Peak.

The staff noted that the applicant's applicant's program program is implemented implemented through plant-specific plant-specific procedures procedures that have requirements requirements for assessing tube integrity. The assessment assessment activities activities include periodic periodic verification verification of SG tubing, tube sleeve and tube plug integrity by volumetric volumetric and visual examination methods examination methods and secondary secondary side components. The staff also noted that the the requirements for SG inspection scope, frequency, and acceptance acceptance criteria for plugging plugging and and repair of flawed tubes are specified specified in BVPS Technical Technical Specifications.

Additionally, the applicant's applicant's program procedures procedures specify specify requirements requirements for water chemistry, control of foreign material, industry assessment, self assessment, and required material, industry reporting (i.e.,

required reporting secondary side internals degradation).

GL 97-06 for secondary degradation).

In accordance accordance with technical technical specifications, specifications, the program program procedures procedures detect flaws in tubing, plugs, and sleeves, or degradation degradation of secondary secondary side internals. The applicant's program utilizes applicant's program utilizes industry established nondestructive examination industry established nondestructive examination techniques techniques to identify tubes that are defective defective and need to be removed removed from service or repaired. requirements are established repaired. These requirements established by BVPS BVPS technical specifications.

technical specifications. The applicant's applicant's program program provides provides reasonable assurance that SG tube reasonable assurance tube integrity is maintained maintained consistent consistent with the plant's licensing basis for extended operation operation because because itit requires requires assessments degradation that occurred assessments of degradation occurred between between RFOs and that reports of the the assessment assessment results are incorporated incorporated into plant and industry experience documents.

industry experience documents.

The topics covered by the reports include SG tube degradation mechanisms, inspection and expansion requirements, tube repair criteria, structural limits, guidelines for testing, and expansion chemical chemical cleaning cleaning provisions.

Based on its review, the staff finds that the applicant's Generator Tube Integrity Program applicant's Steam Generator Program effective in monitoring, has been effective monitoring, detecting flaws, and implementing implementing repairs to correct the aging components within the scope of this program such that they will continue effects of components continue to perform their intended intended functions consistent with the CLB for the period of extended consistent extended operation.

UFSAR Supplement. In LRA Section Section AA1.38, 1.38, the applicant applicant provided the UFSARUFSAR supplement for the Steam Generator Generator Tube Integrity Program.

Program. The staff reviewed this Section Section and determines determines that the information in the UFSAR UFSAR supplement supplement provides provides an adequate adequate summary summary description of the program, program, as required required by 1010 CFR 54.21(d), and is consistent with the guidance guidance provided provided inin the SRP-LR SRP-LR Table 3.1-2.

Conclusion. The staff reviewed the information information provided provided by the applicant in LRA Section B.2.38.

Based on its review, the staff finds the applicant's Steam Steam Generator Generator Tube Integrity Integrity Program Program acceptable because itit is consistent acceptable because consistent with the GALL ReportReport and and the plant is bounded by the the conditions conditions set forth in the GALL Report for this AMP. The staff finds that the program will adequately manage adequately manage the aging effects so that the intended functions will be maintained consistent consistent with the CLB for the period period of extended operation, operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR UFSAR supplement supplement for this AMPAMP and finds that itit provides an adequate summary adequate summary description of the program, required by 10 CFR 54.21(d).

as required 3-91

3.0.3.1.22 Thermal Aging and Neutron 3.0.3.1.22 Irradiation Embrittlement Neutron Irradiation Embrittlement of Cast Austenitic Stainless Austenitic Stainless Steel (CASS) Program Summary Summary of Technical Information in the Application. In LRA Section B.2.40, the applicant Technical Information applicant described the Thermal described Thermal Aging and Neutron Neutron Irradiation Embrittlement of Cast Austenitic StainlessStainless Steel (CASS) Program Program as a new monitoring monitoring program program designed designed to manage reduction of (loss of) fracture toughness in CASS RV internals components.

components. The applicant stated that the program program elements elements for this AMP are consistent consistent with the program element criteria recommended recommended in GALL AMP XI. 13, "Thermal Aging and Neutron Irradiation XL13, Irradiation Embrittlement Embrittlement of Cast Austenitic Stainless Stainless Steel (CASS)," without exception exception or enhancement.

Staff Staff Evaluation. The staffs aging management management recommendations recommendations and programprogram element criteria element criteria for Thermal Thermal Aging and Neutron Irradiation Irradiation Embrittlement Embrittlement of of Cast Austenitic Austenitic Stainless Steel (CASS) Programs Programs are documented documented in GALL GALL AMP XI.M13.XLM13. In the GALL Report, the staff staff established established its position supplemental flaw tolerance position that a supplemental tolerance assessment, volumetric volumetric examination techniques, techniques, or enhanced enhanced VT-1 visual inspection techniques techniques should be credited credited to manage manage reduction of fracture toughness toughness duedue to thermal thermal aging aging embrittlement embrittlement or neutron irradiation embrittlement embrittlement in CASS RV internals components.

guidance (NRC letter dated May 19, 2000) provides additional Further staff guidance additional criteria for establishing establishing whether a particular material is susceptible particular CASS material susceptible to thermal aging embrittlement embrittlement and describes describes aging management management strategies for these materials. The guidance guidance found in GALL AMP XI.M13, references the additional criteria and aging management XLM13, references management strategies strategies documented documented in the May May 19, 19, 2000 NRC letter.

The staff reviewed reviewed the applicant's applicant's information provided in LRA Section B.2.40 and supporting supporting BVPS~specific documents, against the regulatory criteria discussed above.

BVPS-specific The staff noted that the applicant's applicant's program elements for this AMP were consistent with the the element criteria program element criteria recommended recommended in GALL AMP XLM13, XI.M13, with one exception.

exception. The staff staff determined that additional determined information was required additional information required to complete complete its review.

In RAls B.2.40-1 and B.2.41-1, B.2.41-1, dated June 5, 2008, the staff requested that the applicant clarify whether whether the current state-of-the-art UT techniques are capable of detecting either surface state-of-the-art surface penetrating cracks or subsurface cracks in CASS RV internals penetrating components and whether these internals components these UT examination examination methods methods have have been been qualified for CASS materials.

In its response to RAIs RAls B.2.40-1 and B.2.41-1, B.2.41-1, dated July 21, 21, 2008, the applicant stated that it is amending the LRA to delete delete LRA AMP B.2.40 "Thermal Aging and Neutron Irradiation Irradiation Embrittlement Embrittlement of Cast Austenitic Stainless Steel (CASS)," and UFSAR supplement UFSAR supplement Section A.1.40, A. 1.40, "Thermal Aging and Neutron Neutron Irradiation Embrittlement Embrittlement of Cast Austenitic Austenitic Stainless Steel (CASS) Program." The applicant also stated that it is amending LRA Table Table 3.1.2-2 that referred to the Thermal Thermal Aging and Neutron Irradiation Embrittlement Neutron Irradiation Embrittlement of Cast Austenitic Austenitic Stainless Steel (CASS) ProgramProgram to change the AMP for RV internals internals components.

components.

The applicant will instead credit the commitments commitments (Commitments (Commitments No. 18 and 20 in UFSAR UFSAR Supplement Supplement Tables A.4-1 and A.5-1 for Units 1 and 2, respectively) for managing managing cracking, loss cracking, loss of preload, changes in dimension and loss of fracture toughness in the RV internals internals 3-92 3-92

components, as its basis for aging management. The applicant made the following following commitments to manage the aging effects in the RV internals commitments internals components:

Regarding activities for managing Regarding managing the aging of Reactor Vessel internal components and structures, BVPS commits to:

(1) Participate in the industry programs Participate programs applicable to BVPS for investigating investigating managing aging and managing aging effects effects on reactor internals; (2) Evaluate and implement Evaluate implement the results of the industry programs programs as as applicable to the BVPS reactor internals; applicable internals; and, (3)

(3) Upon Upon completion of these programs, but not less than 24 months months before before entering entering the period period of extended extended operation, submit an inspection inspection plan for the BVPS reactor internals to the NRC for review and approval.

The staff verified verified that the applicant applicant has amended amended the LRA to include a commitment commitment to managemanage the aging effects in the RV internals internals components. The staff's evaluation evaluation and basis for accepting applicant's commitments the applicant's commitments for managing managing loss of fracture toughness of CASS RV internals internals components resulting from neutron neutron irradiation embrittlement embrittlement and thermal thermal aging is found in SER 3.1.2.1.2 and 3.0.3.3.3. In these SER sections, the staff provides Sections 3.1.2.1.2 provides the basis for for concluding that the applicant's applicant's commitment for its RV internals components components is an acceptable acceptable managing the aging effects means of managing effects attributed to these components. The staff noted that the the applicant's commitment is consistent applicant's commitment consistent with the recommended recommended AMRs Westinghouse-designed AMRs for Westinghouse-designed RV internals components documented internals components documented in GALL Report, Table IV.B2, IV.B2, which recommends recommends that these types of commitments commitments to manage the aging effects be placed in the LRA.

Based Based on this review, the staff staff finds the applicant's RAIs B.2.40-1 and B.2.41-1 applicant's response to RAls B.2.41-1 acceptable because acceptable because the applicant has committed (Commitments No. 18 and No. 20 in UFSAR UFSAR Supplement TablesTables A.4-1 and A.5.1 for Units 1 and 2, respectively) to manage manage cracking, cracking, loss of preload, changes in dimension and loss of fracture toughness toughness in the RV internals components, as its basis for aging management.

management. The staff further finds that the applicant's applicant's commitment conforms conforms to the staff's aging management management basis provided in provided the GALL Report, Table IV.B2.

described in RAls Therefore, the staff's concern described B.2.40-1 and B.2.41-1 are resolved.

RAIs B.2.40-1 The staff also noted that the applicant's program elements for the Thermal program elements Thermal Aging and NeutronNeutron Irradiation Embrittlement Irradiation Embrittlement of Cast Austenitic Austenitic Stainless Stainless Steel (CASS) Program Program indicate indicate that the the applicant applicant may use the industry-wide industry-wide initiatives of the EPRI MRP on PWR RV internals internals components, components, as an alternative basis basis for managing managing reduction of fracture toughness toughness of the CASS CASS internals components.

RV internals components. The staff noted noted that the applicant's basis for using the EPRI MRP's MRP's flaw evaluation and inspection inspection guidelines guidelines is provided provided through the PWR Vessel InternalsInternals includes Commitment Program, which includes Commitment No.18No.18 in UFSAR UFSAR Supplement Supplement Table A.4-1 for Unit 1 and Commitment Commitment No. 20 for UFSAR Supplement Supplement Table A.5-1 for Unit 2.

In RAI B.2.40-2, dated June 5, 2008, the staff requested crediting requested that the applicant confirm its crediting of the industry initiatives of EPRI MPR as an alternative for managing reduction of fracture fracture toughness in the CASS RV internals internals components components and ifif so, amend the Thermal Thermal Aging and Neutron Irradiation Embrittlement Neutron Irradiation Embrittlement of Cast Austenitic Stainless Stainless Steel (CASS) Program and its (CASS) Program associated UFSAR associated UFSAR supplement, to state that management toughness management of reduction of fracture toughness 3-93 3-93

managed through the will be managed the PWR PWR Vessel Internals Internals Program and the LRA LRA Commitments No. No. 18 and No.

and No. 20.

its response to RAI B.2.40-2, dated July 21, In its 21, 2008, the applicant amended amended the LRA LRA to delete delete the Thermal Aging and Neutron Irradiation Irradiation Embrittlement Embrittlement of Cast Austenitic Stainless Stainless Steel (CASS) Program and UFSAR Supplement Section A.1.40. A. 1.40. The applicant applicant also amended LRA Table 3.1.2-2 (i.e.,(i.e., the management management of loss of fracture toughness of the Unit Unit 1 CASS RV RV internals lower internals lower support casting and the Units1 Unitsl and 2 RV internals CASS CASS upper internals internals assembly support column mixers) mixers) to delete the reference to the Thermal Aging and Neutron Neutron Embrittlement of Cast Austenitic Irradiation Embrittlement Austenitic Stainless Steel (CASS) Program (AMP B.2.40). B.2.40).

The applicant will credit LRA Commitments Commitments No.18 and No. No. 20 for RV internals components for Units 11 and 2, respectively, to manage loss of fracture that may occur in these components components resulting from either thermal aging or neutron irradiation irradiation embrittlement.

The staff verified that the applicant has amended amended the LRA to include a commitment to manage manage the aging effects in the RV internalsinternals components. The staff's staffs evaluation and basis for accepting the applicant's commitments for managing loss of fracture toughness of CASS RV internals internals components resulting from neutron irradiation irradiation embrittlement and thermal aging is found in SER Sections 3.1.2.1.2 and 3.0.3.1.20. In these SER sections, the staff provides the basis for for concluding that the applicant's commitment for its RV internals components is an acceptable acceptable means managing the aging effects attributed to these components~

means of managing components. The staff noted that the the applicant's commitment is consistent with the recommended applicant's recommended AMRs for Westinghouse-designed Westinghouse-designed internals components documented RV internals documented in GALL Report, Table Table IV.B2, which recommends that these types of commitments commitments to manage the aging effects be placed in the LRA.

Based on its review, the staff finds that the applicant's applicant's response response to RAI B.2.40-2 acceptable acceptable because the applicant has provided acceptable basis for deleting provided an acceptable deleting the Thermal Aging and Irradiation Embrittlement Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program Austenitic Stainless Program and UFSAR Supplement Supplement Section A.1.40 A.1.40 from the scope of the LRA, and has committed

. (Commitments No. 18 and No. 20 for Units 1 and 2, respectively) to manage loss of fracture fracture toughness toughness in the CASS RV internals internals components.

components. The staff further finds that the applicant'sapplicant's commitments conform to the staff's commitments staffs aging aging management management basis provided provided in the GALL Report, Table Table IV.B2.

IV.B2. Therefore, Therefore, the staffs staff's concern concern described described in RAI B.2.40-2 B.2.40-2 is resolved.

resolved.

Since the staff has accepted accepted the applicant's applicant's basis basis for deleting this AMPAMP from the LRA, the staff staff finds that there there is no reason to perform perform a program program element element evaluation evaluation of the Thermal Thermal Aging Aging and Neutron Irradiation Neutron Irradiation Embrittlement Embrittlement of Cast Austenitic Austenitic Stainless Steel (CASS) Program Program that was was originally originally docketed docketed in the LRA.

Operatingq Experience. In the "operating experience" program Operating program element for this AMP, the the applicant indicated that the Thermal applicant indicated Thermal Aging and Neutron Neutron Irradiation Embrittlement of Cast Irradiation Embrittlement Cast Austenitic Austenitic Stainless Stainless Steel Steel (CASS)

(CASS) Program Program is aa new program for which there new program there is no operating operating experience experience to confirm its its effectiveness effectiveness in in managing managing reduction reduction ofof fracture fracture toughness toughness in in the the CASS CASS RV internals internals components.

components. The applicant applicant also indicated that industry-specific indicated that industry-specific and plant-specific plant-specific operating operating experience experience will be be considered considered in in the the development development and implementation implementation of of Thermal Aging Aging and and Neutron Neutron Irradiation Irradiation Embrittlement Embrittlement of of Cast Austenitic Austenitic Stainless Stainless Steel (CASS)

(CASS) Program, Program, and that that as additional operating experience is operating experience is obtained, obtained, lessons lessons learned learned will will be incorporated incorporated into the program.

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The staffs basis for evaluating evaluating potential operating operating experience experience that may result from the initiation initiation implementation of new AMPs is found in SRP-LR Section A.1.2.310, Item 2, which states, and implementation "An applicant may have have to commit to providing providing operating operating experience experience in the future for new programs to confirm their effectiveness."

programs effectiveness."

In RAI B.2-1, In B.2-1, dated dated May 22, 2008, the staff requested May 22,2008, requested that the applicant applicant make such a commitment in the LRA for the new new programs, including the PWR Vessel Internals Internals Program, in order to bring these AMPs in conformance conformance with the staff's staffs "operating experience" criterioncriterion inin SRP-LR SRP-LR Section A.1.2.3.10, A.1.2.3.1 0, Item Item 2. Therefore, Therefore, RAI B.2-1 is applicable applicable to the "operating experience" program program element review for this AMP.

Industry operating experience Industry experience regarding regarding reduction of fracture toughness of CASS RV internals internals components components is currently currently being compiled and assessed through the industry-wide industry-wide initiatives of the EPRI MRP task group group on PWR-designed PWR-designed RV internals internals components. The EPRI MRP MRP initiatives on RV internals component degradation include material property component degradation property studies on CASS CASS materials used in the fabrication of PWR RV internals internals components. The staff noted that in the the program elements for this AMP, the applicant applicant indicates that itit maymay apply the industry-wide industry-wide initiatives of the EPRI MRP on PWR RV internals components as an alternative alternative basis for managing reduction managing reduction of fracture fracture toughness in the CASS RV internals internals components at Units 1 and 2. Since operating operating experience experience on fracture toughness properties of CASS RV internals internals materials is being compiled and assessed assessed through the initiatives initiatives of the EPRI MRP, the staff staff determined determined that additional information was required required to complete its review.

In RAI B.2.40-2, dated June 5, 2008, the staff requested requested that the applicant applicant confirm whether whether itit was crediting crediting the industry initiatives of the EPRI MPR as an alternative alternative for managing reduction of fracture toughness in the CASS RV internals internals components components in the Thermal Aging and Neutron Neutron Irradiation Embrittlement Irradiation Embrittlement of Cast Cast Austenitic Stainless Stainless Steel (CASS)

(CASS) Program Program and ifif so, whether the associated associated UFSARUFSAR Supplement Supplement would be amended to state that reduction of fracture toughness toughness will be managed through the PWR Vessel Internals Internals Program Program and the applicant's applicant's LRA commitments (Commitments commitments (Commitments No. 18 for Unit 1 and No. 20 BVPS Unit 2).

In its responses to RAI B.2-1,B.2-1, dated May 22, 2008 and RAI B.2.40-2, dated July 21, 21, 2008, the the applicant amended applicant amended the LRA to delete the ThermalThermal Aging and Neutron IrradiationIrradiation Embrittlement Embrittlement of Cast Austenitic Austenitic Stainless Steel (CASS) Program and the UFSAR Supplement (CASS) Program Supplement for this this AMP (i.e.

(i.e. LRA UFSAR Supplement Supplement Section A.1.40). The applicant also amended LRA Table 3.1.2-2, concerning management management of loss of fracture fracture toughness of the Unit 1 CASS RV internals lower support internals lower support casting and the Units 1 and 2 RV internals CASS upper internals internals assembly support column column mixers, to delete the reference to the Thermal Aging and Neutron Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program Irradiation Embrittlement Program (AMP B.2.40).

Instead, Instead, the applicant applicant credits LRA Commitment No.18 for Unit 1 RV internals internals components and LRA Commitment Commitment No. 20 for Unit 2 RV internals components to manage manage loss of fracture fracture that may occur in these components components resulting from eithereither thermal aging or neutron neutron irradiation irradiation embrittlement.

The staff verified that the applicant has amendedamended LRA. Based on its review of the applicant's applicant's responses to RAls RAIs B.2-1 and B.2.40-2, the staff concludes that the applicant need not provide a commitment on the operating operating experience experience for the Thermal Aging and Neutron Irradiation Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program Embrittlement because the applicant Program because applicant has has 3-95

amended the LRA to delete amended delete this program program and the associated UFSAR supplement supplement from the the scope of the LRA for BVPS. The staff finds the applicant's applicant's alternative alternative basis to manage loss of fracture toughness toughness in the Unit 1 CASS RV internals internals lower support casting and the Units Units 1 and 2 RV internals CASS upper internals internals assembly assembly support support column mixers acceptable because itit acceptable because conforms to the staffsstaff's recommended commitment-based aging management recommended commitment-based management basis for Westinghouse Westinghouse RV internals components, as provided in the GALL Report, Table IV.B2.

Therefore, the staff's staffs concerns described in RAIs RAls B.2-1 and B.2.40-2 B.2.40-2 are resolved.

UFSAR Supplement. The applicant provided provided its UFSAR supplement for the Thermal Thermal Aging Aging and Neutron Irradiation Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS) Program in LRA Irradiation Embrittlement Section Section A. 1.40.

A.1.40.

The staff noted the applicant applicant responses to RAIs RAls B.2-1, B.2.40-1, B.2.41-1, B.2-1, B.2.40-1, B.2.41-1, and B.2.40-2 B.2.40-2 in which the applicant amendedamended the LRA to delete the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program Embrittlement Program and the associated associated UFSAR UFSAR supplement supplement for this AMP (i.e. (i.e. UFSAR Supplement Section A.1.40) from the scope of license license renewal. The applicant applicant also amended LRA Table 3.1.2-2, concerning the management management of loss of fracture toughness of the Unit 1 CASS RV internals internals lower support casting and the Units 1 and 2 internals CASS upper internals RV internals internals assembly support support column mixers, to delete the reference to the Thermal Aging and Neutron Irradiation Embrittlement Neutron Irradiation Embrittlement of Cast Austenitic Steel Austenitic Stainless Steel (CASS) Program.

Program. Instead, Instead, the applicant credits LRA Commitments Commitments No.18 for Unit Unit 1 RV internals internals components components and No. 20 for Unit 2 RV internals components to manage loss of fracture that may occur in these components, resulting from either thermal irradiation thermal aging or neutron irradiation embrittlement. The staff verified that the applicant amended amended the LRA and that the applicableapplicable commitments commitments for the RV internals components are provided in Commitment No. 18 in UFSAR UFSAR Supplement Supplement Table A.4-1 (Unit (Unit 1) and Commitment Commitment No. 20 of UFSAR Supplement Supplement Table A.5-1 (Unit (Unit 2).

Based on its review, the staff concludes that the LRA need not include a UFSAR UFSAR supplement supplement for the Thermal Aging and Neutron Irradiation Embrittlement Neutron Irradiation Embrittlement of Cast Austenitic Steel Austenitic Stainless Steel (CASS) Program (CASS) Program because because the applicant applicant has deleted deleted this AMP from the scope scope of the LRA. The The staff verified that the LRA and UFSAR supplement supplement includes the appropriate appropriate commitments commitments for the Unit 1 and Unit 22 RV internalsinternals components components credited credited with aging management. The staff finds finds that the applicant's applicant's basis for managing managing loss of fracture toughness in the Unit 1 CASS RV internals internals lower lower support casting and the Units 1 and 2 RV internals internals CASS upper internals internals assembly support column acceptable because the applicant's commitments column mixers acceptable commitments are credited with management management of this aging effect and because because it conforms to staff's aging management management recommendations recommendations for Westinghouse-design Westinghouse-design RV internals components, components, as provided in the GALL Report, Table IV.B2.IV.B2. Therefore, the staff's concerns described described in RAlsRAIs B.2-1, B.2.40-1, B.2.41-B.2-1, B.2.40-1, B.2.41-1, and B.2.40-2 B.2.40-2 are resolved.

Conclusion.

Conclusion. BasedBased on its review, the staff concludes that the applicant applicant has provided an acceptable alternative acceptable alternative basis in Commitment Commitment No. 18 in UFSAR Supplement Supplement Table A.4-1 (Unit (Unit 1) and Commitment No. 20 of UFSAR Supplement Table A.5-1 (Unit 2) to manage ofUFSAR manage to manage loss loss of fracture toughness toughness in the Unit 1 CASS RV internals internals lower support support casting and the Units 1 internals CASS upper internals assembly and 2 RV internals assembly support support column mixers. The staff also concludes that the applicant demonstrated that effects of aging applicant has demonstrated aging will be adequately managed so that the intended intended function(s) function(s) will be maintained maintained consistent with the CLB for the period of extended operation, as required extended required by 10 10 CFR 54.21 54.21(a)(3).

(a)(3). The staff also reviewed the UFSAR UFSAR 3-96 3-96

determines that itit need not include a UFSAR supplement and determines supplement Supplement summary description UFSAR Supplement because the applicant has deleted the Thermal Aging and Neutron Irradiation Embrittlement Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program and associated UFSAR UFSAR supplement supplement for thisthis AMP from the scope of the license renewal. The staff confirms that the applicant will rely on on Commitment No. 18 in UFSAR UFSAR Supplement Table A.4-1 (Unit 1) and Commitment Commitment No. 20 of Supplement Table A.5-1 (Unit 2) to manage UFSAR Supplement manage loss of fracture toughness in the Unit 1 CASS RV internals internals lower lower support casting and the Units 1 and 2 RV internals CASS upper upper internals assembly support column mixers.

3.0.3.1.23 Thermal Aging Embrittlement Embrittlement of Cast Austenitic Stainless Steel (CASS) Program Program Summary of Technical Information Information in the Application.

Application. In LRA Section B.2.41,B.2.41, the applicant described the Thermal Thermal Aging Embritllement Embrittlement of Cast Austenitic Stainless Stainless Steel (CASS) Program Program as a new monitoring program asa program designed designed to manage manage reduction of (loss of) fracture toughness in CASS components components in the RCPB. This new program will not manage manage CASS RV internals, which are managed managed by the Thermal Aging and Neutron Neutron Irradiation Irradiation Embrittlement Embritllement of Cast Austenitic Austenitic Stainless Steel (CASS) Program.

Program. The applicant applicant stated stated that the program program elements elements for this new AMP are consistent with the program element criteria recommended recommended in GALL AMP XI.12, Xl.12, "Thermal Aging Embrittlement Embrittlement of Cast Austenitic Stainless Stainless Steel (CASS)," without exception or enhancement.

Staff Evaluation.

Evaluation. The staffs staff's aging management recommendations aging management recommendations and program element criteria criteria for Thermal Aging and Neutron Irradation Embrittlement Neutron Irradation Embritllement of Cast Austenitic Stainless Steel Austenitic Stainless Programs are found in GALL AMP XI.M12. Guidance (CASS) Programs Guidance in the GALL Report Report establishes establishes the criteria for determining determining whether aa supplemental assessment or volumetric or supplemental flaw tolerance assessment enhanced VT-1 visual inspection techniques enhanced techniques should be credited to manage manage reduction reduction of fracture toughness due to thermal aging embrittlement due thermal aging embrittlement or neutron neutron irradiation embritllement in CASS irradiation embrittlement CASS RCS piping, piping components, or piping elements (including (including CASS valve bodes and CASS CASS pump casings).

guidance found in the The guidance the NRC's letter of May May 19, 2000 provides provides additional additional criteria for determining whether a particular determining particular CASS material is susceptible susceptible to thermal aging embrittlement embrittlement and describes aging management management strategies strategies for these materials.

materials. The guidance in GALL AMP XI.M12, references the additional guidelinesguidelines found in the May 19, 2000 NRC letter.

The staff reviewed the information in LRA Section Section B.2.41, B.2.41, Thermal Aging Embritllement Embrittlement of Cast Austenitic Stainless Stainless Steel (CASS) Program, and supporting supporting BVPS-specific BVPS-specific documents, documents, against recommended program elements the staff's recommended elements in GALL GALL AMP XI.M12.XI.M12. The list of BVPS documents documents that were reviewed reviewed by the staff in its audit of March 3-7, 2008 and that support this AMP are provided in the Audit Summary Summary dated November 6, 2008. The list of supporting documents documents reviewed by the staff includes the applicant's applicant's program evaluation document program evaluation document for this AMP.

The staff noted noted that the program program elements for this AMP, as given given in the applicant's applicant's program document for this AMP, were evaluation document were consistent consistent with the program program element criteria element criteria recommended in GALL AMP XI.M12, "Thermal Aging Embrittlement recommended Embrittlement of Cast Austenitic Stainless Austenitic Stainless Steel (CASS)." Based on this review review staff finds that the applicant's applicant's aging management management basis basis and program program elements for the Thermal Thermal Aging Embrittlement of Cast Austenitic Stainless Stainless Steel Program are acceptable because acceptable because they are consistent with the staff's recommended recommended aging 3-97

management management basis and program program element element that are defined in GALL AMP XI.M1, XI.M1, "Thermal

'Thermal Aging Aging Embrittlement of Cast Austenitic Embritllement Austenitic Stainless Steel (CASS)."

Operating Operating Experience.

Experience. In the "operating experience" program element element for this AMP, thethe applicant applicant indicated that AMP B.2.41, B.2.41, Thermal Aging Embritllement Embrittlement of Cast Austenitic Stainless Austenitic Stainless Steel (CASS) Program Thermal program program is a new program program for the BVPS facility, and that as as such, there is no OE yet to confirm the effectiveness effectiveness of the AMP in managing reduction of managing reduction fracture toughness in the CASS RCPB components. In its "operating experience" program element, the applicant also indicated indicated that industry-specific industry-specific and plant-specific plant-specific OE will be considered in the development considered development and implementation implementation of this AMP, and that as additional OE is obtained, lessons learned will be appropriately incorporated into the program.

appropriately incorporated program.

The staff's basis for evaluating evaluating potential operating experience that may result from the initiation operating experience initiation and implementation of new AMPs is provided provided in SRP-LR SRP-LR Section A.1.2.310, A.1.2.31 0, Item 2, which states:

An applicant may have to commit to providing operating experience providing operating experience in the future future for new programs to confirm their effectiveness.

effectiveness.

In RAI B.2-1 dated May 22, 2008, the staff requested 22,2008, requested that the applicant make make such a commitment for the new programs in the LRA in order to bring these AMPs in conformance conformance with with the staff's "operating experience" criterion in SRP-LR Branch Position RLSB-1, RLSB-1, A.1.2.310, Section A.1.2.31 0, Item 2. Therefore, Therefore, RAI B.2-1 on a commitment for new program is thus thus applicable to the OE program applicable program element element review for this AMP.

In response response to RAI B.2.-1 dated 22, 2008, the applicant responded to RAI B.2-1, dated August 22,2008, relative B.2-1, relative B.2.41, "Thermal Aging Embrittlement to B.2.41, Embrittlement of Cast Austenitic Austenitic Stainless Steel (CASS) Program."

the applicant stated the following:

"For potentially potentially susceptible materials materials that are part of the reactor coolant pressure coolant pressure boundary, this program program will consist of either either volumetric volumetric examination of the base metal component-specific flaw tolerance or a component-specific tolerance evaluation.

evaluation. Potentially Potentially susceptible components susceptible components that are not part of the reactor boundary will be inspected, reactor coolant pressure boundary inspected, evaluated, or replaced as appropriate.

appropriate. BVPS will determine determine required inspections on a case by case basis.

To date, there has been no BVPS plant-specific plant-specific operating operating experience experience regarding degradation degradation of austenitic austenitic stainless steel castings due to thermal aging. The The Aging Management Management Program NUREG-1801,Section XI.M12 was Program described in NUREG-1801, was developed developed by using research data obtained laboratory-aged and service-aged obtained on both laboratory-aged service-aged materials.

The BVPS LRA states states that, "Industry plant-specific operating "Industry and plant-specific experience will be operating experience be evaluated evaluated in the development development and implementation implementation of this program. As additional operating experience operating experience is obtained, lessonslessons learned will be appropriately appropriately incorporated incorporated into the program."

The staff noted that in this response the applicant applicant stated that any operating operating experience thatthat results from implementation implementation of this AMP will be evaluated and lesson learned learned incorporated incorporated into 3-98

the AMP. The staff verified that, in the enclosure enclosure to the letter of August 22, 2008, the applicant 22,2008, applicant placed Commitment No. 29 on UFSAR Supplement Supplement Table A.4-1 for Unit 1 and Commitment No.

28 in UFSAR UFSAR Supplement Supplement Table A.5-1 for Unit to address address the need for evaluating operating experience experience that results from the applicant's implementation implementation of new programs programs during the period of extended extended operation. The staff verified that in these commitments, the applicant committed to applicant committed to effectiveness of the license confirming "the effectiveness license renewal aging management management programs programs based on the the incorporation of operating incorporation operating experience experience by performing performing a program program self assessment of all new license renewal license renewal aging management management programs."

The staff noted incorporation of these commitments into the UFSAR Supplement noted that incorporation Supplement for the the application application addresses the staffs recommendation recommendation in SRP-LR Section A.1.2.3.1 A.1.2.3.10, 0, part b. and the the need for the applicant to reassess relevant operating applicant reassess relevant operating experience experience on the program element element activities activities for the applicant's applicant's new programs relative to the SRP-LR recommendations.

recommendations.

RAI B.2-1 is resolved resolved with respect to the need for reassessing reassessing AMP B.2.41, B.2A1, Thermal Aging Embrittlement of Cast Austenitic Austenitic Stainless Steel (CASS) Program Program for relevant operating operating experience experience during the period of extended operation.

extended operation.

UFSAR Supplement. The applicant provides provides its UFSAR Supplement Supplement for its Thermal Thermal Aging Embrittlement of Cast Austenitic Embrittlement Austenitic Stainless Steel (CASS) Program Section A.

Program in LRA Section 1.41. The A.1A1. The staff verified verified that UFSAR Supplement Supplement summary description Embrittlement description for the Thermal Aging Embrittlement of Cast Austenitic Stainless Stainless Steel (CASS) Program conformance with the staff's Program was in conformance staff's recommended recommended UFSAR UFSAR Supplement summary description description for these type of AMPs in Table 3.1-2 Table 3.1-2 of the SRP-LR.

The staff also noted that the applicant committed to the implementation implementation of this AMP during the during the period of extended operation extended operation in Commitment No. 22 of UFSAR Supplement Table A.4-1 for for Commitment No. 24 of UFSAR Supplement Unit 1 and Commitment Supplement Table A.5-1 for Unit 2. The staff also verified verified that the applicant has has amended amended the LRA to incorporate incorporate No. 29 of UFSAR Supplement UFSAR Supplement Table A.4-1 for Unit 1 and Commitment Commitment No. 28 of UFSAR Supplement Supplement Table A.5-1 for Unit 2 onto the scope of the LRA and to commit to confirming the effectiveness effectiveness of the Thermal Aging Aging Embrittlement Austenitic Stainless Steel (CASS)

Embrittlement of Cast Austenitic Program by incorporating (CASS) Program incorporating of any relevant relevant operating operating experience experience on the program element element activities activities for the AMP and by performing performing programmatic self assessment a programmatic assessment of the AMP to ensure ensure that its program element element activities will be be capable capable of achieving achieving the intended aging management management objectives objectives that are defined SRP-LR defined in SRP-LR Section Section A.1.2.3. Based Based on this review, the staff finds that the UFSAR UFSAR Supplement for the the Thermal Thermal Aging Embrittlement Embrittlement of Cast Austenitic Austenitic Stainless Stainless Steel (CASS) Program because because itit is in conformance conformance with the recommended recommended UFSAR Supplement Supplement summary description for these type type of AMPs in SRP-LR SRP-LR Table 3.1-2 and because the UFSAR UFSAR Supplement Commitment Supplement includes Commitment No. 22 and 29 of UFSARSupplement UFSAR Supplement Table A.4-1 AA-1 for Unit 1 and Commitment No. 24 and 28 of UFSAR Supplement UFSAR Supplement Table A.5-1 for Unit 2.

Conclusion. Based on its review of the applicant's applicant's Thermal Thermal Aging Embrittlement Embrittlement of Cast Austenitic Stainless Steel (CASS) Program, the staff concludes concludes that the applicant has has demonstrated that effects of aging will be adequately managed demonstrated managed so that the intended function(s) will be maintained maintained consistent consistent with the CLB for the period of extendedextended operation, operation, as required required by 10 CFR 54.21(a)(3). The staff also reviewedreviewed the UFSAR UFSAR supplement supplement for this AMP and concludes that itit provides an adequate adequate summary summary description description of the program, program, as required by by 10 CFR 54.21(d).

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3.0.3.2 3.0.3.2 AMPs Consistent Consistentwith the GALL GALL Report with Exceptions Exceptions or Enhancements Enhancements In LRA LRA Appendix Appendix B, the applicant applicant stated that the following AMPs are, or will be, consistent with the GALL Report, with exceptions exceptions or enhancements:

enhancements:

• ASME Code Section XI Inservice Inservice Inspection, Subsections Subsections IWB, IWC, and IWD Program

• ASME Code Code Section XI, Subsection IWE IWE Program

• ASME Code Code Section XI, Subsection IWF Program

• Closed-Cycle Cooling Water System Program Closed-Cycle

• Fire Protection Protection Program

• Fire Water System Program Program

• Flux Thimble Tube Inspection Inspection Program Program

• Fuel Oil Chemistry Chemistry Program

• Inspection of Overhead Overhead Heavy Load and Light Load (Related to Refueling)

Refueling) Handling Handling Systems Program Systems Program

• Masonry Wall Program

• Reactor Head Head Closure Studs Program Program

• Structures Structures Monitoring Program Monitoring Program

• Water Chemistry Program Program For AMPs that the applicant claimed are consistent with the GALL Report, with exception(s) exception(s) and/or enhancement(s), the staff performed an audit and review review to confirm that those attributes attributes or features of the program, program, for which the applicant claimed claimed consistency consistency with the GALL GALL Report, were indeed indeed consistent. The staff also reviewed the exception(s) and/or enhancement(s) enhancement(s) to thethe determine whether GALL Report to determine whether they were were acceptable acceptable and adequate. The results of thethe staff's audits and reviews are documented documented in the following sections.

3.0.3.2.1 3.0.3.2.1 ASME Code Section XI Inservice Inspection, Xllnservice Inspection, Subsections IWB, IWC, and IWD IWD Program Summary of Technical Information Information in the Application.

Application. In LRA Section B.2.2, the applicant applicant described described the ASME ASME Code Section XI Inservice Inspection, Subsections Subsections IWB, IWC, *IWD IWD Program as an existing condition monitoring monitoring program designed designed to manage manage the effects of aging in Class 1, 2, and 3 pressure retaining components, including associated associated welds, pump casings, valve bodies, integral attachments, attachments, and pressure pressure retaining bolting. The applicant stated the the ASME Code Section XI Inservice Inservice Inspection, Subsections IWB, IWC, IWD Program Program is updated periodically pursuant to 10 CFR 5055a and is consistent with the program element criteria criteria recommended recommended in GALL AMP XI.M1, XI.M1, "ASME Code Section XI Inservice Inspection, Inspection, Subsections Subsections IWB, IWC, and IWD," with an exception.

Exception. The applicant stated that this AMP includes includes the following exception exception to the "scope of program," "parameters monitored monitored or inspected,"

inspected," "detection of aging effects," "monitoring and 3-100

"acceptance criteria," and "corrective actions" trending," "acceptance actions" program element criteria recommended in GALL AMP XI.M1: XI.M1:

NUREG-1801, ,Section NUREG-1801 Section XI.M1, XI.M1, ASME Code Section Section XI In Inservice Inspection, service Inspection, Subsections IWB, IWC, Subsections IWC, and and IWD specifies specifies the use of ASME Code Section XI, 2001 edition through 2002 and 2003 Addenda. The applicable ASME Code for the third (Unit 1 only) and second (Unit (Unit 2 only) intervals intervals of the BVPS ASME ASME Inservice Inspection, Subsections Code Section XI Inservice Subsections IWB, IWB, IWC, and IWD Program is ASME Code Section XI, 1989 edition (with no Addenda). The use of the 1989 edition of the ASME Code is consistent with provisions in 10 CFR 50.55a to use the Code in in effect 1212 months prior prior to the start of the inspection interval.

BVPS will use the ASME Code edition consistent with the provisions of BVPS 10 CFR 50.55a during the period of extended extended operation.

The applicant also provided a summary summary of the lSI ISI results for examinations examinations performed during the the last RFOs for Units 1 and 2 and of the latest BVPS-implemented BVPS-implemented quality assurance assurance audits and staff inspection conducted on the ASME Code Section XI Inservice Inspection, Subsections Subsections IWB, IWC, IWD Program. The applicant provided technical technical details operating experience details of these operating experience aspects in the "operating experience" program element discussion in LRA Section B.2.2.

Evaluation. The staff's Staff Evaluation. staffs aging management management recommendations recommendations and program element criteria criteria for the ASME Code Section XI Inservice Inspection, Xllnservice Inspection, Subsection Subsection IWB,IWB, IWC and IWD ProgramsPrograms are described described in GALL AMP XI.M1. XI.M1.

requirements found in 10 CFR 50.55a and ASME Code Section XI, Subsections The requirements Subsections IWA, IWB, IWC, and IWC IWC are applicable applicable to the staff's review of the applicant's ASME Code Section XI Inservice Inspection, Subsections Inservice Subsections IWB, IWC, and IWD Program. The requirements requirements of ASME ASME Code Section XI, Subsection ,IWF IWF are applicable ifif an applicant chooses to include ASME ASME Code Class 1, 2, and 3 component component supports within the scope of its ASME Code Section XI Inspection, Subsection Inservice Inspection, Subsection IWB, IWC and IWD Program. Program.

The staff staff reviewed the information information in LRA Section Section B.2.2 against against the regulatory criteria criteria discussed discussed in the Staff Evaluation Evaluation section. With With the exception exception taken on the ASME Code editions this editions for this AMP, the staff verified that the programprogram elements for the applicant's applicant's ASME ASME CodeCode Section Section XI Inservice Inspection, Inservice Inspection, Subsection Subsection IWB, IWC, and and IWD Program Program were consistent consistent with the program program element element criteria recommended recommended in the program elements program elements of GALL AMP XI.M1.

XI.M1. The staff staff concludes concludes that the program program element element aspects of the applicant's applicant's AMP claim of consistency consistency with with the GALL Report Report are acceptable because the staff verified acceptable because verified that these program element these program element criteria criteria are consistent consistent with the corresponding corresponding program program element element criteria recommended in GALL criteria recommended AMP AMP XI.M1.

XI.M1. The staff staff evaluates evaluates the exception exception taken on the ASME ASME Code Section XI edition in the paragraphs that follow the paragraphs follow Assessment Assessment of the Exception Taken the Exception Taken to GALL. GALL GALL AMPAMP XI.M1 XI.M1 recommends recommends that the the inspection, repair, and replacement and replacement of of ASME Code Class Class 1, 2, 2, and 33 components and components are covered covered in the 2001 edition edition ofof the ASME ASME CodeCode Section, Subsections Subsections IWB, IWB, IWC, IWC, and inclusive of and IWD, inclusive the 2002 2002 and 2003 2003 Addenda.

Addenda. The applicant has has taken an an exception exception on the the ASME ASME Code Section Section XI code code edition edition in in that the the applicant applicant identified identified that the the current current ASME ASME 3-101

Code Section Xl XI edition or record for BVPS Units 1 and 2 is the 1989 1989 edition of the ASME ASME Code Section XI, XI, with no applicable applicable addenda addenda and that itit is crediting this edition of the ASME ASME Code Section XI for aging management. This was the ASME Code Section XI Xl edition in in effect for the 33rVrd 10-Year 10-Year ISIlSI Interval for BVPS Unit 1 and the 2 2 nd nd 10-Year 10-Year ISI lSI Interval Interval for BVPS Unit 2.

The staff noted that the applicant had indicated indicated BVPS Unit 1 had entered its 10-Year 44th 10-Year lSI th ISI Interval Interval on April 1, 2008 and that BVPS Unit 2 is scheduled scheduled to enter its 33rdd 10-Year toenter 10-Year lSI ISI Interval for BVPS Unit 2 on August 29,2008. 29, 2008. Under the requirements requirements of 10 CFR 50.55a, the applicant applicant was required to implement the 2001 Edition ASME Code Section XI, inclusive of the 2003 Addenda, upon entrance into the 44th 10-Year ISI th 10-Year lSI Interval for BVPS Unit 1 and will be required to rd implement the 2001 Edition implement Edition of the ASME Code Section XI upon entrance entrance into the 3 3 rd 10-Year 10-Year lSIISI Interval for BVPS Unit 2.

In RAI B.2-2, dated June 5, 2008, the staff requested the applicant clarify which ASME In ASME Code Section XI edition will be credited credited for those AMPs that credit the ASME Code Section Section XI XI criteria for aging management management of ASME Code Class components, structures, or supports.

In its response to RAI B.2-2, dated July 21, In 21, 2008, the applicant applicant clarified clarified the that ASME ASME Code Section XI editions of record credited for ASME Code Section XI Xllnservice Inspection, Inservice Subsections Subsections IWB, IWC, and IWD Program Program for Units 1 and 22 are the ASME Code Section XI, XI, 2001 Edition, inclusive of the 2003 Addenda Addenda pending renewal of the operating operating license for Units 1 and 2 (i.e., the 4th 10-Year and 33rdrd 10-Year 4 th 10-Year 10-Year lSI ISI Intervals Intervals are in in effect for Unit 1 and Unit 2, respectively) respectively) The applicant clarified that updates of the ASME Code Section Section XI editions editions implemented through the 10 CFR 50.55a code update process.

will be implemented In its final statement of considerations In considerations on changes to 10 CFR 50.55a endorsing endorsing new ASME ASME Code Section Xl XI editions, the staff noted that it endorses the editions editions not only for the current operating operating term but also for the period of extended extended operation.

operation. The staff further noted that the the 2004 Edition of the ASME Code Section XI is the most recent edition endorsed for both the the current operating period and the period of extended extended operation operation (refer to Federal Register Register Volume Volume 73, No. 176 [September 10, 10, 2008]).

The staff also noted that the ASME Code Section XI edition credited for aging management management in in the applicant's applicant's response response to RAI B.2-2 was consistent with the ASME Code Section edition that is recommended recommended to for aging management in in GALL AMP XI.M1. XI.M1. The staff finds this edition of the ASME Code Section XI acceptable acceptable because it conforms to the edition recommended it conforms recommended for aging management management in elements in in program elements in GALL AMP XI.M1. XI.M1. The staff further finds this edition edition acceptable acceptable because because the process process to update the edition of record is consistent with the staff's staff's ASME Code Section XI update process pursuant to 10 CFR 50.55a(g)(4)(ii) 50.55a(g)(4)(ii) and the staff's staff's process to approve approve updated editions editions of the ASME Code Section XI for license renewal renewal as provided in in the final statements statements of consideration consideration on updates updates to 10 CFR 50.55a ISI lSI requirements.

Therefore, the staffs concern described described in in RAI B.2-2 is resolved.

clarification that ASME Code Section Based on the clarification Section XI edition of record for aging management management is is the 2001 Edition of the ASME Code Section XI, inclusive of the 2003 Addenda, and that the the edition will be updated updated to the most recent edition endorsed in in 10 CFR 50.55a and approved approved for the 55thth 10-Year 10-Year lSIISI Internal Internal (which is the first full1-Year full 1-Year ISI lSI Interval in in the period of extended operation, the staff finds that the applicant's applicant's ASME Section Section XI Inservice Inspection, Subsections Inspection, Subsections IWB, IWC, and IWD Program Program to be acceptable acceptable because because the staff has verified that the program 3-102 3-102

elements for the AMP are consistent consistent with the staff's recommended recommended program element element criteria in GALL GALL AMP XI.M1, XI.M1, "ASME Section XI Inservice Inspection, Subsections Subsections IWB, IWC, and IWD." IWD."

Operating Operating Experience. The staff reviewedreviewed the applicant's experience basis document applicant's operating experience document safety significant for safety operating experience significant operating experience relevant relevant to aging management management of ASME ASME Code Class 1, 2, and 3 components. The staff placed emphasis on operating operating experience experience that that could impact impact the ability of these components components to maintain boundary integrity maintain the pressure boundary integrity functions, with particular particular interest interest in operating experience that could impact the pressure operating experience pressure boundary integrity functions of the ASME boundary ASME Code Class 1 components components in the RCPB. More More specifically, the staff reviewed the integrity of ASME Code Class 1 nickel-alloy nickel-alloy base metal components and/or ASME Code Class 1 base metal components with associated components associated nickel-alloy nickel-alloy pressure pressure boundary boundary welds.

The staff noted noted that although although the Nickel-Alloy Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Reactor Vessel Closure Program provides the applicant's Closure Head Program augmented inspection program for applicant's augmented for managing PWSCC in the upper managing penetration nozzles, upper RV closure head penetration nozzles, the applicant implements implements the augmented inspection requirements augmented inspection requirements for these nozzles nozzles pursuant to NRC Order EA-03-009, as amended, through its 10-Year 10-Year lSI ISI plans for Units 1 and 2. Thus, the applicant addresses addresses relevant relevant safety significant significant operating nickel-alloy upper RV closure head operating experience on nickel-alloy penetration penetration nozzles through the program elements of its Nickel-Alloy program elements Nickel-Alloy Penetration Nozzles Nozzles Welded to the Upper Reactor Vessel Closure Head Program, and implements implements the mandated augmented augmented inspections of these componentscomponents through its 10-Year ISI lSI plans for Units 1 and 2.

BVPS-specific and generic industry-wide BVPS-specific operating experience industry-wide operating experience with upper upper RV closure head head nozzles managed through the applicant's nozzles is managed Penetration Nozzles applicant's Nickel-Alloy Penetration Nozzles Welded Welded to the the Upper Upper Reactor Vessel Closure Head Head Program implemented through both the Nickel-Alloy Program and implemented Nickel-Alloy Nozzles Welded to the Upper Penetration Nozzles Upper Reactor Reactor Vessel Closure Head Head Program Program and the the applicant's applicant's ASME Code Section XI Inservice Inservice Inspection, Subsection IWB, Subsection IWB, IWC, and IWD IWD Program.

The staff verified that the applicant applicant has adequately addressed relevant operating experience adequately addressed experience on on PWCCC PWCCC of upperupper RV closure head penetration nozzles and factored the relevant operating head penetration operating experience experience into the its Nickel-Alloy Nickel-Alloy Penetration Penetration Nozzles Nozzles Welded to the Upper Reactor Vessel Upper Reactor Closure Closure Head and ASME Code Section XI Inservice Inservice Inspection, Inspection, Subsection IWB, IWB, IWC, and IWD IWD Programs. Therefore, the staff finds the applicant's basis for addressing this operating operating experience experience acceptable.

acceptable. The staff evaluation evaluation of the applicant's applicant's Nickel-Alloy Nickel-Alloy Penetration Penetration Nozzles Nozzles Welded Welded to the Upper Reactor Reactor Vessel Closure Head Head Program Program is discussed in SER Section 3.0.3.1.16 and includes includes the staff's experience evaluation staffs operating experience evaluation of flaw indications indications detected detected in the Unit 2 upper upper RV closure head nozzles during RFO #2R12 #2R12 (2006).

The staff noted that the Nickel-Alloy Nozzles and Penetrations Nickel-Alloy Nozzles Penetrations Program Program provides the applicant's applicant's augmented augmented inspection program for managing PWSCC in the remaining nickel-alloy Class 1 nickel-alloy base metal metal and weld locations. The program includes the applicant's applicant's commitment (Commitment (Commitment No. 15 for Unit 1 and Commitment No. 17 for Unit 2) to implement it commitments that have been made to applicable NRC Orders, GLs, and Bulletins on nickel-alloy nickel-alloy component component cracking.

confirmed that the applicant has implemented The staff confirmed implemented the augmented augmented inspection inspection criteria forfor these nickel-alloy components through nickel-alloy components through implementation implementation of its 10-Year 10-Year lSIISI plans for the BVPS BVPS units. The staff has also confirmed that the applicantapplicant has adequately addressed addressed relevant operating experience experience on PWCCC of ASME Code Class 1 nickel-alloy nickel-alloy components components and factored the relevant relevant operating experience experience into the applicant's Nickel-Alloy Nozzles Nickel-Alloy Nozzles and Penetrations and 3-103

ASME ASME Code Section Xl XI Inservice Inspection, Subsection Subsection IWB, IWC, and IWD IvVD Programs, and finds the applicant basis for addressing addressing this operating operating experience experience to be acceptable.

acceptable. The staff staff evaluation of the applicant's Nickel-Alloy Nozzles applicant's Nickel-Alloy Nozzles and Penetrations Penetrations Program is discussed in SER Section 3.0.3.3.3. The staff's evaluation includes includes resolution of RAI B.2.28-3, in which the the requested that the applicant clarify whether the scope of its responses staff requested commitments responses and commitments made in response to NRC Bulletin 2003-02 (lower (lower RV closure head bottom-mounted bottom-mounted instrumentation instrumentation nozzle cracking and Bulletin 2004-01 on nickel-alloy pressurizer components nickel-alloy pressurizer components cracking) cracking) were within the scope of the applicant's applicant's Nickel-Alloy Nozzles Nozzles and Penetrations Penetrations Program.

Program.

Based on these reviews, the staff confirms that the applicant applicant has has appropriately augmented its appropriately augmented ASME Code Section XI InserviceInservice Inspection, Subsection Subsection IWB, IWC, and IWD Programs Programs to to factor in relevant safety-significant safety-significant Code Class operating operating experience.

UFSAR Supplement. The applicant provided provided its UFSAR Supplement Supplement for the ASME ASME Code Section XI Inservice Inservice Inspection, Inspection, Subsection Subsection IWB,IWB, IWC and IWD IWD Program in LRA Section Section A.1.2. In the Staff Evaluation Evaluation section, the staff provided provided its basis for accepting accepting the the applicant's applicant's exception to the ASME ASME Code Section Xl XI edition or record program program for use as the the basis for the ASME Code Section XI Inservice Subsection IWB, IWC and IWD Inservice Inspection, Subsection IWD Program.

The staff staff reviewed the UFSAR Supplement described described in LRA Section A.1.2 and determines determines that that the applicant's applicant's UFSAR Supplement Supplement for the ASME Code Section Inservice Inspection,Section XI Inservice Inspection, Subsection Subsection IWB, IWC and IWD Program Program provides provides an acceptable descriptiondescription of the program program because itit appropriately appropriately indicates indicates that the program is implemented implemented in accordance accordance with the ISI lSI requirements of 10 requirements 10 CFR CFR 50.55a and the ASME Code Section Section XI and because because the applicant applicant credits credits an acceptable edition edition of the ASME Code Code Section XI (Le. (i.e. the 2001 Edition inclusive of the Edition inclusive the 2001 Addenda)

Addenda) for aging management aging management of its ASME Code Class components. Based Based on its review, the staff determines determines that the applicant's UFSAR UFSAR Supplement Supplement for the ASME ASME Inservice Inspection, Code Section XI Inservice Inspection, Subsection Subsection IWB, IWC and IWD Program Program provides provides an acceptable description of the AMP, as required by acceptable summary description by10 10 CFR 54.21(d).

54.21(d).

Conclusion. Based Based on its review review of the applicant's Inservice Inservice Inspection Program, the staff staff concludes concludes that the applicant has demonstrated demonstrated that effects of aging will be adequately adequately managed so that the intended function(

function(s)s) will be maintained maintained consistent consistent with the CLB for the period period of extended extended operation, operation, as required by 10 CFR 54.21(a)(3). The staff staff also reviewed the FSAR supplement supplement for this AMP and concludes that itit provides an adequate adequate summary description description of thethe program, as required by 10 CFR 54.21(d).54.21(d).

3.0.3.2.2 3.0.3.2.2 ASME Code Code Section XI, XI, Subsection Subsection IWE Program Summary Summary of Technical Technical Information Information in the Application. In LRA Section Section B.2.3, the applicant applicant described described the existing ASME Code Section Section XI, Subsection IWE Program Program as consistent, with exception, with GALL AMP XI.S1 "ASME "ASME Code Section XI, XI, Subsection IWE." IWE." This program is implemented implemented through plant procedures, which provide for ISI lSI of Class MC and metallic liners of Class CC components.

Section Section 50.55a 50.55a of 10 10 CFR specifies specifies the use of the examination examination requirements in the ASME ASME Code,Section XI, Subsection IWE, for steel liners of concrete containments and other concrete containments other 3-104 3-104

containment components.

containment components. The applicant stated that it has implemented implemented ASME Code Section XI, XI, Subsection IWE, 1992 Edition with the 1992 Subsection 1992 Addenda, and will use the ASME Code edition consistent with the provisions provisions of 10 CFR 50.55a, during the period period of extended extended operation.

Staff Evaluation. In the LRA, the applicant applicant stated that ASME Code Section Section XI, XI, Subsection Subsection IWE IWE is an existing program that is consistent, with exception, exception, with GALL AMP XI.S1.

XI.S1.

During the audit, the staff interviewed interviewed the applicant's applicant's technical technical staff and audited the applicant's applicant's ASME Code Section Section XI, Subsection IWE Program onsite basis documents documents to confirm the the consistency with GALL applicant's claim of consistency GALL AMP XI.S1.

XI.S1. In In addition, addition, the staff reviewed the the exception and its justification to determine whether exception whether the AMP, with the exception, remains remains adequate to manage adequate manage the aging effectseffects for which itit is credited.

The applicant's applicant's ASME Code Section XI, Subsection IWE Program Program takes exception exception to the scopescope monitored or inspected, of program, parameters monitored inspected, detection detection of aging effect, monitoring and and acceptance criteria, and corrective trending, acceptance corrective action program program elements in that itit did not use the the ASME Code Section XI, Subsection Subsection IWE, 2001 edition, with the 2002 through 2003 Addenda. In In the LRA, the applicant applicant stated stated that its use of the ASME Code 1992 edition through the 1992 1992 Addenda complies complies with 10 CFR 50.55a which requires use of the Code in effect 12 months prior prior to the start of the inspection inspection interval. The applicant applicant further further committed that itit will use the ASME ASME Code edition consistent consistent with the provisions provisions of 10 CFR 50.55a 50.55a during the period of extended extended operation. The staff issued issued generic RAI B.2-2,8.2-2, by letter letter dated June 5, 2008, requesting requesting that the the applicant clarify which edition of the ASME Code Section XI will be credited for those AMPs that credit the ASME Code SectionSection XI, during the period period of extended extended operation. The staff's review of RAI 8.2-2 documented in SER Section B.2-2 is documented Section 3.0.3.2.1.

3.0.3.2.1.

The staff reviewed reviewed the exception exception described in LRA Section B.2.3 and additional information Section 8.2.3 information provided provided by the applicant in its response to RAI B.2-2 8.2-2 dated July 21, 21, 2008. The staff finds that the exception exception to the use of the ASME Code Section XI, Subsection IWE, 1992 1992 edition with 1992 1992 Addenda Addenda is within the limitations and modifications modifications required by 10 CFR 50.55a. The applicant's applicant's assurance of the use of subsequent subsequent editions and addenda of ASME Code Section Section XI, Subsection IWE, as required required by 10 10 CFR 50.55a ensures that the applicant's applicant's IWE IWE program program will be consistent with GALL AMP XI.S1 during the period of extended extended operation. Based 8ased on its review, the staff finds the applicant's applicant's exceptions exceptions to the use of the IWE program acceptable.

program Operating Experience. The staff also reviewed reviewed the operating operating experience, including including samples of condition reports, and interviewed interviewed the applicant's applicant's technical staff to confirm that the plant-specific plant-specific experience did not reveal any degradation operating experience degradation not bounded by industry experience. experience.

However, during its review review audit, the staff noted that a temporarytemporary construction construction opening was was created in 2006 for the Unit 1 SG and reactor head replacements. Inspections during RFO 17 replacements. Inspections revealed degradation (2006) revealed degradation from the inaccessible inaccessible side of the steel liner, for which the applicant applicant could not identify aa root-cause root-cause from observations observations in field or from lab analysis.

analYSis. To ensure the the essential essential leak-tight condition of the containment, the staff identified three issues where where additional clarifications and justifications additional clarifications justifications were needed to complete complete the review.

In RAI 8.2.3-1, In B.2.3-1, dated May 8, 2008, that staff requested requested that the applicant provide provide information information related related to the minimum required thickness of the liner; discuss discuss the possibility possibility and severity of similar corrosion corrosion at other locations, including Unit 2 containment; containment; and justify whether the the corrosion is active. Furthermore, Furthermore, the staff requested the applicant applicant discuss the use of the GALL 3-105

Report which recommends further evaluation of plant-specific plant-specific programs to manage this aging effect for inaccessible inaccessible areas, if corrosion is significant.

In its response to RAI B.2.3-1, B.2.3-1, dated June June 16, 2008, the applicant stated:

Analyses and evaluations of the Unit 1 containmentcontainment liner corrosion corrosion in 2006 were performed for FENOC FENOC by several several vendors that specialize in these types of analyses analyses and by the FirstEnergy FirstEnergy Beta Laboratory.

The Shaw Group, Inc., evaluatedevaluated the condition condition of the Unit 1 containment containment liner regarding the extent of the degradation degradation and effects on intended intended function following following the discovery of the containment containment liner corrosion in 2006. The evaluation included evaluation included consideration of the impactimpact of an additional additional 20 years of operation as a result of license renewal renewal on the recurring Integrated Leak Rate Test loading. loading.

In the Shaw Shaw Group's report, design basis calculations calculations originally developed developed for the the BVPS Unit 1 containment containment liner were used to demonstrate demonstrate that the degraded conditions found on the liner did not adversely adversely affect its mechanical/structural mechanical/structural function as a leak-tight leak-tight membrane. The thickness of the remaining sound metal was determined determined to be adequate adequate to maintain maintain the design safety function of the the liner. In addition, the capacity capacity of the concrete concrete containment structure to withstand Design Basis Accident loadings was not adversely affected.

Of the three areas of corrosion identified, two were replaced replaced with new plate plate material. The third area showed minimal wall loss at the deepest deepest pit, and was left in place for further monitoring.

monitoring. In In addition to initial "baseline" "baseline" ultrasonic ultrasonic thickness thickness measurements in accordance measurements accordance with Table IWE-2500-1, examination category E-C, IWE-2500-1, examination itit was recommended recommended that the third area area of degradation degradation be mapped mapped on the inside inside of the containment containment liner for future UT examinations.

examinations. ItIt was recommended recommended that that this area be examined examined for the next three inspection inspection periods. IfIf no change in liner liner thickness thickness was detected detected after three inspection inspection periods, it was determined determined that the the area would require no additional inspections. Further engineering evaluation was was recommended if the thickness changed. FENOC has scheduled recommended scheduled additional UT UT examinations as recommended by The Shaw Group, Inc., for the three inspection inspection periods following the 2006 RFO when the degradation degradation was discovered.

discovered.

A material material analysis was performed performed by the FirstEnergy FirstEnergy Beta Laboratory Laboratory on the the corroded steel liner areas and sample pieces of concrete to aid in determining determining a cause of the corrosion. The following conclusionsconclusions were drawn concerning concerning thethe corrosion activities:

• The corrosion was general general pitting corrosion corrosion (wastage) with no evidence evidence of stress corrosion microbiological attack. The metallographic corrosion or microbiological metallographic work performed by Beta Labs found the pitting to be rounded in nature nature with no no crack crack like projections. The examination examination of the corrosion product product trapped in the deep pits identified identified no unusual unusual levels of elements elements that were not expected expected to be present. No preferential preferential corrosion attack was observed observed on the sample piece with the weld or on the welds around around the Nelson studsstuds 3-106

welded to the liner plate. Some crevice corrosion corrosion was observed in the the cross section of the studs where the flash weld could trap contaminates.contaminates.

• • The corrosion occurred occurred after welding and construction of the liner plate plate since the corrosion pitting was even across the weld, the heat affected affected (HAZ) and both edges of the weld where weld prep would have zone (HAZ) have preferential corrosion occurred occurred. No preferential occurred at the weld or HAZ.

• " necessary elements for corrosion (oxygen and water) were present The necessary present throughout the construction phase of Unit 1, from the fabrication and throughout erection erection of the liner plate through through the completion of concrete concrete pours for the the containment structure. During this timeframe, water, in the form top of the containment of the wetting methodology used during the concrete concrete pour sequences sequences and weather weather (rain and snow), could accumulate accumulate in areas areas between the liner plate and the concrete structure. Corrosion Corrosion activities activities are likely to have have initiated during this construction construction period.

• • Access to these necessary necessary elements for corrosion corrosion activity became became significantly limited once the concrete structure structure was completed. Exposure Exposure to water sources sources all but ceased, and the concrete/steel concrete/steel interface interface was no no longer exposed to the atmosphere re-oxygenation.

atmosphere for re-oxygenation.

• • The corrosion process process consumes oxygen, and, once it is depleted, corrosion can not be sustained at a high rate due to the limited supply of oxygen between between the concrete concrete and the liner plate following fabrication.

• • No corrosive agents or corrosion catalysts, such as chlorides, could be be identified identified on or in the steel liner liner plate. Additionally, no corrosion agents were found in the pitted areas of the liner plate or in the concrete concrete materials tested in concentrations materials concentrations that would be of concern. However, it must be considered considered that such materials materials may have existed in local areas local areas and were removed removed during the water hydrolyzing process that was used to hydrolyzing process remove remove the exterior containment containment concrete.

"* Approximately Approximately 1% 1% of the observable observable liner plate (portion removed for the the construction construction opening) opening) contained corroded areas and a much smaller contained corroded smaller percentage percentage of the rebar surface area had evidence evidence of corrosion. So, it is reasonable reasonable to assume that the concreteconcrete did not contain corrosive corrosive agents, and that corrosion elements elements (water and oxygen) oxygen) were not present inin abundant abundant amounts. This finding would support the general general conclusion that no general corrosion corrosion is active active in the area between between the liner plate and the the concrete.

• • The corrosion is localized for reasons reasons that can not be determined determined with certainty. However, small breaks breaks in the mill scale surface surface or other surface surface imperfections imperfections can provide the initiation sites for pitting (oxygen cell corrosion) during the time of construction corrosion) construction when oxygen and water were known known to be present.

3-107 3-107

• • The concrete concrete did contain contain small void areas at the concrete/steel concrete/steel interface.

These voids would most likely have filled with water during the the construction construction phase. During the post-construction post-construction life of the liner, these locations locations could also serve as an accumulation accumulation point for any moisture that enters the concrete concrete structure. However, the area of the containment containment liner liner where the concrete concrete was found to have small voids at the steel/concrete steel/concrete interface interface had no corrosion corrosion activity.

"

• Foreign material has been identified by other power plants that removed removed the liner plate from the inside of containment containment leaving the concrete in in place. The foreign debris was identifiable in these instances instances since thethe corrosion product was available for analysis. At BVPS, little or no corrosion product no corrosion product remained following the water hydrolyzing, corrosion product hydrolyzing, so no no conclusions conclusions could be drawn regarding the source of the corrosion.

A vendor materials specialist specialist was commissioned commissioned to perform aa corrosion assessment assessment of the corroded corroded steel liner, and stated stated that the primary primary source of passivation of the steel used in fabrication of the containment containment liner, studs and and rebar is the concrete itself. The passivity of the steel depends depends upon the quality quality of concrete in contact with the steel and the intimate contact the concrete contact of the steel to the the concrete. The vendor concluded that, where the containment containment steel liner, studs studs and rebar rebar are in contact with the concrete concrete cover, the containment containment steel liner at BVPS Unit 1 would passivated state and not !?ubject would be in a passivated subject to oxygen concentration concentration cell corrosion. The visual inspection inspection of the removed cutout and rebar identified identified that the majority majority (over 99%)

99%) of the surfaces in contact contact with the the concrete concrete were passive to an oxygen concentration concentration cell corrosion mechanism.

corrosion mechanism.

Based Based on its review, the staff finds the applicant's applicant's response to RAI B.2.3-1 acceptable because acceptable because the applicant has adequately adequately explained that corrosion of the liner plate or rebar materials from from the concrete concrete side of the liner plate is passive becausebecause there is no active mechanism mechanism for determines that the Shaw corrosion. The staff determines containment liner Shaw Group's evaluation of the Unit 1 containment liner confirmed that the degraded confirmed degraded conditions conditions found on the liner did not adversely affect its mechanical and/or structural function as a leak-tight leak-tight membrane.

membrane. Therefore, Therefore, the staff's concern described described in in RAI B.2.3-1 is resolved.

In LRA Section Section B.2.3, the applicant applicant stated that following following RFO 17 (2006) for Unit 1, test procedures procedures for the evaluation evaluation of the containment containment liner plates plates were modified at both units. The The staff determined determined that additional information information was required to complete its review.

In RAI B.2.3-2, dated May 8, 2008, the staff requestedrequested that the applicant applicant identify which test procedures or part of the procedures procedures procedures were modified compare them with previous modified and compare previous procedures, as well as those required by ASME Code Section Section XI, Subsection IWE. The The applicant applicant was also asked to explain whether the modified test procedures procedures help detect similar similar containment liner degradation degradation on the side that is in contact with the concrete and; ifif not, how the the applicant applicant will ensure ensure that similar degradation, ifif any, is detected.

detected.

In its response to RAI B.2.3-2, dated June 16, 2008, the applicant explained that the procedures procedures for Units 1 and 2 were modified to includeinclude two additional requirements in the containment additional requirements containment 3-108 3-108

inspection procedures, resulting from the liner corrosion inspection corrosion found in 2006: (1) when paint or or removed for further coatings are removed further inspection, inspection, the paint or coatings shall be visually examined examined by qualified VT-3 inspector a qualified inspector prior to removal, and (2) if the visual examination examination detects detects surface surface flaws on the liner or suspect areas on the liner plate that could potentially impact the leak tightness or structural structural integrity of the liner, then surface or volumetric examinations examinations shall be be performed characterize the condition (i.e., depth, performed to characterize depth, size, shape, orientation).

orientation). The applicant applicant further stated that these additional examination requirements and the use of the FENOC examination requirements FENOC Corrective Action Program provide reasonable Corrective assurance that potential corrosion on the reasonable assurance the concrete containment liner plate will be identified concrete side of the containment addressed.

identified and addressed.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.3-2 acceptable acceptable because because the applicant described the modifications applicant described modifications of the containment containment inspection inspection procedures procedures that will identify additional areas of corrosion (if (if any). These procedures will be incorporated incorporated as part of the ASME Code XI, Subsection IWE examinations.

examinations. Therefore, Therefore, the staff's concerns described in concerns described in RAI B.2.3-2 are resolved.

resolved.

The staff reviewed reviewed that applicant's applicant's ASME ASME Code Section XI, XI, Subsection Subsection IWE Program. The The GALL AMP XI.S1 states that ASME Code Section Section XI paragraph paragraph IWE-1240 IWE-1240 requires augmented augmented examinations of containment examinations containment surface areas that are subject subject to degradation. The staffstaff determined that additional determined additional information information was required to complete the review.

In RAI B.2.3-3, dated May 8, 2008, the staff requested that applicant historically explain what applicant historically inspection findings under inspection under the BVPS lSI ISI - IWE Program, including the 2006 findings of the liner degradation on the side in contact degradation contact with concrete, have led to the need need for augmented augmented inspections.

In its response to RAI B.2.3-3, dateddated June June 16, 2008, the applicant stated that Units 1 and 2 do do not meet the criteria for ASME ASME Code augmented examinations Code augmented examinations as defined defined in ASME ASME Code XI, IWE-1240. There There are no augmented augmented examinations performed on examination examinations being performed examination surface surface areas at Units 1 or 2 as defined defined in ASME ASME Code Section XI, Subsection Subsection IWE-1240. However, the the applicant further explained explained that two of the three degraded degraded areas areas were removed and replaced with new plate material material in 2006, following the discovery discovery of corrosion on the concrete side of the the liner plate. The third area was found acceptable from examination examination and laboratory analysis laboratory analysis and was left in place. As part of the corrective actions from the discovery, this third area is monitored monitored examinations. FENOC has scheduled with additional examinations. scheduled additional UT examinations examinations as as recommended recommended by The Shaw Group, Incorporated Incorporated for the three inspection inspection periods following RFO 17 (2006), when the degradation degradation was discovered.

Based on its review, the staff finds the applicant's response to RAI B.2.3-3 acceptable because acceptable because the applicant applicant has verified verified that Units 1 and 2 do not meet meet the criteria for ASME Code augmented augmented examinations as defined in ASME ASME Code Code Section XI, IWE-1240. Two of the three unacceptableunacceptable degraded areas were removed and replaced with new plate material material following the discovery of the corrosion corrosion on the concrete side of the liner plate during RFO 17 17 (2006). Therefore, the staff's staffs described in RAI B.2.3-3 are resolved.

concerns described On April 23, 2009, during a Unit 1 IWE inspection, a paint blister was discovered on the the containment liner. Further containment Further investigation revealed through-wall investigation revealed through-wall corrosion containment liner.

corrosion of the containment In response response to this operating operating experience, experience, by letter dated May 7, 2009, the staff issued RAI May 7,2009, B.2.3-4, requesting the applicant to explain 8.2.3-4, explain how the recent plant-specific plant-specific operating experience, operating experience, 3-109 3-109

as well as the as the 2006 degradation, would be be incorporated incorporated into into the ASME Section Section XI, Xl, Subsection IWE AMP.

IWEAMP.

In its response, dated June 1, 2009, the applicant stated that the procedures for both Units were modified following the 2006 degradation to include the following following acceptance criteria:

1. When paint or coatings are to be removed for further inspection, inspection, the paint or coatings shall be visually examined by a qualified VT-3 inspector prior to removal. '

2. If the visual examination detects surface flaws on the liner IUhe liner or suspect areas on on the liner plate that could potentially impact leak tightness or structural integrity of the liner, then surfacesurface or volumetric examinations shall be perfollTled performed to characterize the condition (Le., (i.e., depth, size, shape, orientation). '

The applicant The, applicant also explained explained that visual examinations of 100% of the accessible liner area have scheduled for Unit 1 refueling been scheduled refueling outage 1R20 in fall 2010 and Unit 2 refueling refueling outage 2R14 2R1 4 in fall 2009. 'A A LIT UT inspection inspection of the repaired area is also scheduled scheduled for outage 1 R20. In addition to the visual inspections, the applicant' applicant committed to perform supplemental supplemental volumetric volumetric examinations of 75 One examinations one foot square sample locations locations at each unit prior to the period of extended operation.

The following table provides the relevant past operating experience, as well as proposed proposed future actions.

,t--'"

Un It

/";Unlt;" Date', AtIvit

S,;

};:bDate:;,\j))\<;",~ ,:~:.:!n;;;~i'::i):s";:;:'S:;'";:,'J:,':::'<,)";;v::;;\:,~;;,, c::~ACtlVlty,:~;,\,,';'[':,","';*  ;/"./.. ..

'"

-;

'.

"

,. "

1 1 May May 2006 2006 Found three small Found small areas areas of of degraded'lin~r degraded-liner plate. plate. Two areas removed and replaced. Thirej replaced. Third area area foundfound acceptable.

acceptable. Successful Successful integrated leakage leakage rate testtest (lLRT)

(ILRT) after repair repair 22 May 2008

'May 2008 Successful integrated Successful integrated leakage leakage rate rate test test (ILRT)

(ILRT)

\11 April 2009

' April 2009 IWE inspection IWE inspection found found a 3/8"x 1" 1"hole in in liner plate which was removed replaced and 'replaced 22 October October 2009 2009 100 percent 100 visual examination of'liner percent visualexamiriatioh ofliner plate

,11 ,October

,October 2010' 2010 "100 percent "100 visual examination -f percent visual'examination liner plate

• of.liner .--~

22 April 2011 April 2011 Scheduled IWEprogram Scheduled IWE:program visual examination of visualexamiriation liner plate of liner 1

1 April 2012 April 2012 Scheduled, IWEprocgram'visual

,Scheduled. IWEprogram' visual examination examination of liner liner plate 1

1 January Janu~iy 2016 2016 Volumetric Volumetric examination eXamination of 75 one one foot square square area area of liner liner plate prior to to the start of the start' extended period of extended period of operation o(operation 22 May May 2027 2027 Volumetric Volumetric ,examinationexamination of 75 one oriefootfoot square square area area of liner liner plate prior to to the the'start extended period Of start of extended of operation operation The staff reviewed reviewed the applicant's applicant's RAI response, response; ,and and participated participated in a conferenceconference call with the the applicant applicant on June 4, 2009. During the call, call, the staff staff-asked for clarification on the supplemental asked for',clarification volumetric volumetric examinations examinations including:including: (1) aa discussion discussiOn of the the method method used. used to select the the examination examination locations; (2) anmexplanation an' explanation of the thE! resulting resulting actions if degradation degradation was found; found; and (3)

(3) an explanation of the implementation anexplanati6n implementation timeframe. timeframe.

During During the conference conference call, call, the applicant applicant explained explained that the the sample locations have not been sample locations decided decided yet, but will focus focus on areas areas most most likely to experience similar experience similardegradation, degradation, such such as as locations locations at similar similar elevations, elevations, or areas areas that t~at have required recoating in the past. The haverequire.drecoating The applicant applicant further further explained explained that the sample sample locations locationswould would not not be completely completely random, but would be be 3-110 3-110 .

based on past operating operating experience.

experience. During the call the applicant applicant also stated that if if degradation identified during the supplemental is identified supplemental volumetric examinations, examinations, the degradation degradation would be entered into the applicant's applicant's corrective action program.

program. Depending Depending on the type and extent of degradation, degradation, the corrective actions actions may include include reanalyzing reanalyzing and increasing increasing the sample size. In response to implementation timeframe, the applicant the implementation applicant stated that the program is currently being evaluated to decide decide when the examinations examinations will take place. The applicant has committed to completing the the supplemental volumetric examinations prior to the period of extended volumetric examinations extended operation for each unit.

Based Based on its review, the staff finds the applicant's applicant's response to RAI B.2.3-4 acceptable because because management program incorporates the applicant's aging management incorporates the recent plant-specific plant-specific operating experience.

experience. The modified procedures, along with the 100% examination of the liner plate 100% visual examination plate during the next outage and the supplemental supplemental volumetric examinations examinations prior to entering entering the the period of extended extended operation, provide provide reasonable reasonable assurance that the AMP is adequate adequate to manage the aging effects for which it is credited manage credited in the LRA. The staff's concerns regarding license license renewal, as described described in RAI B.2.3-4 are resolved. The impact impact of this operating experience experience on the current operation of the plant is being reviewed under under the provisions provisions of the the applicant's applicant's 10 CFR Part 50 operating operating license.

In response to questions questions raised during the ACRS sub-committee sub-committee meeting on FebruaryFebruary 4, 2009, the staff issued RAI B.2.3-5, by letter dated May 7,2009. 7, 2009. The RAI requested the applicant to to explain how their IWE Program was enhanced enhanced as discussed during the meeting, and how these enhancements compared enhancements compared to the ASME code required required augmented augmented inspections.

In its response, dated June June 1, 2009, the applicant stated that the program was not enhanced enhanced to to achieve consistency as described in NUREG-1800.

achieve GALL consistency NUREG-1BOO. The procedures procedures were modified, as as discussed discussed above, to identify additional additional actions actions in the event suspect surfacessurfaces are identified identified by thethe IWE visual inspection. The applicant further stated that UT examinations were performed performed on the the area of degradation degradation discovered discovered during the 2006 steam generator generator replacement replacement outage outage which was left in place. The applicant applicant explained that these examinations examinations were corrective corrective actions actions related to the degradation degradation and are not considered considered IWE augmented examinations augmented examinations since the the degradation degradation was discovered discovered outside of the scheduled IWE examinations. The applicant also stated that the through-wall through-wall degradation discovered discovered in April 2009 during during an IWE examination examination does not require augmented augmented examinations because because the degraded degraded area was replaced.

replaced. The The applicant stated that the corrective applicant corrective actions from the 2009 degradation degradation include 100% 100% visual inspection inspection of the accessible liner during the next outage, a UT inspection inspection of the replaced area, supplemental volumetric inspections. These are not characterized and supplemental characterized as IWE augmented augmented examinations.

applicant's response to RAI Based on its review, the staff finds the applicant's 6.2.3-5 acceptable RAI B.2.3-5 because acceptable because itit explains explains how the program was enhanced enhanced and why the degraded areas areas do not fall under the the IWE Examination Examination Category E-C (i.e., (i.e., augmented examination). The 2006 degradation degradation was not not discovered during an IWE examination and the corrective actions actions are not tracked under under the IWEIWE AMP, while the 2009 degradation degradation does not require require IWE augmented examinations augmented examinations per IWE-2420 IWE-2420 because the area was replaced.

because replaced. The staffs concerns describeddescribed in RAI B.2.3-5 are resolved.

The staff confirmed that the "operating experience" program element satisfies satisfies the criterion defined in defined in the GALL Report and in SRP-LR Section A.1.2.3.10. A.1.2.3.1 O. The staff finds the program element acceptable.

3-111 3-111

UFSAR Supplement. The applicant provided UFSAR provided the UFSAR supplement supplement for the the ASME ASME Code Section XI, Subsection IWE Program in in LRA Section A.1.3.

A. 1.3. The staff staff reviewed reviewed thisthis determines that the information Section and determines information in the UFSAR UFSAR supplement is an adequate adequate summary description of the program, as required by 10 10 CFR 54.21 54.21(d).

(d).

Conclusion. The staff reviewed the informationinformation in LRA Section B.2.3 and additional information information provided byby the applicant by letter dated June 16, 2008. The staff finds that those attributes of the applicant's applicant's ASME Code Section XI, Subsection IWE Program for which the applicant claimed consistency with the GALL Report are consistent with the GALL Report. In In addition, the staff reviewed the applicant's exception and justification justification and determines that the AMP, with the the adequate to manage the aging effects for which the LRA credits it.

exception, is adequate it.

Based on its review, the staff concludes that the applicant has demonstrated demonstrated that the effects of aging will be adequately managed managed so that the intended functions maintained consistent functions will be maintained with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the UFSAR supplement supplement for this AMP and concludes concludes that it provides an adequate summary summary description of the program, as required by 10 CFR 54.21 54.21(d).

(d).

3.0.3.2.3 ASME Code Section XI, Subsection Subsection IWF Program Summary of Technical Technical Information in the Application. In LRA Section B.2.4, the applicant applicant described the existing ASME Code Section Section XI, Subsection IWF Program as consistent, with exception, with GALL AMP XI,S3 XI.S3 "ASME Code Section XI, Subsection IWF." This program program is implemented through plant procedures implemented procedures which which provide provide for visual examination of lSI ISI Class 1, 2, and 3 supports in accordance accordance with the requirements requirements of ASME Code Case N-491 N-491,, Alternate Alternate Rules for Examination of Class 1, 2, 3, and MC Component Component Supports of Light-Water Cooled Power.

The ASME Code Section XI, XI, Subsection IWF Program Program consists of periodic periodic visual visual examination of ASME ASME Code Section XI Class 1, 1, 2, 3 and MC components components and piping support members for loss loss of mechanical mechanical function and material. The applicant stated that it has implemented implemented ASME ASME Code Section Section XI, Subsection Subsection IWF, 1989 Edition with no Addenda, and will use the ASME ASME Code edition consistent consistent with the requirements requirements of 10 CFR 50.55a during the period of extended operation.

operation.

Staff Evaluation.

Evaluation. In the LRA, the applicant stated that ASME Code Code Section XI, XI, Subsection Subsection IWF IWF is an existing program that is consistent, with exception, with GALL existing program GALL AMP XI.S3.XI,S3.

During its audit, the staff interviewed interviewed the applicant's applicant's technical staff and audited audited the applicant's applicant's ASME ASME Code Section XI, XI, Subsection Subsection IWF Program Program onsite onsite basis basis documents documents to confirm confirm thethe applicant's applicant's claim of consistency consistency with GALL GALL AMP XI.S3. Furthermore, XI,S3. Furthermore, the staff reviewed reviewed the the exception exception and its justification justification to determine whether determine whether the AMP, with the exception, exception, remains remains adequate adequate to manage manage the aging aging effects effects for which which it is credited.

credited.

The The applicant's applicant's ASME Code Code Section Section XI,XI, Subsection Subsection IWF Program takes exception exception to the scopescope of program, program, parameters parameters monitored monitored or inspected, inspected, detection detection of of aging effect, monitoring monitoring and and

trending, trending, acceptance acceptance criteria, criteria, and corrective actions and corrective actions program program elements elements in in that it has has not used ASME ASME Code Section Section XI,XI, Subsection Subsection IWF, 2001 2001 Edition, with the 2002 through through 2003 Addenda.

Addenda. In the LRA, the the applicant applicant stated stated that that the the use use of the ASME ASME Code, 1989 1989 Edition Edition with no Addenda Addenda for for 3-112 3-112

the third (Unit 1 only) and second (Unit (Unit 2 only) ISI lSI intervals is consistent with 10 CFR 50.55a50.55a which which requires requires use the Code in effect 12 months prior to the start of the inspection inspection interval.

interval. The The applicant further committed that itit will use the ASME Code edition, consistent consistent with the the provisions of 10 CFR 50.55a, during the period period of extended operation. The staff issued RAI B.2-2, dated dated June 5, 2008 requesting that the applicant applicant clarify which edition of the ASME ASME Code Section XI will be credited credited for those AMPs that credit the ASME Code Section XI during during the period of extended operation. The staff's staffs review of RAI B.2-2 is documented documented in in Section 3.0.3.2.1.

3.0.3.2.1.

The staff reviewed the exception described described in LRA Section B.2.4 and additional information additional information provided by the applicant applicant in RAI B.2-2 in its response dated July 21, 21, 2008. The staff finds that the ASME Code Section XI, XI, Subsection Subsection IWF, 1989 Edition with no Addenda, was the edition edition incorporated incorporated into 10 10 CFR 50.55a at the time the applicant was required to declare declare its inspection inspection basis for the current 10-year 10-year IWF inspection inspection interval.

The applicant's assurance assurance to use ASME Code Section XI, 2001 Edition through 2002 and 2003 Addenda Addenda for the next next ISI Intervals will assure its IWF program is consistent with GALL lSI Intervals AMP XI.S3 during the period of extended extended operation.

operation. On this basis, the staff staff finds these these exceptions exceptions acceptable.

acceptable.

The staff noted that the exception exception due to the use of ASME Code, 1989 Edition with no Addenda Addenda included the applicant's applicant's use of ASME Code Section XI Code Case N-491 as alternate alternate rules for examination. However, in the "Operating Experience" program program element, the applicant applicant indicated indicated that ASME Code Code Section XI, Subsection IWF, 1989 edition, Table IWF-2500-1 was used instead instead of ASME Code Section XI Code Case N-491 N-491,, Table-2500-1.

Table-2500-1.

B.2.4-1, dated In RAI B.2.4-1, dated May 8, 2008, the staff requested that the applicant clarify this issue and confirm the version of ASME Code Section Section XI, Code Case N-491 used in making its determination. .

In its response response to RAI B.2.4-1, B.2.4-1, dated June 16, 2008, the applicant stated that ASME ASME Code Case N-491N-491,, Table-2500-1 Table-2500-1 should have been cited in the "Operating Experience" of LRA Section B.2.4 instead of ASME Code Section Section XI, IWF. The applicant applicant revised the first Experience," to reference paragraph of LRA Section B.2.4, "Operating Experience," reference ASME ASME CodeCode Case N- N-491. The applicant further stated that the version of ASME Code Case N-491 491. N-491,, used for the the ASME Code Section XI, XI, Subsection Subsection IWF Program, was RevisionRevision 0, dated March 14, 1991. The 1991. The date date listed in LRA Section Section B.3, "Appendix B References," is incorrect. The applicant B References," applicant also revised LRA Section B.3, Reference Reference B.3-4 to provide the correct date.

Based on its review, the staff finds the applicant's response to RAI B.2.4-1 B.2.4-1 acceptable acceptable because because the applicant has revised LRA Sections B.2.4 and B.3 to reflect the correct correct standards.

Therefore, the staff concern concern described described in RAI B.2.4-1 B.2.4-1 is resolved.

Operatingi Experience.

Operating Experience. The staff also reviewed the operating operating experience, experience, including samples samples of condition reports, and interviewed condition interviewed the applicant's applicant's technical staff to confirm that the plant-specific plant-specific operating experience did not reveal any degradation degradation not bounded by industry industry experience.

experience. In the the application, application, the applicant explained that the operating experience explained experience of the ASME Code Section XI, Subsection IWF Program activities shows no adverse trend of program performance.

Subsection performance. The The applicant also stated in the LRA that the ASME Code Section Section XI, Subsection IWF programprogram for 3-113 3-113

Units 1 and 2 has been updated updated to account account for industry industry operating operating experience experience to maintain maintain program quality. The applicant commenced commenced periodic inspections inspections in 2006 for Unit 1 and in 2003 for Unit 2 planned and every 10 years thereafter, for the duration duration of plant operation.

The staffs operating operating experience experience review concludes that the applicant's applicant's administrative controls controls effective in detecting are effective detecting age-related age-related degradation initiating corrective action. The staff did degradation and initiating did age~related issues not bounded not identify any age-related bounded by the industry operating experience.

UFSAR UFSAR Supplement.

Supplement. The applicant applicant provided the UFSAR supplement supplement for the ASMEASME Code Section XI, Subsection IWF Program Program in LRA Section A.1.4. The staff reviewed this this Section and determines determines that the information information in the UFSAR supplement UFSAR supplement is an adequate adequate summary description description of the program, as required required by 10 CFR 54.21 54.21(d).

(d).

Conclusion.

Conclusion. The staff reviewed reviewed the information information provided in LRA Section B.2.4 and additional provided by the applicant information provided applicant by letter dated June June 16,16, 2008. The staff finds that those those attributes of the applicant's applicant's ASME Code Section Section XI, Subsection IWF Program which the the applicant applicant claimed claimed consistency consistency with the GALL Report are consistent with the GALL Report. In GALL Report In

addition, addition, the staff has reviewed reviewed the exception and its justification and determines determines that the AMP, with the exception, exception, is adequate to manage manage the agingaging effects effects for which the LRA credits it. it.

Based on its review, the staff concludes that the applicant applicant has demonstrated demonstrated that the effects of aging will be adequately adequately managed managed so that the intended intended functions will be maintained consistent with the CLB for the period period of extended extended operation, as required by 10 CFR 54.21 54.21(a)(3). staff (a)(3). The staff UFSAR supplement for this AMP and concludes also reviewed the UFSAR concludes that it provides an adequate adequate summary description summary description of the program, as required required by 10 CFR 54.21(d).

54.21 (d).

Closed-Cycle Cooling Water System 3.0.3.2.4 Closed-Cycle System Program Summary of Technical Information in the Application. In LRA Section B.2.9, the applicant applicant described described the existing, Closed-Cycle existing' Closed-Cycle Cooling Water System Program Program as consistent, with enhancements, enhancements, with GALL AMP XI.M21 XI.M21, , "Closed-Cycle Cooling Water Water System."

The Closed-Cycle Closed-Cycle Cooling WaterWater System Program includes preventive preventive measures measures to minimize minimize corrosion and periodic system and component performance corrosion and. performance testing and inspection to monitor monitor the effects effects of corrosion, and confirm whether intended functions functions are met. This program program manages loss of material, cracking, cracking, and reduction reduction of heat transfer for components components exposed exposed to closed CWSs (i.e., primary primary component component and neutron shield tank cooling water, chilled water, diesel-driven diesel-driven fire pump engine cooling water (common), EDG cooling water, security diesel generator generator cooling water emergency response facility substation water (common), emergency substation diesel generator cooling water (common), and Unit 2 diesel-driven diesel-driven station standby air compressor compressor engine cooling cooling water).

These systems are closed cooling loops with controlled controlled chemistry, consistent consistent with the GALL Report description description of a closed-cycle closed-cycle CWS. The program routinely confirms the adequacy adequacy of chemistry chemistry control by sampling sampling to determine whether contaminants determine whether contaminants and additives are within established established limits and by equipment performance performance monitoring for aging effects. These chemistry activities applicant's procedures activities controlled by the applicant's procedures and processes processes are based on guidance guidance for closed-cooling water chemistry in EPRI 1007820 closed-cooling 1007820 (EPRI 107396, Revision 1).

(EPRI 107396, 3-114 3-114

Evaluation. In LRA Section Staff Evaluation. Section B.2.9, the applicant Closed-Cycle Cooling Water applicant stated that the Closed-Cycle System Program Program is an existing program program that is consistent with GALL Report AMP XLM21, XI.M21, with enhancements.

enhancements.

The staff reviewed those portions of the applicant's Closed-Cycle Closed-Cycle Cooling Water System Program that the applicant claimed claimed consistency consistency with GALL AMP XI.M21 XLM21 and found they are consistent with this GALL consistent GALL AMP. The staff also confirmed that the plant program, as enhanced by the applicant, incorporated incorporated all the program program elements of the referenced referenced GALL AMP and that the conditions at the plant are bounded by those for which the GALL Report is evaluated. The The conducted onsite interviews with the applicant's technical staff to confirm these staff also conducted these results.

The staff finds the applicant's Closed-Cycle Cooling Water System Program acceptable applicant's Closed-Cycle acceptable because itit conforms to the recommended recommended GALL AMP XLM21, XI.M21, subject subject to the applicant's applicant's proposed enhancements. The staff evaluates these enhancementsenhancements in the paragraphs paragraphs and subsections that follow and provides its basis for concluding concluding that the proposed enhancements proposed enhancements will make the applicant's Closed-Cycle Cooling Water System Program applicant's Closed-Cycle Program consistent the consistent with the recommendations in GALL AMP XLM21.

recommendations XI.M21.

Enhancement 1. The applicant's program Enhancement program includes includes an enhancement enhancement to the "Scope of Program" program element element of the AMP that states that components components were added to the program for aging aging management (i.e., diesel-driven management diesel-driven fire pump Unit 1 only and diesel-driven diesel-driven standby compressor standby air compressor Unit 2 only). During its review and audit, the staff noted that the scope of the Closed-Cycle Closed-Cycle Cooling Water System Program include all systems credited for in the Type 22 AMR Program did not include AMR tables of the LRA.

In RAI 8.2.9-1, B.2.9-1, dated dated May 22, 2008, the staff requested that the applicant address the address the identified as within the scope of the Closed-Cycle discrepancy between the systems identified Closed-Cycle Cooling Cooling Water System Program Program and those that the AMP credits in the Type 2 AMR Tables Tables of the LRA.

response to RAI B.2.9-1, In its response B.2.9-1, dated dated July 24, 2008, the applicant applicant stated that the text in LRA Section B.2.9, "Closed-Cycle Cooling Water," program program description description was intended to identify those systems that are a source closed-cycle cooling water systems and not a list of those source of closed-cycle those systems crediting crediting the program to manage the effects of aging. The applicant applicant further further described although system interfacing components exist such as heat exchangers, exchangers, that system is not necessarily a source necessarily source of closed-cycle closed-cycle cooling water and is therefore not identified in LRA Section B.2.9.

reviewed the applicant response The staff reviewed response and finds that the applicant adequately explained applicant has adequately explained the intent of the program description description text which was not meant meant to identify each system with components components that credit the program program with aging management. Therefore the Therefore the staff finds the response acceptable acceptable and the concern identified identified in RAI B.2.9-1 is closed.

Enhancement 2. The applicant also included an enhancement Enhancement enhancement to the "Parameters Monitored/Inspected" program element Monitoredllnspected" element of the AMP that statesstates that the AMP will be enhanced to performance testing of the heat exchangers "detail performance exchangers and pumps pumps and provide direction to perform visual inspections components." The staff noted that the "parameters inspections of system components.'~ monitored or "parameters monitored inspected" program program element in GALL GALL AMP XI.M21 XLM21 states that the parameters parameters monitored for 3-115 3-115

pumps in closed-cycle CWSs include system flow, discharge discharge pressure, and suction pressure.

Furthermore, the staff noted that for heat exchangersexchangers in closed-cycle CWSs, the parameters inspected include monitored or inspected include flow, inlet and outlet temperatures, and differential pressures.

In RAI 8.2.9-2, B.2.9-2, dated dated May 22, 2008, the staff requested requested that the applicant applicant explain whether the the closed-cycle closed-cycle CWS pumps for the Unit 1 diesel driven fire pump and the Unit 2 diesel driven driven compressor that the applicant added to the scope of this AMP (i.e., Enhancement standby air compressor Enhancement 1) are subject to the pump parameter parameter monitoring identified above, and ifif not, why this is not identified as an exception identified exception to the recommendations recommendations in GALL XI.M21. XLM21.

In its response to RAI B.2.9-2, 8.2.9-2, dated July 24, 2008, the applicant applicant stated that for the pumppump parameters, parameters, although although the Unit 1 diesel driven driven fire pump and the Unit 2 diesel driven standby air air compressor compressor engines do not have installed instrumentation for all the parameters installed instrumentation parameters identified, the identified, the engines engines are provided provided with coolant temperature temperature indications that permit monitoring monitoring and trending of the pump's function. The applicant applicant further explained explained that the effectiveness effectiveness of the cooling cooling systems can be related related to the installed engine temperature temperature indication indication and therefore therefore is not an exception exception to GALL Report Section XLM21, XI.M21, "Closed-Cycle Cooling Water System." Additionally, the applicant explained explained that the parameters parameters to be monitored monitored and trended with respect to the the closed-cycle closed-cycle cooling water pumps (system flow, discharge pressure, and suction pressure), are a recommendation recommendation of Revision 1 to EPRI 107396, which is now renumbered renumbered as EPRI 1007820, 1007820, "Closed-Cooling Water Chemistry Guideline, Revision 1," 1," which does not require installation installation of instrumentation parameters are available instrumentation if other parameters available to monitor system performance. The applicant applicant identified that the Closed-Cycle Closed-Cycle Cooling Water System System Program in LRA Section B.2.9, 8.2.9, was was prepared using the EPRI 1007820 1007820 as referenced.

referenced. Finally, the applicant explained that with the the hand-held temperature use of hand-held temperature instrumentation instrumentation along with the installed instrumentation, instrumentation, system performance degradation performance degradation will be monitored and trended as identified identified in the Program Enhancements.

The staff reviewed the applicant's applicant's response response and finds that it adequately adequately explained how how thethe enhancements to the Closed-Cycle proposed enhancements Closed-Cycle Cooling Water System in LRA Section 8.2.9 B.2.9 areare consistent with the program program in the GALL Report XLM21. XI.M21. The applicant applicant adequately explained that by using installed monitoring monitoring instrumentation instrumentation along with hand-held hand-held instrumentation, instrumentation, the the recommendations of both, XI.M21 recommendations XLM21 and EPRI1007820 EPRI 1007820 are met and adequate monitoring will exist to confirm that the Closed-Cycle Closed-Cycle Cooling Water System AMP is effective effective in managing managing aging effects. Therefore, Therefore, the staff's B.2.9-2 is resolved.

concern in RAI 8.2.9-2 B.2.9-3, dated In RAI 8.2.9-3, dated MayMay 22, 2008, the staff similarly requested requested that the applicant explain explain whether whether closed-cycle closed-cycle CWS heat exchangers exchangers for the Unit 1 diesel driven fire pump and the Unit 2 diesel diesel driven standby air compressor, added added to the scope of this AMP are subject to the heat exchanger exchanger parameter monitoring identified identified above, and ifif not, why this is not identified as an an exception exception to the recommendations recommendations of the recommendations recommendations in GALL XI.M21.

XLM21.

In its response to RAI B.2.9-3, dated July RAI 8.2.9-3, July 24, 2008, the applicant stated that for the heat heat exchanger exchanger parameters, althoughalthough the Unit 1 diesel driven fire pump and the Unit 2 diesel driven standby standby air compressor engines instrumentation for all the parameters engines do not have installed instrumentation parameters identified, the engines engines are provided with coolant temperature temperature indications that permit monitoring monitoring and trending of the heat exchanger's exchanger's function. The applicant further explained explained that the the effectiveness effectiveness of the cooling systems can be related to the installed engine temperature temperature indication and therefore is not an exception to GALL Report Report Section Section XLM21 '. Closed-Cycle XI.M21, Closed-Cycle 3-116 3-116

Cooling Water Water System. Additionally, the applicant applicant explained explained that the parameters parameters to be be monitored monitored and trended with respectrespect to the closed-cycle closed-cycle cooling water heat exchangers exchangers (temperature, flow, and differential differential pressure), are a recommendation recommendation of Revision Revision 1 to EPRI

107396, 107396, which which is now renumbered as EPRI 1007820, 1007820, "Closed-Cooling "Closed-Cooling Water Water Chemistry Guideline, Revision 1," and does not require installation installation of instrumentation instrumentation if other parameters parameters are available to monitor monitor system performance. The applicant identified performance. identified that the Closed-Cycle Closed-Cycle Cooling Water System ProgramProgram in LRA Section Section B.2.9, was prepared 1007820 prepared using the EPRI 1007820 as referenced. Finally, the applicant applicant explained explained that with the use of hand-held hand-held temperature temperature instrumentation along instrumentation along with the installed instrumentation, instrumentation, system performance performance degradation degradation will be monitored monitored and trended as identified in the Program Enhancements.

Enhancements.

The staff reviewed reviewed the applicant's response response and finds that it adequately explained how the adequately explained the proposed enhancements enhancements to the Closed-Cycle Cooling Water Water System System in LRA Section B.2.9 are consistent consistent with the program in the GALL Report XLM21. XI.M21. The applicant adequately explained applicant adequately explained installed monitoring instrumentation that by using installed hand-held instrumentation, instrumentation along with hand-held instrumentation, the the recommendations of both, XLM21 recommendations XI.M21 and EPRI 10078201007820 are met and adequate adequate monitoring monitoring will exist to confirm confirm that the Closed-Cycle Cooling Water System System AMP is effective managing effective in managing aging effects. Therefore, the staff's concern in RAI B.2.9-3 B.2.9-3 is resolved.

resolved.

Enhancement 3. The applicant applicant also included an enhancement enhancement to the "detection of aging aging effects" program program element of the Closed-Cycle Cooling Water Program that states that the AMP "will be be enhanced enhanced to identify closed-cycle CWS parameters parameters that will be trended to determine determine whether heat exchanger tube fouling or corrosion product heat exchanger buildup exists~"

product buildup exists."

As previously previously stated, the staff reviewed reviewed the applicant's applicant's responses to RAI B.2.9-2 B.2.9-2 and B.2.9-3 and finds that it adequately explained enhancements to the Closed-Cycle explained how the proposed enhancements Closed-Cycle Cooling Cooling Water System in LRA Section B.2.9 are consistent consistent with the program in the GALL Report XI.M21 XLM21 for this program element.

The staff noted applicant's responses to RAI B.2.9-2 and RAI B.2.9-3 are relevant noted that the applicant's relevant to the the evaluation of this enhancement staff's evaluation identification of the enhancement because it is related to the identification the performance monitoring performance parameters associated monitoring parameters associated with the closed-cycle closed-cycle CWS pumps pumps and heat heat exchangers exchangers for the Unit 1 diesel driven fire pump and the Unit 2 diesel driven driven standby air air compressor, added to the scope of this AMP. On the basis that the issues in RAI B.2.9-2 and RAI B.2.9-3 are resolved, the staff finds this acceptable.

acceptable.

Enhancement Enhancement 4. The applicant also included an enhancement enhancement to the "detection of aging effects" program element element of the Closed-Cycle Closed-Cycle Cooling Water Water Program that states that the AMP "will be be enhanced to control performance performance tests and to perform visual inspections at the required required frequency."

freq uency."

Operating Experience. In LRA Section B.2.9, the applicant Operating applicant provided the following operating operating experience evaluation experience evaluation for BVPS:

The Closed-Cycle Closed-Cycle Cooling Cooling Water Water System Program is an existing program program that includes preventive preventive measures measures to manage manage loss of material, material, cracking, andand reduction of heat transfer for passive reduction passive components which make up the closed-cycle cooling water (CCCW) systems.

3-117 3-117

Multiple operating experience experience tools are used to assess, evaluate, evaluate, and improveimprove the management management of passive aging of the CCCW systems. This includes includes Corrective Action Program documents, documents, self assessments, quality assessment assessment audits, latent issues reports, INPO operating operating experience experience documents documents (operating experience messages, Significant Event Reports, Significant Event Notifications, experience Notifications, Significant Significant Operating Operating Experience Reports, etc.), and NRC documents (INs, (INs, Generic Generic Letters, Bulletins, etc.). Corrective Corrective Action Program items or SAP Activity Tracking items will be used to track and document document the site response to any internal internal or external external document which is or may be applicable to BVPS.

A Self Assessment was performed on chemistry chemistry control of closed CWSs CWSs in in March of 2007. There were improvement recommendations were two specific program improvement recommendations which were documented using the Corrective Corrective Action Program and will be tracked in SAP. The program improvements improvements are (1) evaluating the feasibility of aa corrosion couponcoupon monitoring monitoring system and (2) (2) determining determining ifif implementation implementation of a sessile microbiological microbiological monitoring system providesprovides a cost-justified cost-justified benefit.

Including these program recommendations Including recommendations into the Corrective Corrective Action Program and SAP Program will ensure that these potential potential improvements improvements are tracked until itit is determined determined whether or not to implement the proposed proposed changes. The basis basis for either either decision decision will be documented documented in the corrective report investigation investigation summary. The integrity integrity of the CCCW Systems is ensuredensured by monitoring monitoring and maintaining maintaining water chemistry acceptable limits, and by chemistry parameters within acceptable inspecting the physical inspecting physical condition of system piping. Unexpected Unexpected CCCW System addressed through the Corrective conditions are addressed Corrective Action Program for resolution and to provide provide documented documented guidance guidance for similar, future events (operating (operating experience).).

experience BVPS evaluated for applicability an INPO operating experience experience message message regarding unexpected regarding unexpected temperature control valve bolting corrosion in the the Emergency Emergency Diesel Generator Generator (EDG)

(EDG) Jacket Water System. The EDG at the the affected affected plant was built by the same manufacturer manufacturer as the BVPS Unit 2 EDGs.

BVPS was also notified via the EDG owners group (Fairbanks-Morse),

(Fairbanks-Morse), of which BVPS is an affiliated affiliated member. BVPS documented documented the assessment assessment of this this industry operating experience industry operating experience event in the Corrective Action Program, which which provides provides tracking, documentation documentation and an engineering engineering basis for why no specific specific actions actions were needed.

The Closed Cycle Cooling Water System System Program has been effectiveeffective at at managing aging effects for passive components which make make up the closed cooling water systems. Use of corrective corrective action process to identify, track, and document applicable operating document applicable improvement operating experience events, and improvement recommendations from self-assessments, recommendations self-assessments, latent issues reports, and quality assessment assessment audits audits provide reasonable reasonable assurance that the CCCW program, program, as as enhanced, enhanced, will effectively manage effectively manage passive component component loss of material, cracking, cracking, and reduction reduction of heat transfer.

The staff reviewed LRA Section B.2.9 and noted noted that the applicant has identified identified examples examples of operating experience.

operating experience. The staff staff also noted that although unexpected unexpected temperature temperature control valve 3-118 3-118

bolting corrosion corrosion in the EDG jacket water water system was included in the experience, experience, no bolting waswas managed by the Closed-Cycle managed Closed-Cycle Cooling Water System Program.

In RAI B.2.9-4, dated dated May 22, 2008, the staff requested that the applicant explain where this this bolting was described described in the LRA and which program managed managed its aging effects.

In its response to RAI B.2.9-4, dated July 24,2008, 24, 2008, the applicant stated that the EDG jacket water system bolting bolting is internal internal bolting which is not part of the valve body and; therefore, not subject to aging management management in accordance accordance with 10 CFR 54.21(a)(1 54.21 (a)(1 )(i). The applicant applicant further further explained explained that this specific specific example example of operating experience experience demonstrated demonstrated an instance wherewhere operating experience industry operating experience was assessed. The applicant applicant further stated that this example example confirms that the program will be effectiveeffective at managing managing aging effects for the period period of extended extended because it shows that the program evaluates operation, because evaluates industry operating experience.

industry operating The staff reviewed reviewed the applicant's response and finds that it adequately adequately explained that thisthis experience was not meant to be related to the Closed-Cycle specific example of operating experience Closed-Cycle Cooling Water System Program alone, but was included to demonstrate demonstrate the breadth and scope of the operating experience experience researched researched because because it included included industry industry operating experience as as well as plant-specific plant-specific operating operating experience.

experience. On the basis that the temperature temperature control valve valve internal bolting does not support support the valve's pressure boundary boundary intended intended function, the staff staff agrees agrees that the bolting's aging management management is not within the scope of the Closed-Cycle Cooling Closed-Cycle Cooling Water System Program. Therefore, the staff's staffs concern in RAI B.2.9-4 B.2.9-4 is resolved.

resolved.

UFSAR Supplement. The applicant provided Closed-Cycle provided the UFSAR supplement for the Closed-Cycle Cooling Water System Program Water System Program in LRA Section A. 1.9.

A.1.9. The staff reviewed reviewed this Section Section and determines determines that the information in the UFSAR UFSAR supplement provides an adequate adequate summary description description of the program consistent with the guidance guidance found in the SRP-LR.

The staff reviewed the commitment commitment list in LRA Section enhancements Section A, and confirms that the enhancements for Unit 1 are captured captured in LRA Table A4.1 (Commitment (Commitment No.2) No. 2) and for Unit 2 in Table A5.1 (Commitment No.2).

(Commitment No. 2).

The staff determines determines that the information information in the UFSAR Supplement Supplement provides an adequateadequate summary summary description of the program as required required by 10 CFR 54.21(d).

Conclusion. The staff reviewed reviewed the information provided in LRA Section information provided Section B.2.9 and additional information provided information provided by the applicant by letter dated July 24, 2008. Based on its review, the the staff's acceptance acceptance of the applicant's applicant's Closed-Cooling Water System Program will adequately adequately manage the aging effects so that the intended functions will be maintained maintained consistent with the the CLB for the period of extended operation, CLB for the period of extended operation, as required as required by 10 CFR 54.21(a)(3). The staff also reviewed reviewed the UFSAR supplement supplement for this AMP and finds that itit provides provides an adequate summary description description of the program, program, as required by 10 CFR 54.21 54.21(d).

(d).

3.0.3.2.5 3.0.3.2.5 Fire Protection Program Summary Summary of Technical Information Information in the Application. In LRA Section B.2.16, the applicant applicant described the Fire Protection Program as an existing program that is consistent with GALL existing program Report Report AMP XI.M26, "Fire Protection," with enhancementsenhancements and an exception. The applicant applicant stated that this program program is a condition monitoring performance monitoring monitoring and performance monitoring program, program, 3-119 3-119

comprised of tests and inspections that follow the applicable comprised applicable National Fire Protection Protection Association recommendations. The Fire Protection Program manages Association (NFPA) recommendations. manages the aging effects effects barrier penetration on fire barrier penetration seals; fire barrier walls, ceilings and floors; fire wraps and fire rated doors (automatic and manual) that perform aa CLB fire barrier intended function; diesel engine-driven fire pump fuel oil supply line; and Halon driven Halon and carbon dioxide fire suppression suppression systems.

Evaluation. The staff reviewed those portions Staff Evaluation. portions of the applicant's Program applicant's Fire Protection Program that the applicant claimed consistency consistency with GALL AMP XI.M26 and found they are consistent with this GALL AMP. The staff also confirmed confirmed that the plant program contains all of the the referenced GALL elements of the referenced GALL program and the conditions conditions at the plant are bounded bounded by the the conditions for which the GALL GALL Report is evaluated.

evaluated. The staff conducted onsite interviews interviews with the applicant's applicant's technical technical staff to confirm confirm these results.

The staff finds the applicant's Fire Protection acceptable because it conforms to the Protection Program acceptable the recommended recommended GALL AMP XI.M26, with the enhancements enhancements and an exception exception as discussed below.

In comparing comparing the elements elements in the applicant's applicant's Fire Protection Protection Program Program to GALL AMP XI.M.26, the the staff found that the applicant has taken enhancements enhancements as follows:

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

• • Enhance the inspection guidance guidance to include details details about fire barrier degradation.

degradation.

The staff reviewed the enhancements enhancements and compared the changes changes with the GALLGALL AMP XI.M26 XI.M26 recommendations recommendations for the enhanced enhanced elements. The staff determined determined that implementation of implementation these enhancements enhancements will make the applicant'sapplicant's Fire Protection Protection program program consistent with the GALL AMP XI.M26.

XI.M26. On this basis, the staff finds the enhancements enhancements acceptable.

In LRA Section Section B.2.16, the applicant stated that its Fire Protection Program is consistent with the GALL AMP Xl. M26, however, the applicant XI. M26, applicant claimed an exception exception to the "parameters monitored/inspected" element regarding monitoredlinspected" regarding frequency of functional functional testing for Halon and carbon dioxide dioxide systems. The applicant applicant took this exception because itit conducts exception because conducts the functional tests onceonce every 18 months, which is less frequent than the GALL AMP XI.M26 guideline of at least one every one test for the detection of aging degradation degradation every 6 months. The applicant also performs the the Halon and carbon dioxide system inspections 18-month intervals. However, to ensure the inspections at 18-month the optimum optimum integrity integrity of the in-scope Halon and carbon dioxide dioxide systems, the applicant will inspect each each system at least once every 6 months during during the period of extended extended operation.

operation.

The staff reviewed UFSAR Sections Sections 9.10.4 9.10.4 (Unit 1) and 9.5.1.7.4 (Unit (Unit 2) for CO C022 and Halon Halon systems systems to determine determine if if the CLB specified specified any frequency of inspections. The staff found that the the UFSAR only states that in-servicein-service inspection inspection and testing will be periodically periodically performed. Since the CLB does does not specify any frequency for inspections, the staff determined determined that additional information was required to complete the review.

In RAI B.2.16-3, dated May 22, 2008, the staff requested May 22,2008, requested that the applicant applicant provide the bases bases different inspection for using a different inspection frequency frequency than the recommended recommended GALL AMP XI.M26 XI.M26 frequency of once every six months.

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In its response to RAI B.2.16-3, dated July 24,2008,24, 2008, the applicant stated that the UFSAR UFSAR for Units 1 and 22 described described the testing and inspection of the fire protection protection system as conducted in conducted in accordance accordance with BVPS administrative administrative procedures. The applicant further stated that plant operating experience operating experience indicates that the 18-month 18-month testing frequency frequency is adequate to provide provide assurance that the systems will continue to perform their intended functions during the period of extended operation.

reviewed the applicant The staff reviewed applicant response and noted that the applicant referenced referenced the BVPS BVPS Administrative Procedures; Procedures; which is where the applicant applicant defines the current licensing basis basis testing frequencies. The staff reviewed reviewed the plant operating experience experience and noted noted that there was was no age related degradation degradation identified Halon and carbon dioxide identified for the Halon dioxide systems. On the basis basis that the applicant is performing performing functional tests in accordance accordance with its current current licensing licensing basis, and conducts visual inspections once every six months, and based on the plant operating operating experience, the staff finds that these inspection experience, inspection and testing frequencies frequencies are adequate to ensure the system maintains its function and finds the exceptionexception acceptable.

The above above exception exception also implied that the applicant applicant will enhance Protection Program enhance the Fire Protection Program to to change frequency of Halon change the frequency Halon and carbon carbon dioxide system inspections inspections from once every 18 months to once every six months. However, the applicant enhancement for applicant has not identified an enhancement this change nor made made a commitment in the application.

application.

The staff issued RAI B.2.16-1, B.2.16-1, dated May 22, 2008, requesting requesting that the applicant justify why this this enhancement enhancement has not been identified in LRA Section Section B 2.16.

response to RAI 8;2.16-1, In its response B.2.16-1, dated dated July 24,2008, 24, 2008, the applicant stated that this enhancement enhancement identified in LRA Section B.2.16, Table A.4-1 (Item 7) and Table is identified Table A.5-1 (Item (Item 8). However, the the determined that the applicant's wording of the enhancement staff determined enhancement and the commitment commitment are too too general in that they do not specifically specifically state that the Fire Protection Program will be enhanced enhanced to to change frequency to once every six months. Therefore, change the inspection frequency Therefore, the staff requested the the applicant applicant via conference conference call dated dated November 17, 2008, to be more specific in the enhancement enhancement and the commitment.

In its letter letter dated December December 11, 11, 2008, in response to the follow-up RAI, the applicant modified modified Commitment No.7 Section B.2.16, Commitment No. 7 in Table Table A.4-1 and Commitment Commitment No.8 No. 8 in Table A.5-1 to to clarify that the inspection frequency frequency of Halon and carbon dioxide systems will be changed changed to at at least once every six months.

The staff reviewed the applicant response and the changes to the commitment commitment list; and finds the the response acceptable acceptable based on revision to the commitment words to specifically include change include change in inspection inspection frequency of Halon Halon and carbon dioxide systems to once every six months.

Operatingq Experience. The staff reviewed Operating applicant's operating reviewed the applicant's experience described operating experience described in the the interviewed the applicant's LRA and interviewed applicant's technical technical personnel to confirm that the plant-specific plant-specific operating experience did not reveal any aging effects not bounded operating experience bounded by the GALL Report. The The staff also confirmed confirmed that the applicant has reviewed applicable applicable aging aging effects and industry and plant-specific plant-specific operating operating experience experience and are evaluated evaluated in the GALL Report. In addition, the staff staff confirmed that the applicant confirmed applicant has addressed operating experience identified operating experience identified after issuance issuance of the the GALL Report.

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The staff also reviewed The reviewed the the applicant's "operating "operating experience" discussion provided in in the license license basis document for the Fire Protection Program. Examples renewal basis Examples of operating operating experience experience involve missing or damaged fire seals on fire doors, roll-up doors, shake spaces, and wall penetrations which were identified during 2001-2006. Discrepancies penetrations Discrepancies in fire barrier wrappings wrappings were detected by the applicant during periodic surveillances in 2003. The staff reviewed a a sample of condition reports and confirmed that the applicant had identified age-related degradation of fire protection protection components and implemented implemented appropriate appropriate corrective actions.

Protection Program, The staff finds that the applicant's Fire Protection Program, with the corrective corrective actions actions discussed in the LRA, has been effective effective in identifying, identifying, monitoring, monitoring, and correcting the effects of age related degradation in fire protection systems and can be expected to ensure that the the systems and components within the scope of this program will continue to perform their intended functions, consistent intended consistent with the CLB for the period of extended operation. operation.

UFSAR Supplement. The applicant provided provided the UFSAR supplement supplement for the Fire Protection Protection Program in LRA Section A A1.16.

1.16. The staff verified that the UFSAR supplement supplement summary description for the Fire Protection description Protection Program Program conformed conformed to the staff's recommended recommended UFSAR supplement supplement for these types of programs described in SRP-LR Table 3.3-2. The staff determined determined that the information information in the UFSAR supplement is not sufficiently comprehensive. The UFSAR supplement supplement states that the program manages manages the aging effects; however, itit does not state how itit manages manages the aging effects.

SRP-LR Section 3.3.2.4, FSAR supplement, summary description supplement, states that the summary description of the the programs and activities managing the effects activities for managing effects of aging for the period of extended operation operation in the FSAR supplement supplement should be sufficiently comprehensive comprehensive such that later changes can be be controlled in by 10 10 CFR 50.59. The description description should contain information associated associated with the the bases for determining determining that aging effects managed during the period effects will be managed period of extended extended operation.

operation.

In RAI B.2.16-2, dated May 22, 2008, the staff requested requested that the applicant applicant provide a more more comprehensive UFSAR comprehensive UFSAR supplement summarysummary for the Fire Protection Protection Program.

In its response response to to RAI B.2.16-2, B.2.16-2, dated dated July 24, 2008, the applicant applicant revised revised the UFSAR UFSAR summary description description to include additional include additional detail on how the program manages aging program manages aging effects, such as as periodic inspections periodic inspections of fire barriers, barriers, operational operational testing testing of diesel-engine diesel-engine driven driven fire pump, and and functional functional testing and inspection inspection of Halon Halon and carbon carbon dioxide dioxide systems.

The staff reviewed the revised revised UFSAR UFSAR supplement supplement summary summary descriptions descriptions and and finds that the the revised UFSAR supplement description for the Fire Protection Program conforms to supplement summary description the staff's recommended UFSAR staff's recommended UFSAR supplement supplement for the Fire Protection Protection Program described described in SRP-LR Table 3.3-2. The staff reviewed the commitment SRP-LR commitment list in LRA Section A and and confirmed confirmed that the enhancements enhancements for Unit 1 are are captured captured in in Table Table A4.1 (Commitment (Commitment No. 7) and for Unit No.7) Unit 2 in Table in Table 5.1 5.1 (Commitment (Commitment No.8).No. 8).

Based Based on this review, the staff finds that that the FSAR FSAR Supplement Supplement Section Section A. 1.16 provides A.1.16 provides an an acceptable acceptable FSAR FSAR supplement supplement summary summary description description of the applicant's applicant's Fire Fire Protection Protection Program.

Program.

Therefore, Therefore, the staff's concern concern described described in RAI RAI B.2.16-2 B.2.16-2 is resolved.

resolved.

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Conclusion. The staff reviewed Conclusion. reviewed the information provided in LRA Section Section B.2.16 B.2.16 and additional information information provided by the applicant by letters dated July 24, 2008 and December 11, 11, 2008.

Based on its review, the staff finds the applicant's applicant's Fire Protection Protection Program acceptable acceptable because because it is consistent with the GALLGALL Report with enhancements enhancements and exception, exception, and the plant plant is bounded by the conditions set forth in the GALL Report for this AMP. The staff also finds that the Fire Protection Protection Program Program will adequately adequately manage manage the aging effects so that the intended functions will be maintained maintained consistent consistent with the CLB for the period of extended extended operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed reviewed the revised UFSAR supplement revised UFSAR supplement for this AMP and finds that it provides provides adequate summary description an adequate description of the program, program, as required required by 10 CFR 54.21(d).

54.21 (d).

3.0.3.2.6 Fire Water System Program Program Summary of Technical Summary Information in the Application.

Technical Information Application. In LRA Section B.2.17, the applicant applicant described the Fire Water System Program as an existing program that is consistent with GALL described Report Report AMP XI,M27, XI.M27, "Fire Water Water System," with enhancements.

enhancements. The applicant stated that program program activities activities include periodic periodic inspection inspection and hydro-testing hydro-testing of hydrants and hose stations, sprinkler head head inspections, and system flow tests.

Staff Evaluation.

Evaluation. The staff reviewed reviewed those portions of the applicant's Fire Water System Program that the applicant applicant claimed consistency with GALL AMP XI.M27 XI.M27 and found they are are consistent consistent with this GALL AMP. The staff also confirmed confirmed that the plant program contains all of the elements of the referenced referenced GALL programprogram and the conditions conditions at the plant are bounded by the conditions conditions for which the GALL Report is evaluated. The staff conducted conducted onsite interviews interviews with the applicant's technical staff to confirm these results.

The staff finds the applicant's Fire Water System Program Program acceptable acceptable because because it conforms to to the recommended recommended GALL AMP XI.M27, with the enhancements enhancements as discussed discussed below.

In comparing the elements in the applicant's applicant's AMP to GALL AMP XI.M27, the staff found that the the applicant applicant has taken enhancements taken enhancements as follows:

"

• Added Added a program program requirement in the "Parameters monitored/inspected" to perform flow test or inspection inspection of all accessible fire water headers headers

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

The staff reviewed the enhancements enhancements and compared the changes with the GALL AMP XI,M27 XI.M27 recommendations recommendations for the enhanced enhanced elements. The staff determined determined that implementation implementation of these enhancements enhancements will make make the applicant's applicant's Fire Water System Program consistent consistent with the the GALL GALL AMP XI.M27.

XI,M27. On this basis, the staff finds the enhancements acceptable.

enhancements acceptable.

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The applicant also included an enhancement enhancement in the "detection of aging effects" element that states enhancement described states that the program enhancement described under the "scope of program" element is necessary. However, there is no enhancement enhancement identified identified in the "scope of program" element.

In RAI 8.2.17-1, B.2.17-1, dated May 22, 2008, the staff requested requested that the applicant applicant clarify this this discrepancy.

In its response to RAI 8.2.17-1, B.2.17-1, dated July 24, 2008, the applicant stated that the reference to "scope program" element was an error and that there is no-enhancement "scope ofof program" element was an error and that there is no enhancement in the "scope of program" element.

The subject sentence sentence should have referenced referenced the "parameters monitored/inspected" monitored/inspected" element.

th The staff noted noted that the applicant has revised LRA Section B.2.17, 5 th paragraph, under 8.2.17, 5 under subheading subheading "Detection of Aging Effects" as follows:

Also, the program program enhancement enhancement described described under under the Parameters Parameters Monito~ed/lnspected Monitored/Inspected program element necessary for consistency element is necessary consistency with this this program element.

Based on its review, the staff finds the applicant's 8ased applicant's response to RAI 8.2.17-1 B.2.17-1 acceptable because because the applicant has revised LRA Section 8.2.17 B.2.17 to make the enhancement enhancement wording consistent with this program element. Therefore, the staffs concern concern described in RAI B.2.17-1 8.2.17-1 is resolved.

During the review of the Fire Water System Program basis document, the staff noted noted that the the applicant applicant states that the Unit 1 fire hydrant gasket inspection is performed gasket inspection performed every 18 months, compared to the GALL GALL AMP recommendation recommendation of 12 months. However, the staff determined determined that the applicant applicant did not include include this as an exception exception in the LRA because gaskets gaskets were considered consumables and will be replaced as necessary.

In RAI 8.2.17-2, B.2.1 7-2, dated dated May 22, 2008, the staff requested requested that the applicant applicant justify the basis for this excluding the 18 month Unit 1 fire hydrant gasket inspection as an exception gasket inspection exception to the 12 recommendation of the GALL month recommendation GALL AMP.

In its response to RAI 8.2.17-2, B.2.17-2, dated July 24, 2008, the applicant applicant stated that based on ANSI B31.1 831.1 and the ASME Code Boiler 80iler and Pressure Vessel Code, Section III, the subcomponents subcomponents of pressure retaining components pressure retaining components are not pressure pressure retaining parts. Therefore, these subcomponents are not relied on to form a pressure-retaining SUbcomponents pressure-retaining function and are not subject to an AMR. The applicant further stated that althoughalthough these gaskets perform perform no license renewal intended function, their condition is monitored intended monitored by the Fire Water System Program Program and they are replaced as necessary.

replaced The staff reviewed reviewed the response and noted that the condition of the fire hydrant gaskets gaskets is monitored monitored by the Fire Water System Program and the gaskets are replaced replaced as necessary.

However, the GALL AMP recommended recommended frequency for these gaskets gaskets is once a year whereas whereas the applicant performs these inspections inspections once every 18 18 months. The staff determines the determines that the applicant's response response does not address why this is not an exception. Therefore, the staff issued exception. Therefore, issued September 3, 2008, requesting a follow-up RAI by letter dated September requesting that the applicant applicant justify the basis basis for this excluding excluding the 18 month Unit 1 fire hydrant gasketgasket inspection exception to the 12 inspection as an exception month recommendation recommendation of the GALL AMP.

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In its In its letter dated October 3, 2008, in response response to to the follow-up RAI the applicant stated that because the gaskets because gaskets are considered consumables consumables which are replaced on condition following following inspection, the inspection, the applicant diddid not not consider the difference in in gasket inspection frequency to be be an exception. Operating experience has has shown that the 18 18 month frequency is adequate to provide provide reasonable assurance that the fire hydrants can perform their intended function.

SRP-LR Table 2.1-3 provides specific staff guidance on screening of consumables.

The SRP-LR states that gaskets are subcomponents and are not relied on for pressure boundary and could be excluded from aging management review.

boundary On the basis that the gaskets perform no license renewal function, are replaced on condition condition inspection, and operating experience following inspection, experience has shown that the frequency is is adequate adequate to maintain component maintain component intended intended function, the staff finds that the difference difference in inspection inspection frequency between the GALL AMP and the applicant program does not need to be an exception.

Therefore, the staff finds the response acceptable and considers the issue closed.

During the review of the Fire Water System Program basis document, the staff noted that the the applicant stated that fire hydrant hose hydraulic tests are performed performed at frequencies different different recommended frequency of once every 12 months. However, the applicant than the GALL AMP recommended did not include this as an exception in the LRA because because hoses were considered considered consumables consumables and would be replaced as necessary.

In RAI B.2.17-3, dated May 22,2008, 22, 2008, the staff requested that the applicant applicant justify why this this frequency difference difference is not an exception.

exception.

In its response to RAI B.2.17-3, B.2.17-3, dated July 24, 2008, the applicant stated that fire hoses hoses are consumables, and are routinelyroutinely tested, inspected, and replaced replaced when necessary. Criteria for inspection and replacement are based based on accepted accepted industry standards (e.g., NFPA-1962). The industry standards The applicant applicant further stated that while these consumables consumables are within the scope of license renewal, they do not require an AMR.

The staff reviewed reviewed the applicant's response and acknowledgesacknowledges that the the condition of the fire fire hydrant hoses is monitored monitored by the Fire Water System Program Program and the hoses are replaced replaced as as necessary. However, the GALL GALL AMP recommended recommended frequency for hydraulic hydraulic testing of hoses is once once aa year, whereas the applicant applicant performs performs these tests at various frequencies frequencies and its response response to the RAI RAI does does not address address why this test frequency frequency is not an an exception. Based Based on its review, the staff finds the applicant's applicant's response response not acceptable.

acceptable. Therefore, Therefore, the staff issued a follow-up follow-up RAI by letter dated September September 3, 2008, requesting that the applicant justify applicant justify why this is not an exception.

exception.

In its letter dated October 3, 2008, in response to the follow-up October 3,2008, RAI, the applicant follow-up RAI, applicant responded that hoses hoses are considered consumable items which are replaced considered consumable replaced on condition condition following following inspections.

inspections. Since Since they areare not subject subject to aging management management review, the difference difference in frequency frequency was not considered an exception.

considered an exception.

SRP-LR SRP-LR TableTable 2.1-3 2.1-3 provides provides specific specific staff guidance guidance on on screening screening of consumables.

consumables. The The SRP-LR SRP-LR states states that for for fire hoses are are typically replaced based typically replaced based on performance performance or or condition condition monitoring monitoring and and may may bebe excluded excluded on a plant plant from from aging management management review. However, the the standards standards thatthat are relied upon upon for thethe replacement replacement should be be part of the methodology methodology 3-125 3-125

description.

description. The staff reviewed LRA LRA Section 2.1.2.4.3 that explains explains/thethe applicant's methodology applicant's methodology for treatment treatment of consumables such as fire hoses, and states that criteria criteria for inspection and replacement are based on accepted replacement accepted industry standards standards (e.g., Branch Technical Technical Position BTP-APCSB 9.5-1, NFPA-1 0 for fire extinguishers, 9.5-1, NFPA-10 extinguishers, and NFPA-1 NFPA-1962 962 for fire hoses. On the basisbasis that the applicant has provided provided the criteria for replacement of fire hoses hoses in accordance accordance with the the guidance in SRP-LR Table 2.1-3, the staff concurs staff guidance concurs that fire hoses are consumables and therefore, finds that the difference difference in inspection frequency between the GALL GALL AMP and the the applicant program does does not need to be an exception.

exception. The staff finds the applicant response response to to be acceptable acceptable and considers the issue closed.

Operating Experience.

Operating Experience. The staff reviewed reviewed the operating operating experience experience provided provided in the LRA and in in the applicant's operating experience basis document document and interviewed the applicant's interviewed applicant's technical personnel to confirm that the plant-specific personnel plant-specific operating operating experience experience did not reveal any aging effects effects not bounded by the GALL Report. The staff also confirmed confirmed that applicable aging effects effects and industry and plant-specific industry plant-specific operating experience reviewed by the applicant experience have been reviewed applicant and are evaluated evaluated in the GALL GALL Report. Furthermore, the staff confirmed confirmed that the applicant has has addressed experience identified addressed operating experience identified after the issuance issuance of the GALL GALL Report.

The staff also reviewed the applicant's applicant's "operating experience" discussion discussion in the license license renewal basis basis document document for the Fire Water System Program. The staff noted that several corrective several corrective reports were generated generated to address pinhole leaks in fire protection protection piping. The cause of the .Ieaks leaks was identified identified as loss of material material due to MIC. In Corrective Report 05-3940, the applicant applicant determined determined that the chemical treatment of the piping did not eliminate eliminate MIC already established in the piping. The applicant applicant confirmed confirmed by UT inspections that areas areas in the piping system had a wall thickness thickness loss of 50% or more.

In RAI B.2.17 B.2.17-4,

-4, dated dated May 22, 2008, that staff requested requested that the applicant applicant identify what what preventive measures have been taken to address this issue and whether those measures were adequate.

adequate.

In its response response to RAI B.2.17-4, dated July July 24, 2008, the applicant stated stated that the 2005 condition condition report indicates that further chemical treatment at that time would not have eliminated the MIC MIC in the piping welds. Because Because of the large number of potentially susceptible susceptible welds in the piping, piping, the applicant applicant replaced the entire length of affected affected pipe. The applicant also stated that continuing continuing chemical treatments, testing, and inspection inspection of the new pipe provide reasonable reasonable assurance assurance that MIC will be adequately adequately managed managed prior to loss of intended function.

The applicant also stated that testing of the fire water system is performed performed in accordance accordance with applicable applicable NFPANFPA codes and standards, including requirements associated including testing requirements associated with the fire fire suppression suppression water system, spray and sprinkler sprinkler system, and fire hose stations. The fire water systems are normally normally maintained at required operating pressure pressure and monitored monitored such that loss of system pressure is immediately immediately detected and corrective corrective actions actions initiated. The applicant explained that ultrasonic explained ultrasonic tests are capable of effectively evaluating evaluating pipe wall thickness inner thickness and inner diameter. The applicant further stated that continuingcontinuing chemical treatments, testing, continuouscontinuous pressure pressure monitoring, inspections (including UT), incorporation inspections (including incorporation of site-specific site-specific operating operating experience, and evaluation evaluation of degradation degradation using the Corrective Corrective Action Program, provide provide reasonable reasonable assurance that the fire water system's intended intended functions will be maintained for the the extended operation.

period of extended 3-126

Based on its review, the staff finds that applicant's response to RAI B.2.17 B.2.17-4 acceptable

-4 acceptable because the applicant has verified that chemical treatment would not have eliminated eliminated the MICMIC established in the piping welds. The staff further finds that the applicant that was already established has applicant has affected pipe. The staff concludes appropriate corrective action to replace the affected taken appropriate concludes that chemical treatment treatment will ensure ensure that MIC MIC is minimized in the new pipe and that periodic periodic testing, continuous pressure monitoring, inspections inspections and UT will provide provide assurance assurance that the Fire WaterWater System Program Program will adequately adequately manage Therefore, the staffs concern manage aging. Therefore, concern described described in B.2.17-4 is resolved.

RAI 6.2.17-4 The staff finds that the applicant's Fire Water System Program Program has been been effective identifying, effective in identifying, monitoring, and correcting the effects of age related monitoring, degradation related degradation in fire water water systems and can be expected to ensure that the systems and components components within the scope of this program program will continue to perform their intended continue intended functions consistent consistent with the CLB for the period of extended operation.

operation.

UFSAR Supplement. The applicant supplement for the Fire Water System applicant provided the UFSAR supplement Section A.1.17. The staff verified that the UFSAR Program in LRA Section UFSAR supplement summary recommended UFSAR supplement conforms to the staffs recommended description for this AMP conforms described in supplement described SRP-LR Table 3.3-2. The staff determines that the information information in the UFSAR supplement supplement provides adequate summary provides an adequate program consistent with the SRP-LR.

summary description of the program The staff reviewed commitment list in LRA Section A, and confirms that the enhancements reviewed the commitment enhancements for Unit 1 are captured in Table A4.1 (Commitment Number 8) and for Unit 2 in Table (Commitment Number A5.1, Table A5.1, (Commitment Number 9).

Based on its review, the staff finds that FSAR Supplement A. 1.17 provides an Supplement Section A.1.17 Supplement summary acceptable FSAR Supplement acceptable applicant's Fire Water System summary description of the applicant's Program.

Program.

Conclusion. The staff reviewed Conclusion. information provided in LRA Section reviewed the information Section B.2.16 and additional information provided information provided by the applicant applicant by letters dated July 24 and October 3, 2008. Based on its October review, the staff finds the applicant's acceptable because Program acceptable applicant's Fire Water System Program because it is enhancements, and the plant is bounded by the conditions consistent with the GALL Report with enhancements, conditions GALL Report for this AMP. The staff finds that the program will adequately the GALL set forth in the manage the aging effects manage intended functions effects so that the intended maintained consistent with the functions will be maintained the period of extended CLB for the period 54.21(a)(3). The staff also extended operation, as required by 10 CFR 54.21(a)(3).

reviewed the UFSAR reviewed supplement for this AMP and finds that itit provides an adequate UFSAR supplement adequate summary description of the program, description program, as required by 10 CFR 54.21(d).

3.0.3.2.7 Flux Thimble Tube Inspection Program 3.0.3.2.7 Application. In LRA Section B.2.19, the applicant Technical Information in the Application.

Summary of Technical Summary applicant Inspection Program.

described the Flux Thimble Tube Inspection described program will identify loss of material Program. This program due to wear leakage, by monitoring wear prior to leakage, predicting wall thinning in the movable incore monitoring for and predicting incore detector system flux thimble tubes. The program achieves this through the use of periodic NDE NDE determine the tube wall thinning progression. The program extrapolation of data to determine and extrapolation program uses the the extrapolated data to take preemptive extrapolated action to reposition, replace or isolate the affected preemptive action affected thimble thimble intended function.

tube prior to loss of intended 3-127 3-127

Staff Evaluation. In the LRA, the applicant stated that the Flux Thimble Inspection Thimble Tube Inspection Program is an existing existing program program that is consistent with GALL AMP XI.M37, "Flux Thimble Tube Tube Inspection," with an enhancement. The enhancement Inspection," enhancement includes corrective corrective actions actions which would would require removal of a thimble tube from service service if it cannot be inspected inspected over the tube length.

During its audit, the staff reviewed reviewed the applicant's applicant's onsitedocumentation onsite documentation used to support its conclusion that the program conclusion program elements elements are consistent with the elements in the GALL GALL Report.

The staff conducted interviews with the applicant's technical staff to confirm these results.

conducted onsite interviews In comparing the elements elements in the applicant's program, the staff found that that the GALL Report "parameters monitored and inspected" "parameters monitored and inspected" and "detectionand "detection of aging effects" program program elements elements require require a wear limit, but the applicant applicant did not include a full history of the change approval.

In RAI B.2.19-1, March 26, 2008, the staff requested B.2.19-1, March requested that the applicant applicant provide a full history history of the change approval.

In its response to RAI B.2.19-1, B.2.19-1, dated April 25, 2008, the applicantapplicant stated stated that in a memorandum dated dated August 1, 1989, the NRC acknowledged that the flux thimble tube wear NRC acknowledged limits were subject to potential future changes. Further, the applicant stated that since the the original original wear limit calculation calculation was instituted, advancements advancements have have been made on improved eddy current current test methods that decrease uncertainty value, and that a Westinghouse decrease the uncertainty Westinghouse Owners Owners Group program developed to manage the effects of flux thimble tube wear. The applicant program was developed applicant stated that the current wear limit utilizes the wear limit guidance guidance from this Westinghouse Owners Owners Group program.

program.

Based on its review, the staff finds the applicant's response to RAI B.2.19-1 B.2.19-1 acceptable because acceptable because the applicant has adequately adequately explained explained the history of the changechange approval and has verified verified thethe performance of its flux thimble tube inspection program past performance program and the basis for the wear limit limit change. Therefore, the staff's concern described in RAI B.2.19-1 is resolved.

RAI B.2.19-1 In In LRA Section 8.2.19, B.2.19, the applicant stated that an enhancement enhancement to the GALL Report "corrective actions" program element includes corrective "corrective actions" program element includes corrective actions actions which would require removal of a thimble tube from service, if if it cannot be inspected inspected over the tube length. The staff finds this this enhancement acceptable enhancement acceptable because, when implemented,implemented, the Flux Thimble Tube Inspection Inspection Program will be consistent with GALL AMP XI.M37 XI.M37 and will add assurance assurance of adequate of adequate management of aging effects.

management reviewed the operating The staff also reviewed operating experience experience reports, and interviewed interviewed the applicant's applicant's technical staff to confirm that that the plant-specific operating experience did not reveal any the plant-specific operating experience did not reveal any degradation not bounded by industry experience. experience. In In one report, the applicant stated that an elevated wall thinning rate was experiencedexperienced in 2003, but was deemed acceptable acceptable due to to industry experience.

industry However the specific industry experience experience. However experience was not found at the time of the the audit.

In RAI B.2.19-2, March 26, 2008, that staff requested that the applicant provide information on the industry experience experience that led to the .decision.

decision that the elevated thinning rate was acceptable.

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In its response to RAI B.2.19-2, dated April 25, 2008, the applicant applicant stated that the wear wear for thethe two thimble tubes, initially showing elevated elevated wear rates, was projected by Westinghouse Westinghouse to to determine determine the expected timeframe for reaching expected timeframe reaching the program program maximum wear limit. The applicant applicant repositioned the two thimble tubes in a subsequent subsequent RFO, prior to the projected projected wear limit.

Additionally, the applicant supplied the actual wear measurements supported their measurements data, which supported their claim that the projections projections were conservative, conservative, and that the thimble tubes were not at risk of surpassing the maximum surpassing maximum wear limit.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.19-2 B.2.19-2 acceptable acceptable because because the applicant has provided provided an adequate summary of specific industry experience experience supporting supporting its basis for concluding concluding that the wall thinning rate was acceptable. The staff confirms that the the applicant applicant has supplied wear measurement data, has repositioned wear measurement repositioned the two thimble tubes, and has completed completed aa history of projections. Therefore, the staff's staffs concern described described in RAI B.2.19-2 B.2.19-2 is resolved.

UFSAR Supplement. The applicant supplement for the Flux Thimble Tube applicant provided the UFSAR supplement Tube Inspection Program Inspection Program in LRA Section A. 1.19. The staff reviewed this Section A.1.19. Section and determines determines that the information information in the UFSAR UFSAR supplement adequate summary supplement is an adequate description of the program, summary description as required required by 10 CFR 54.21(d).

The applicant committed committed (Commitment (Commitment Nos. 9 (Unit 1) and 10 (Unit (Unit 2)) to implement this this program before before the period of extended extended operation.

operation.

Conclusion. The staff reviewed the information provided in LRA Section B.2.19 and additional information provided by the applicant applicant by letter dated April 25, 2008. Based on its review, the the staff concludes that the applicant has demonstrated demonstrated that effects effects of aging on flux thimble tubes tubes will be adequately adequately managed managed so that the intended intended functions of these components components will be be maintained consistent maintained consistent with the CLB for the period period of extended extended operation, as required by by 10 CFR 54.21(a)(3).

10 3.0.3.2.8 3.0.3.2.8 Fuel Oil Chemistry Chemistry Program Program Summary of Technical Information in the Application.

Technical Information Application. In LRA Section B.2.20, the applicant applicant described described the existing existing Fuel Oil Chemistry Program as consistent, with exceptions Chemistry Program exceptions and enhancements, with GALL AMP XI.M30, XI,M30, "Fuel Oil Chemistry."

The mitigating mitigating and condition-monitoring condition-monitoring Fuel Oil Chemistry Program Program manages manages aging effects of the internal surfaces of oil storage storage tanks and system components components that contain diesel fuel oil. oil.

The program program includes: (a) monitoring to maintain diesel fuel oil quality by contaminant contaminant control control in accordance with ASTM D975, accordance D1 796, D2276 0975, D1796, 02276 and D4057; (b) periodic sampling sampling of fuel oil tank content and new fuel oil shipments for water water and contaminants and draining of any accumulated accumulated water from the tanks; (c) sampling sampling of fuel oil tank content and new fuel oil shipments shipments for sediment, viscosity, and flash point; pOint; and (d)

(d) periodic or conditional conditional visual inspecting inspecting of internal measuring of wall thickness (e.g., UT) of tanks. The One-Time surfaces or measuring One-Time Inspection Inspection Program will verify the effectiveness effectiveness of the Fuel Oil Chemistry Chemistry Program.

Staff Evaluation. In LRA Section B.2.16, the applicant applicant stated that the Fuel Oil Chemistry Program is an existing program that is consistent Program consistent with GALL Report AMP XI,M30, XI.M30, Fuel Oil Chemistry with enhancements Chemistry enhancements and exceptions.

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The staff reviewed reviewed those portions of the applicant's applicant's Fuel Oil Chemistry Chemistry Program Program that the the applicant claimed consistency consistency with GALLGALL AMP XI.M30 and found they are consistent consistent with thisthis GALL AMP. The staff also confirmed that the plant program program contains contains all of the elements elements of thethe referenced GALL program referenced program and the conditions conditions at the plant are bounded by the conditions for which which the GALL Report Report is evaluated.

evaluated. Onsite interviews were also held to confirm these results.

The staff finds the applicant's applicant's Fuel Oil Chemistry Program acceptable because itit conforms acceptable because conforms toto recommended GALL the recommended GALL AMP XI.M30, Fuel Oil Chemistry. The staff's review of the the enhancements exceptions in the AMP that are taken against enhancements of the AMP and exceptions against the program elements in GALL AMP XI.M30XI.M30 are evaluated evaluated in the subsections subsections that follow.

Enhancements. In comparing Enhancements. comparing the elements elements in the applicant's applicant's AMP, the staff found that the the applicant applicant has taken enhancements enhancements as follows:

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

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

As a result of the staff's IP-71002 inspections inspections that occurred occurred during the weeks of June 23 and July 14, 2008, the applicant identified necessary revisions to the LRA which includes identified necessary includes a new program enhancement.

enhancement. The applicant provided the program changes program changes in letter L-08-262 dated, September 8, 2008 which includes includes LRA Amendment Amendment No. 23.

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

occurring.

By letter dated October 2, 2008, the applicant identified dated October identified necessary revisions to the BVPS LRA which includes includes an additional new program enhancement. This letter described described LRA Amendment Amendment 26, resulting from the findings of the staffs staff's IP-710002 inspections that occurred occurred during the the weeks of June 23 and July 14. The following is the staff's staffs evaluation evaluation of the enhancements.

enhancements.

(4) The "Detection of Aging Effects" describe describe that for inaccessible inaccessible tank bottoms, appropriate appropriate NDE techniques will be used to determine tank bottom thickness, if inspections indicate indicate the presence presence of significant corrosion.

corrosion.

The staff reviewed reviewed the enhancements enhancements and compared compared the changes with the GALL AMP XI.M30 XI.M30 recommendations for the enhanced recommendations enhanced elements. The staff determined implementation of determined that implementation these enhancements enhancements will make make the applicant's applicant's Fuel Oil Chemistry program program consistent with the the GALL GALL AMP XI.M30. The applicant adopted adopted the more restrictive requirements restrictive requirements of those fuel oil tanks subject to Technical Specification Specification Requirements to the non-Technical non-Technical Specification fuel oil 3-130 3-130

tanks. Additionally, Additionally, the administrative control requirements in in Technical Specification (TS) (TS) 5.5.9 5.5.9 have been applied for all the fuel oil tanks within the scope of have of the the program.

program. On this basis, the staff finds the enhancements staff enhancements acceptable.

Exception 1. In the LRA, LRA, the applicant identified identified the following exception to the "Scope of Monitored/Inspected," "Monitoring and Trending," and "Acceptance Program," "Parameters Monitoredllnspected,"

program elements in GALL AMP XI.M30:

Criteria" program BVPS does not use ASTM standard 02709. D2709. BVPS BVPS uses ASTM 01796 D1796 versus ASTM D2709 for guidance 02709 guidance on the determination determination of water and sediment contamination. The use D1 796, with an acceptance of ASTM 01796, acceptance criterion for water and sediment content of less less equal to 0.05% is required byBVPS than or equal by BVPS Technical Specification Specification Surveillance Surveillance Requirements.

The staff verified that the implementation implementation of applicant's Fuel Oil Chemistry Chemistry Program, as as implemented relative to the emergency diesel generator implemented generator system, is based on the applicant's applicant's administrative control requirements for diesel fuel oil testing that are provided in Technical administrative Specification (TS) 5.5.9, which requires API gravity or absolute specific Specification specific gravity testing, flash point and viscosity testing, and water and sediment testing of all new, procured fuel oil prior to to adding the new oil inventories inventories to the diesel fuel oil tanks, and API gravity or absolute specific specific gravity testing, flash point and viscosity testing, water and sediment testing, and particulate gravity particulate testing on existing fuel oil inventories inventories in the tanks at least once every 31 days.

In RAI B.2.20-2, the staff asked asked the applicant to provide provide a summary of the evaluation evaluation for the use use of ASTM Standard D1 796 and to identify Standard 01796 identify specific fuel oil tanks whose diesel fuel oil inventories inventories are subject to the TS testing requirements.

requirements.

In its response dated July 24, 2008, 200B, the applicant applicant stated stated that since the use of ASTM D1 796 is 01796 also recommended recommended by NUREG-1801, NUREG-1B01, XI.M30 and has been reviewed be the NRC staff staff therefore therefore no further further evaluation is required. The applicant stated that both standards standards outline test methods for determining water and sediment concentration concentration by centrifuge. Further, the applicantapplicant identified that, the use of ASTMASTM 01796 D1796 is required by BVPS Technical Specifications. Finally, the applicant stated that through the program enhancements enhancements identified identified above, water and sediment sediment testing is applied to all tanks within the scope of the program, program, in addition to just the the safety-related safety-related tanks.

The staff reviewed reviewed the applicant's applicant's response and finds that it adequately adequately explains explains the reasons for for using ASTM D1 796 using ASTM 01796 instead instead of D2709. The 02709. The staff also reviewed reviewed the BVPS Unit 1 and 22 Technical Specifications Specifications 3.8.1, 3.B.1, 3.8.3, 3.B.3, Surveillance Surveillance Bases 3.8.3.3.d, ASTM Bases 3.B.3.3.d, D1796, and ASTM 01796, and ASTM 02709.

D2709. The The Surveillance Surveillance Bases Bases require require ASTM ASTM D179601796 be used to satisfy Surveillance Requirement 3.8.3.3.d Surveillance Requirement 3.B.3.3.d in verifying that the new fuel oil has has water and sediment content content of less less than or equal to 0.05%.

On this basis, the staff staff finds this exception acceptable because exception acceptable adequately explains because it adequately explains that thethe Technical Technical Specification Specification Surveillance Surveillance Requirements Requirements specify specify ASTM ASTM 01796 D1796 and that this ASTM Standard Standard is identified identified in in the TS basesbases 5.5.9, 5.5.9, "Diesel "Oiesel Fuel Fuel Oil Testing Testing Program," and because because the the applicant has clarified applicant has clarified that that it applies the required testing required testing to all all diesel fuel fuel oil tanks tanks within the the scope of of the the program.

program. Therefore, Therefore, the staff's concern concern in in RAI RAI B.2.20-2 B.2.20-2 is resolved.

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Exception 2. In the LRA, the applicant identified the the following exception exception toto the "Scope "Scope of Program," "Parameters Monitored // Inspected," Inspected," "Monitoring and and Trending," and "Acceptance "Acceptance Criteria" program elements Criteria" elements in in GALL AMP XI.M30:

BVPS does not use ASTM standard standard 0D 6217. BVPS uses ASTM 0D 2276 versus ASTM 0D 6217 for guidance on the determination determination of particulate contamination. The use of ASTM 0 D 2276, with an acceptance acceptance criterion of a total particulate contamination of less than 10 10 mg/liter, is required by BVPS Technical Specification mg/liter, Specification Surveillance Requirements.

The staff reviewed the BVPS Unit 11 and 2 Technical Specifications The Specifications 3.8.1, 3.8.1, 3.8.3, Surveillance Surveillance Bases 3.8.3.3, ASTM 06217, Bases D6217, and ASTM 02276. D2276. The Surveillance Surveillance Bases require ASTM 02276 D2276 be used to satisfy Surveillance Surveillance Requirement 3.8.3.3 in verifying that the new fuel oil has a particulate concentration of less than or equal to 10 mg/I. Additionally, ASTM 02276 D2276 is used for determination of particulate determination particulate contamination for all diesel fuel oil tanks within the scope of the the program. On program. this basis, On this basis, the staff finds the staff finds this exception exception acceptable because itit adequately explainsexplains Surveillance Requirements specify ASTM 02276 that the Technical Specification Surveillance D2276 and that the the requirement ASTM Standard testing requirement Standard is identified in Technical Technical Specification Specification 5.5.9, "Diesel Fuel Oil Testing Program."

Exception 3. In the LRA, the applicant identified the following exception to the "Parameters Exception Monitored/Inspected" program Monitored/Inspected" program element in GALL AMP XI.M30:

BVPS does not use a filter with a pore size of 3.0 microns when testing fuel oil for particulates. BVPS will continue to use the 0.8 micron pore size filter recommended recommended by ASTM D227602276 (which is required by BVPS Technical Technical Specification Specification Surveillance Surveillance Requirements). Use Use of a filter with a smaller pore size results in a larger sample of particulates because particulates because smaller particles particles are retained. Thus, use of a 0.8 micron filter is more conservative conservative than use of a 3.0 micron micron filter.

In RAI B.2.20-3, the staff asked the applicant to provide tt1e applicant provide the evaluation and basis for using the 8 micron filter instead of the 3.0 micron filter in determining micron determining fuel oil particulates. Additionally, the the staff asked the applicant applicant to identify identify the specific fuel oil tanks subject to testing for particulates.

In its response dated dated July 24, 2008, the applicant applicant stated stated that the Technical Technical Specifications Specifications require require the guidance guidance of ASTM D2276-78 02276-78 without modification modification for filter pore size. The smaller smaller filter size filter generates aa more size generates more conservative conservative test for particulates than the larger larger recommended recommended size, providing providing assurance assurance that fuel oil systems are adequately adequately managed for the period of extended extended operation. Finally, the applicant applicant stated that through through the program program enhancements enhancements identified identified above, the smaller the smaller filter pore size is applied applied to all tanks within the scope of the program, in addition to just just the safety-related safety-related tanks.

The staff The staff reviewed reviewed the the applicant's applicant's response response andand finds itit adequately adequately identified identified that the use of thethe smaller filter pore size is more conservative in testing smaller filter pore size more conservative testing for particulates particulates than than the 3.0 micron micron filter filter pore pore size. Further, the staffstaff agrees agrees that the Technical Technical Specifications Specifications require the useuse of the the smaller smaller pore size. Therefore, Therefore, thethe staff's concern in RAI staff's concern RAI B.2.20-3 resolved.

8.2.20-3 is resolved.

Exceptions Exceptions 4 and and 5. In the the LRA, the applicant applicant identified identified the following exception exception to the the "Preventative "Preventative Actions," program element in GALL AMP element GALL AMP XI.M30: XI.M30:

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Biocides, stabilizers, and corrosion inhibitors, are not used used at BVPS. A recent recent review, documented documented using the Corrective Corrective Action Program, evaluatedevaluated thethe possibility of using fuel oil additives, and determined determined that additives additives would not provide any significant benefit provide benefit and thus were not recommended recommended for use at BVPS.

Results from "for-cause" performed in response "for-cause" testing, performed response to Corrective Action Corrective Action Program Program reports written when excessive sediment sediment was detected detected within a fuel oil system, indicate indicate that microbiological activity has not been thatrnicrobiological problem in any fuel been a problem subsystem at BVPS. Due to the materials oil subsystem materials of construction construction and a lack of water in the fuel oil tanks, there is also no benefit to the addition of corrosion corrosion inhibitors inhibitors or metal deactivators deactivators to the fuel oil.oil.

In addition, the LRA identified the following exceptionexception to the "Detection of Aging Effects," and Monitoring and Trending" program elements Monitoring elements in GALL AMP XI.M30:

BVPS does not routinely sample microbiological organisms. BVPS sample fuel oil for microbiological BVPS monitors for corrosion products and sediment; sediment; ifif detected, BVPS will evaluate the the need for further laboratory laboratory analysis to detect the presence presence of microbiological organisms or by-products.

Both of the exceptions pertain to the question on whether whether the applicant needs needs to monitor for microbiological organisms microbiological organisms in the diesel fuel oil inventories inventories or add microbiological microbiological growth inhibitors (biocides) in the diesel diesel fuel oil inventories.

inventories. The staff reviewed the BVPS UFSAR Section 9.14 for Unit 1 and Section Section 9.5.2 for Unit 2 for diesel fuel oil storage systems. The staff staff noted that these UFSAR UFSAR sections sections do not mention that the material material of construction for the fuel oil storage storage tanks are resistant to microbiologically microbiologically induced induced corrosion. Therefore Therefore the staff issued RAI B.2.20-1 B.2.20-1 dated May 22, 2008, requesting requesting the applicant provide justification for taking these justification exceptions.

exceptions.

In its response response dated dated July 24, 2008, the applicant explained the exception of using using biocides due due to the materials of tank construction.

construction. The explanation included an evaluation weighing the use explanation included use of biocides, stabilizers, stabilizers, and corrosion inhibitors in the Emergency Diesel Generator fuel oil tanks. The applicant further explained explained that the evaluation found that biocides were not needed because testing found no evidence of microorganisms microorganisms in the tanks, corrosion inhibitors were not not necessary due to the lack of water in the tanks, and metal deactivators deactivators were not necessary necessary due due to the materials of tank construction. The applicant identified all the fuel oil tank systems for applicant identified which the Fuel Oil Chemistry Program is credited with managing managing their aging effects. Additionally, the applicant applicant stated the material of construction construction for each tank. In summary, of the ten tanks tanks identified nine are carbon steel and one is fiberglass. The applicant stated that although there was no evidence evidence for the needneed of biocides, fuel stabilizers, or corrosion corrosion inhibitors, a sampling sampling schedule schedule for the diesel generator generator fuel tanks that determines determines concentrations of water and/or concentrations particulates particulates in a timely manner. The applicant also stated stated that such analyses will minimize tank loss of material and that the sampling frequency frequency is based on plant-specific plant-specific operating operating experience. The history has shown relatively experience. relatively few instances instances of particulate particulate levels exceeding exceeding the the Technical Specifications Technical Specifications limit. The applicant applicant explained that particulate testing will provide provide indication indication of corrosion byproducts and microbiological corrosion byproducts microbiological growth.

The Fuel Oil Chemistry Program provides provides for the use of fuel oil additives via the Corrective Corrective Action Program Program if if analysis results warrant their use due to out of specification specification conditions and the the existence of adverse adverse trends. Finally, the applicant applicant stated that the effectiveness effectiveness of the Fuel Oil Chemistry Chemistry Program Program is verified by the One-Time One-Time Inspection Program.

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adequately explained how the The staff reviewed the applicant's response and finds that itit adequately the proposed exception proposed Chemistry Program in LRA Section B.2.20 is acceptable.

exception from the Fuel Oil Chemistry acceptable.

The staff finds that with the sampling frequency plant-specific operating frequency established by plant-specific experience and the particulates limits set by the Technical experience Specifications for the diesel Technical Specifications generator fuel oil tanks, the Fuel Oil Chemistry Program generator managing the Program would be effective in managing the aging effects due to loss of material. particulate analysis would material. Further, the staff agrees that the particulate would indication of microorganisms be an indication microorganisms which would then be documented, evaluated, and trended in in Corrective Action Program, the Corrective specification. The staff finds that the One-Program, ifif found to be out of specification.

Inspection would be adequate Time Inspection effectiveness of the Fuel Oil Chemistry adequate to verify the effectiveness because it provides for visual inspections or NDE of internal tank surfaces. Thus, Program because based on this assessment, the staff finds that the applicant has provided an acceptable acceptable basis for for determination on whether the fuel oil needs deferring its determination deferring needs to be monitored monitored for microbiological experience at the plant to date has not indicated that biological organism because the operating experience organism problem for the diesel fuel oil stored at the plant and because presence and growth is a problem presence because the the applicable will use its One-Time Inspection Program of the diesel fuel oil inventories One-Time Inspection inventories to to present in the diesel fuel oil inventories organisms are present determine whether biological organisms determine inventories and needs needs extended operation.

to be managed for the period of extended operation.

Exception 6. By letter L-08-262 dated October identified necessary October 2, 2008, the applicant identified revisions to the BVPS LRA which includes an additional additional program exception to the program described LRA Amendment element, "Detection of Aging Effects." This letter described Amendment 26, resulting from the findings of the staff's IP-71 inspections that occurred 002 inspections IP-71002 weeks of June occurred during the weeks June 23 and and July 14. The following is the staff's evaluation of the additional additional exception.

measurement of tank bottom NUREG-1 801 states that an ultrasonic thickness measurement NUREG-1801 surfaces surfaces ensures that significant degradation occurring. FENOC takes an degradation is not occurring.

exception to this element of the program, exception program, because ultrasonic (UT) because ultrasonic measurement (UT) measurement techniques may not be used to determine tank bottom thickness for tanks whose whose surfaces are not normally accessible. Pitting corrosion could external bottom surfaces potentially potentially result in an irregular Meaningful results irregular internal tank bottom surface. Meaningful results measurements using UT require access to the unpitted for tank bottom thickness measurements unpitted external surface of buried fuel oil tanks surface of the tank. Access to the bottom external tanks and to the Unit 1 emergency generator engine-mounted emergency diesel generator engine-mounted day tanks is impractical. For these tanks, FENOC will perform impractical. appropriate NDE technique perform an appropriate technique determine tank wall thickness if to determine periodic visual inspections if periodic identify significant inspections identify significant corrosion.

The staff reviewed the additional program program exception determine whether tank exception and finds that it will determine needed based on the results of periodic wall thickness NDE is needed periodic visual inspections. During the the interviewed the applicant's audit and review, the staff interviewed applicant's technical personnel technical personnel about the frequency frequency of inspections for the buried fuel oil tanks and the emergency the periodic visual inspections emergency diesel generatorgenerator engine mounted inspections is implemented mounted day tanks. The staff noted that the frequency of the inspections implemented acceptance criteria for corrosion that would trigger the procedure that contains acceptance by plant procedure the measurements. On this basis, the staff finds this determining wall thickness measurements.

appropriate NDE for determining appropriate this adequately explains acceptable because itit adequately exception acceptable explains that the appropriate techniques will appropriate NDE techniques implemented for the fuel oil tanks with inaccessible be implemented unpitted surfaces that are not suitable or inaccessible unpitted accessed for UT measurements.

cannot be accessed measurements.

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LRA AMP B.2.20 provides the following experience (OE) evaluation for BVPS:

following operating experience The Fuel Oil Chemistry Program is an existing program program that utilizes sampling sampling and and analysis to ensure that adequate adequate diesel fuel quality is maintained maintained to prevent loss loss of material and fouling in the various in-scopein-scope fuel oil systems. Exposure Exposure of fuel oil to contaminants such as water and particulates is also minimized by periodic periodic draining draining of accumulated accumulated water, tank interior interior cleaning, and by verifying verifying the quality of new oil before its introduction introduction into the storage tanks.

Water Water has occasionally occasionally been discovered discovered in various BVPS diesel fuel oil storage storage tanks during during sampling activities. In accordance accordance with sampling and analysis analysis procedures, any detected detected water is removed from the affected tank as part of the the sampling process.

There have been instances during the past five years, been multiple, but infrequent, instances where where fuel oil particulate concentrations concentrations were near or aboveabove the Technical Specification limit for Emergency Specification Emergency Diesel Generator fuel oil storagestorage tanks. Four Corrective Action Program items were identified since 2002, which documented Corrective documented elevated elevated fuel oil particulate particulate levels in Emergency Emergency Diesel Generator fuel oil storage Generator storage and day tanks. In all cases, corrective actions were taken such as recirculatingrecirculating the tank contents through through a particulate particulate filter. Other than these events, fuel oil sample results from 2001 through 2005 reveal that fuel oil quality is being being maintained maintained in compliance compliance with industry standards. Regular analysis analysis and confirmation of diesel fuel quality provide reasonable assurance confirmation assurance that the program program is effectively effectively managing fuel oil chemistry.

A sampling schedule schedule for diesel generator generator fuel oil tanks has been established, established, to allow timely identification identification of excessive concentrations of water and/or excessive concentrations particulates, which will minimize tank loss of material. SamplingSampling frequency frequency is adequate adequate as evidenced evidenced by the relatively relatively few instances of particulate levels particulate levels exceeding exceeding the Technical Specification limit. A recent CR identified Technical Specification identified elevated particulate particulate levels which which had yet to exceed the limit, but were monitored monitored with with sufficient frequency to identify sufficient frequency identify a rising trend.

important element An important element of fuel oil (or any other) analysis is operation operation of the testing laboratory. Fuel oil samples from BVPS are sent to Beta Laboratory Laboratory (a First Energy subsidiary) after an initial set of factors are measured measured at the BVPS site.

The laboratory completes the oil analysis by measuring measuring parameters parameters such as as viscosity, flash point, and percent sulfur.

A fleet oversight Quality Assurance audit was conducted to assess the operation practices practices and regulatory regulatory compliance compliance of the Beta Laboratory facility. The principal tool for this assessment assessment was the FENOC Quality Assurance Assurance Program Manual.

The results of the audit reveal that Beta Lab is effective in performing performing analyses analyses of the fuel oil samples from BVPS, however however multiple areas improvement were areas for improvement identified identified and Corrective Corrective Action Program items items were generated generated to document document and track the recommended recommended improvements. The Quality Assurance audit process audit process provides an additional level of assurance provides assurance that the fuel oil chemistry program will continue continue to effectively effectively monitor and manage manage fuel oil chemistry.

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On the basis of its review and of industry plant-specific operating experience industry and plant-specific experience and discussions discussions with the applicant's applicant's technical personnel, personnel, the staff concludes concludes that the applicant's applicant's Fuel Oil Chemistry Chemistry Program, Program, would adequately adequately manage the aging effects identified in the the LRA for which which this AMP is credited.

UFSAR Supplement UFSAR Supplement In LRA Section A.1.20, the applicant applicant provided provided the UFSAR Supplement for UFSAR Supplement for Chemistry Program.

the Fuel Oil Chemistry Program. The staff reviewed reviewed this Section and determined determined that thethe information in the UFSAR Supplement provides an adequate information adequate summary description the description of the program consistent with that provided in the SRP-LR SRP-LR Table 3.1-2 for diesel fuel oil testing programs.

As a result of the staff's IP-71002 IP-71002 inspections that occurred during the weeks of June 23 and July 14, 2008, the applicant identified necessary necessary revisions to the LRA which includes includes a new program enhancement. The applicant provided the program program changes in letter L-08-262 dated, September 8, 2008 which includes September Amendment No. 23 which included the addition of a includes LRA Amendment enhancement to Commitment new enhancement Commitment No.1 No. 10.O. In LRA Section Section A.1.20 the applicant provided the applicant provided the UFSAR Supplement UFSAR enhancement that revised Supplement for the new enhancement revised the implementing implementing procedures procedures to to perform perform UT thickness measurements of accessible thickness measurements accessible above-ground above-ground fuel tank bottoms at the same same frequency frequency as tank cleaning and inspections to ensure degradation degradation is not occurring.

The staff reviewed reviewed the commitment commitment list in LRA SectionSection A.4-1 for BVPS Unit Unit and Table A.5-1 for BVPS Unit 2 in the UFSAR Supplemental Supplemental for the application (i.e., (i.e., LRA Appendix Appendix A), and enhancements the Fuel Oil Chemistry Program are captured confirmed that the enhancements captured in Table A4.1, A4.1, Commitment No.1 Commitment No. 100 for BVPS Unit 1 and in Table A5.1, A5. 1, Commitment No. 11 for BVPS Unit 2.

The staff determined determined that the information information in the UFSAR SupplementSupplement provides provides an adequate adequate summary description summary description of the program consistent with the SRP-LR SRP-LR because because the UFSAR Supplement, as modified by LRA Amendment 23, dated September September 8, 2008, is in conformance conformance with those provided for these type of programs in Table 3.1-2 of the SRP-LR and because because the the enhancements of the program enhancements'of program have been been reflected reflected in appropriate appropriate Commitments Commitments that have been Supplement for the application.

placed on the UFSAR Supplement application.

Conclusion.The Conclusion.The staff has reviewed the information provided in LRA Section B.2.20 and information provided additional information provided additional information provided by the applicant by letter letter dated July 24, 2008. On the basis of its review as discussed above, the staff finds the applicant's applicant's Fuel Oil Chemistry Program acceptable acceptable because it is consistent consistent with the GALL Report enhancements and exceptions, Report with enhancements and the plant is bounded by the conditions conditions set forth in the GALL Report Report for this aging management management program. The staff finds that the program program will adequately adequately manage the aging aging effects effects so that the intended intended functions will be maintained consistent with the CLB for the period of extended extended operation, operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR UFSAR supplement supplement for this AMP and finds that it provides an adequate adequate summary summary description the description of the program, as required by 10 CFR 54.21(d).

3.0.3.2.9 Inspection of Overhead Heavy Load and Light Load (Related 3.0.3.2.9 Inspection (Related to Refueling)

Refueling) Handling Handling Systems Program Summary of Technical Summary Technical Information Information in the Application. In LRA Section B.2.23, the applicant applicant described described the Inspection Inspection of Overhead Overhead Heavy Load and Light Load (Related (Related to Refueling)

Refueling) 3-136

Handling Systems Program. This program will manage loss of material Handling material of structural structural components components for heavy heavy load and fuel handling components components within the scope of license renewal renewal and subject to aging aging management. The program focuses on inspections of structural structural components components that make make up up the bridge, trolley, and rails of the cranes cranes and hoists, and is implemented implemented through the use of visual inspections.

inspections.

Staff Evaluation. In the LRA, the applicant applicant stated that the Overhead Overhead HeavyHeavy Load and Light Load Load (Related to Refueling)

Refueling) Handling Systems Program Program is an existing program that is consistent with with GALL AMP XI.M23, "Inspection of Overhead Heavy Heavy Load and Light Load (Related to Refueling) Refueling)

Handling Systems," with an enhancement.

Handling enhancement. The enhancement guidance in licensee enhancement includes guidance licensee procedures procedures to inspect for loss of material due to corrosioncorrosion on certain crane components.

During the audit, the staff reviewed the applicant's applicant's onsite documentation documentation to support support its conclusion that the program elements conclusion elements are consistent with the elements elements in the GALL AMP. The The staff conducted onsite interviews interviews with the applicant's technical staff to confirm confirm the results.

In comparing the elements elements in the applicant's Overhead Overhead Heavy Load and Light Load (Related (Related to to Refueling) Handling Handling Systems Program, the staff found that the applicant applicant credited its Maintenance Rule Program Maintenance Program for meeting the GALL Report "parameters monitored/ monitored! inspected" program element by evaluating evaluating the effectiveness maintenance monitoring program effectiveness of the crane maintenance program and the effects of past and future usage on the structural reliability of cranes and hoists.

However, the staff did not find a reference reference to the Maintenance Maintenance Rule Program Program in in LRBV-PED-XI.M23.

LRBV-PED-XI.M23.

In RAI B.2.23-1, B.2.23-1, March March 26, 2008, the staff requested that the applicant provide a detailed explanation on how the Maintenance explanation Maintenance Rule Program meets the GALL Report Report "parameters "parameters monitored/inspected" monitored/ inspected" program element element recommendation.

recommendation.

In its response to RAI B.2.23-1, B.2.23-1, dated April 25, 2008, the applicant applicant stated that the license license renewal renewal program evaluation document for this program has been revised to identify the site evaluation document site Maintenance administrative procedure Maintenance Rule Program administrative procedure as an existing existing implementing implementing procedure, and also to clearly credit the site Maintenance Maintenance Rule Program administrative administrative procedure procedure as the the implementing document implementing document for the GALL Report "parameters monitored/ monitored/inspected" inspected" program element.

Based on its review, the staff finds the applicant's response to RAI B.2.23-1 acceptable acceptable because because the applicant has revised its license license renewal program program evaluation evaluation document document for the Overhead Heavy Load and Light Load (Related Heavy (Related to Refueling)

Refueling) Handling Handling Systems Program to credit the site Systems Program site Maintenance Maintenance Rule Program administrative administrative procedure as the implementing implementing document for the the GALL Report GALL Report "parameters "parameters monitored/

monitored/ inspected" inspected" program element. Therefore, Therefore, the staff's staff's B.2.23-1 is resolved.

concern described in RAI 8.2.23-1 resolved.

In LRA Section B.2.23, the applicant stated that an enhancement enhancement to the GALL Report "Scope of Program" and "Detection of Aging Effects" program program elements includes guidance in licensee includes guidance licensee procedures to inspect for loss of material procedures material due to corrosion corrosion on certain crane components. The The enhancement acceptable staff finds this enhancement acceptable because when implemented, implemented, the Inspection of Overhead Heavy Load and Light Load (Related Overhead Refueling) Handling Systems Program (Related to Refueling) Program will be be consistent with GALL AMP XI.M23 and will add assurance of adequate management of aging adequate management effects.

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The The staff staff also reviewed the also reviewed the operating operating experience reports including experience reports including aa sample sample ofof condition condition reports, and interviewed reports, and interviewed the the applicant's applicant's technical staff to confirm technical staff confirm that that the plant-specific plant-specific operating experience did operating experience did not reveal reveal any any degradation bounded by degradation not bounded by industry industry experience.

experience. In oneone applicant stated that report, the applicant that an occurred in 2003 where an event occurred where programmatic deficiencies and programmatic deficiencies and degraded degraded crane material conditions crane material conditions related integrity container related to aa lift of a high integrity container grapple grapple necessitated aa stop work order necessitated order for radiological determined that radiological lifts. However, the staff determined additional details were additional were not readily readily apparent regarding the event, most notably, the apparent regarding resulting the resulting enhancements that were enhancements developed as a result of this event. The staff were developed staff noted that a lack lack of response by the response monitoring program the monitoring program would would bring into question the applicant's into question applicant's ability ability to meet meet the the GALL Report "detection of GALL Report of aging effects" program program element.

In In RAI B.2.23-2, March 26, 2008, the staff requested that the applicant provide B.2.23-2, March provide further detail on further detail on the follow-up actions actions taken taken for this event.

In its response to RAI In RAI B.2.23-2, dated April 25, 2008, the applicant applicant stated that thethe 2003 2003 operating experience event was operating experience documented in a condition was documented condition report in the FENOC FENOC Corrective Corrective Action Program, Program, and that administrative controls were administrative controls place to ensure that the waste were put in place waste handling building crane would not handling radiological lifts until the proper corrective not be used for radiological corrective actions actions had had been completed.

completed. In response, FENOC personnel completed FENOC personnel completed a root cause analysis report for analysis report the event and a generic implications review, which led to another generic implications another condition condition report being entered into the FENOC into FENOC Corrective Program. The Corrective Action Program. The applicant conducted a total of 21 corrective applicant conducted corrective actions actions to resolve the condition report, including program enhancements.

including several program enhancements.

The applicant applicant stated that several corrective actions were taken as follows:

several notable corrective

• A CAP review was requiredrequired to ensure specific to an earlier, related ensure that all issues specific condition report were addressed in the response to this operating experience experience condition report. A new corrective corrective action developed to track those previous action was developed previous issues to closure.

• The crane electrical Preventive Preventive Maintenance Procedure was revised to include Maintenance Procedure include inspections inspections of the crane cameras, monitors monitors and controllers, controllers;

• • A facilitated review of the CAP condition report and the associated Root Cause Cause Report was conducted for selected crane Operations Radiation Operations Support and Radiation Protection Personnel to ensure they had a full understanding understanding of the issues, consequences, findings and corrective actions associated with the potential consequences, operating experience experience event.

• Radwaste Personnel attended crane operator training and completed On the Job Radwaste Performance Standards to become qualified to operate the Training and Task Performance the Waste Handling Building Crane.

• An Effectiveness Review (completed August 26,2004)

Review (completed performed six months 26, 2004) was performed months after completion of the corrective actions. During the process for the the implementation of the original corrective actions and during the use implementation use of the crane, additional issues were identified. These additional issues led to the development development of 3-138

additional additional condition reports and associated associated corrective actions.

actions. Therefore the initial Review was Effectiveness Review was considered indeterminate, and a new corrective action initiated to was initiated to conduct another Effectiveness Review at at the appropriate timetime following completion of the newly identified actions.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.23-2 acceptable because because demonstrated a timely and thorough reaction to the 2003 operating the applicant has demonstrated operating experience event. Therefore, the staff's concern described experience described in RAI RAI B.2.23-2 is resolved.

resolved.

UFSAR Supplement. The applicant provided the UFSAR supplement for the Inspection of Overhead Heavy Load Load and Light Load (Related to Refueling) Handling Handling Systems Program LRA LRA Section A.1.23. The staff reviewed this Section and determines that the information in the supplement is UFSAR supplement is an adequate summary description of the program, as required by 10 CFR 54.21(d).

The applicant committed (Commitments (Commitments U1-13 and U2-14) to implement implement this program program before before the period of extended operation.

Conclusion. The staff reviewed the information provided in LRA Section B.2.23 and additional information provided by the applicant information applicant by letter dated April 25, 2008. Based on its review, the the staff concludes that the applicant demonstrated that effects of aging on crane and trolley applicant has demonstrated components for those cranes that are within the scope of 10 CFR 54.4, and the structural components effects of wear on the rails in the rail system will be adequatelyadequately managed managed so that the intended functions of these components will be maintained ofthese maintained consistent with the CLBfor CLB for the period of extended operation, as required by 10 CFR54.21(a)(3).

extended CFR 54.21(a)(3). The staff also reviewed reviewed the UFSARUFSAR supplement for this AMP and finds that itit provides supplement provides an adequate adequate summary description of the summary description the program, program, as required required by 10 CFR 54.21(d).

3.0.3.2.10 3.0.3.2.10 Masonry Wall Program Summary of Technical Information in the Application.Application. In LRA Section B.2.25, the applicant applicant described the existing Masonry described Masonry Wall Program as consistent, with an enhancement, with GALL XI.S5, "Masonry AMP XI,S5, "Masonry Wall Program." This program will manage manage aging effects effects so that thethe evaluation evaluation basis established established for each masonry wall within the scope of license license renewal remains remains valid through the period of extended operation.

extended operation.

The program includes all masonry identified as performing masonry walls identified performing intended functions functions pursuant to to 10 CFR 54.4. Components 10 Components included included in this program are are the masonry masonry walls pursuant to to 10 CFR 50.48, radiation masonry walls, and masonry walls with the potential radiation shielding masonry potential to affect safety-related components.

safety-related components. The Masonry Masonry Wall Program Program is implemented implemented as part of the Structures Structures Monitoring Program.

Monitoring Program. Masonry walls are are visually examined at a frequency selected frequency selected to ensure no no loss of intended intended function betweenbetween inspections.

Staff Evaluation.

Evaluation. During During itsits audit and review, the staff confirmed confirmed the applicant's applicant's claim of consistency consistency withwith the GALL GALL Report. The The staff staff reviewed reviewed the enhancement enhancement to determine determine whether whether the AMP, with with the enhancement, enhancement, is adequate adequate to manage manage the the aging aging effects effects for which which the LRALRA credits it.

it. The staff interviewed staff interviewed the applicant's technical applicant's technical staff and reviewed the associated associated bases bases documents documents for the Masonry Masonry Wall Program, which assesses Program, which assesses the AMP elements' elements' consistency consistency with with GALL GALL AMP XI.S5.XI,S5.

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The staff noted that the Masonry Wall Program is part of the Structures Monitoring Program that Monitoring Program implements implements structures monitoring requirements pursuant monitoring requirements pursuant to 10 CFR 50.65. The program manages manages aging of masonry masonry walls and their structural steel restraint systems within the scope of license renewal and is guided by NRC license renewal NRC IE Bulletin 80-11,80-11, "Masonry Wall Design," and NRC NRC IN 87-67, "Lessons Learned Learned from Regional Inspections of Licensee Actions in Response Actions Response to to NRC IE Bulletin Bulletin 80-11." Components included in this program program are the masonry walls pursuant masonry pursuant to 10 10 CFR 50.48, radiation shielding masonry masonry walls, and masonry walls with the potential potential to affect affect safety-related safety-related components. The Masonry Masonry Wall Program describes describes inspection inspection guidelines, lists lists causes of aging of masonry masonry walls to be monitored monitored duringduring structural monitoring monitoring inspections, inspections, and examination criteria, evaluation requirements, and acceptance establishes examination acceptance criteria.

During the audit and review, the staff requested that the applicant applicant verify the frequency frequency of visual examination for the program and its technical basis. In its response, the applicant applicant stated that the the inspection is implemented by the Structures Structures Monitoring Monitoring Program and consists of visual inspection for cracking cracking in joints, deterioration deterioration of penetrations, missing or broken blocks, missing missing general mechanical mortar, and general soundness of steel supports. Visual inspections are at least mechanical soundness least every five years to ensure ensure no loss of intended function function between inspections.

The staff reviewed the Masonry Wall Program by comparing comparing the 10 elements in the applicant's applicant's program program for which which the applicant claims consistency consistency with GALL AMP XI.S5. The staff finds the the acceptable, because it conforms to the recommended program acceptable, recommended GALL GALL AMP XI.S5, with with enhancements as described enhancements described below.

Enhancement 1. In the LRA, the applicant Enhancement applicant credited an enhancement enhancement to the GALL Report program element program element "scope of the program." Specifically, the enhancementenhancement states:

The scope of the existing comprised of masonry walls within the existing program is comprised the scope of 10 CFR 50.65 (The Maintenance Maintenance Rule). The scope of the program will be enhanced additional masonry enhanced to include additional masonry walls identified identified as having aging effects requiring management license renewal.

management for license renewal.

The staff reviewed procedures and the aging effects requiring management reviewed the plant procedures management under under thethe scope of the Masonry Wall Program.

Program. The staff finds this information acceptable information acceptable because the the corrective corrective action program will consider consider expanding the scope if if significant significant degradation is observed.

The staff finds this enhancement enhancement acceptable acceptable because, when the enhancement enhancement is implemented, implemented, the Masonry Masonry Wall Program Program will be consistent with GALL AMP XI.S5 and provide provide additional assurance assurance that the effects effects of aging will be adequately adequately managed.

Enhancement Enhancement 2. In a letter letter dated September September 8, 2008, the applicant added to LRA Commitment Commitment No. 14 and credited credited an enhancement enhancement to the GALL GALL Report program program element element "monitoring and enhancement states:

trending." Specifically, the enhancement The results of the Masonry Masonry Wall Program Program inspections inspections are incorporated incorporated into the the inspection report to document inspection document the condition of the walls.

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The staff reviewed the applicant's applicant's additional commitment and the aging effects requiringrequiring management under the monitoring management monitoring and trending of the Masonry Masonry Wall Program. The staff finds finds this information acceptable since the corrective information acceptable corrective action program program will consider expanding the the inspection inspection scope, ifif significant significant degradation degradation is observed.

The staff staff finds this enhancement enhancement acceptable acceptable because, when the enhancement enhancement is implemented, the Masonry Masonry Wall Program Program will be consistent with the GALL Report and provides additional assurance assurance that the effects effects of aging will be adequately adequately managed.

The staff reviewed reviewed those portions of the Masonry Masonry Wall Program for which the applicant applicant claims claims consistency consistency with GALLGALL AMP XI.S5 and finds that they are consistent with the GALL AMP. The The staff finds the applicant's applicant's Masonry Wall Program acceptable acceptable because it conforms to the the recommended AMP, with the enhancements enhancements described.

Operatinq Experience. The staff reviewed the operating Operating Experience. operating experience experience provided in the LRA, and and Operation Experience Review Report (Masonry Operation Experience (Masonry Wall's section), and interviewed interviewed the applicant's applicant's technical staff to confirm confirm that the plant-specific plant-specific operating operating experience experience has been reviewed by the the applicant applicant and is evaluated in the GALL Report. During During its audit, the staff requested that the the applicant's applicant's technical staff explain explain why the results of the inspection inspection in June 2000 were sent to design engineering design engineering for evaluation. The applicant stated that the design engineering engineering organization organization reviews any conditions found. The staff reviewed those result conditions conditions and found they were nature and did not affect the structural minor in nature structural integrity of any of the structures structures reviewed.

reviewed.

Furthermore, the staff confirmed confirmed that the applicant applicant has addressed operating experience experience identified after the issuance issuance of the GALL Report. The staff finds that the applicant's applicant's Masonry Wall Program, with the corrective corrective actions discussed discussed in the LRA, has been been effective in identifying, monitoring, and correcting the aging effects of masonry masonry walls and confirms that the the plant-specific plant-specific operating experience revealed experience revealed no degradation degradation not bounded bounded by industry experience.

The staff confirmed confirmed that the "operating experience" program element satisfies the criterion criterion defined in the GALL Report and in SRP-LR SRP-LR Section A.1.2.3.10.

SectionA.1.2.3.1 O. Therefore, the staff finds this this program program element acceptable.

UFSAR UFSAR Supplement. The applicant provided the UFSAR supplement supplement for the Masonry Masonry Wall Program in LRA Section Section A.1.25. The staff reviewed this Section and finds the UFSAR UFSAR supplement supplement information an adequate adequate summary summary description description of the program, as required required byby 10 CFR 54.21(d).

Conclusion. Based on its audit and review of the applicant's Conclusion. Masonry Wall Program, the staff applicant's Masonry staff determines that those program elements for which the applicant claimed claimed consistency with the the GALL Report are consistent. Also, the staff reviewed reviewed the enhancements enhancements and confirms confirms that their implementation prior to the period of extended implementation operation will make the existing Masonry Wall extended operation Program consistent consistent with the GALL Report AMP to which which itit was compared. The staff concludes concludes that the applicant has demonstrated demonstrated that effects of aging will be adequately managed managed so that the the maintained consistent with the CLB for the period of extended intended functions will be maintained extended operation, operation, as required required by 10 CFR 54.21(a)(3).

54.21 (a)(3). The staff also reviewed reviewed the UFSAR supplement UFSAR supplement for this AMP and concludes concludes that itit provides provides an adequate description of the program, adequate summary description as required by 10 CFR 54.21(d).

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3.0.3.2.11 Reactor Head Head Closure Studs Program Summary Summary of Technical Information in the Application. In LRA Section Technical Information Section B.2.34, the applicant applicant described the Reactor Head described Head Closure Studs Program. This program will manage manage the effects of aging of the reactor headhead closure studs, nuts, washers and RV flange threads. Examinations for for the program program are conducted during each lSI ISI interval as part of the Inservice Inservice Inspection Inspection Program.

Program.

The examinations examinations are performed in accordance accordance with the ASME Code Section XI requirements.

The applicant will use the the ASME Code edition consistent with the provisions of 10 CFR 50.55a, during the period of extended extended operation.

Staff Evaluation. the LRA, the applicant Evaluation. In theLRA, applicant stated that the Reactor Reactor Head Closure Studs Program is an existing program that is consistent with GALL AMP XI.M3, "Reactor "Reactor HeadHead Closure Studs,"

with an exception.

exception. The exception is to the ASME Code Section Section XI edition, in which the GALL Report AMP specifies the use of ASME Code Section XI, 2001 Edition, including the 2002 and Edition, including 2003 Addenda, whereas whereas the applicant currently uses the ASME Code Section XI, 1989 1989 Edition.

Edition.

During its audit, the staff reviewed reviewed the applicant's onsite documentation documentation to support its conclusion that the program elements elements are consistent consistent with the elements elements in GALL AMP XI.M3.

The staff compared the elements in the applicant's applicant's program with the GALL Report Report program program elements. In In comparing the 10 elements in the applicant's applicant's program, the staff found that the the applicant applicant has addressed all 10 elements elements in a satisfactory satisfactory manner. In addition, the 10 elements elements were consistent with GALL AMP XI.M3.

The applicant has taken an exception exception to the ASME Code Section Section XI code edition in that the the applicant identified that the current ASME Code Section applicant identified Section XI edition on record for Units 1 and 2 is ASME Code Section Section XI, 1989 1989 Edition, with no addenda.

addenda. The applicant credits this edition of the the code for aging management. The staff noted noted that this was the ASME Code Section XI edition in effect effect for the 3rd 10-Year 10-Year lSIISI Interval Interval for Unit 1 and the 2nd 10-Year 10-Year ISI Interval for Unit lSI Interval The Unit 2. The staff noted that the applicant indicated indicated that Unit 1 entered entered its 4th 10-Year ISI lSI Interval on April 1, 2008 and that Unit 2 is scheduled scheduled to enter its 3rd 10-Year 10-Year ISI 29, 2008.

lSI Interval on August 29,2008.

Pursuant to 10 CFR 50.55a, the applicant was required to implement the ASME ASME Code Section Section XI, 2001 Edition, Edition, including including the 2002 and 20032003 Addenda, upon entrance into the upon entrance the 4th 10-Year lSIISI Interval for Unit 1, and will be required to implement this same edition, including including

addenda, addenda, uponupon entrance entrance into into the 3rd 10-Year 10-Year lSI ISI Interval for Unit 2.

In RAI B.2-2, dated JuneJune 5, 2008, the staff requested requested that the applicant applicant clarify the ASME ASME Code Section Section XI edition edition credited for those AMPs that credit applicable applicable ASME Code Section XI requirement criteria for aging management.

requirement management.

In its response to RAI B.2-2, B.2-2, dated dated July 21, 2008, the applicant stated that the 4th (Unit 1) and July 21, 3rd (Unit 2) 10-Year 10-Year ISI Intervals lSI Intervals will use ASME Code Section XI, XI, 2001 2001 Edition, including the the 2002 2002 and 2003 Addenda. These intervals are scheduled scheduled to begin on April 1, 2008 (4th- Unit 1) and August 29, 2008 (3rd - Unit 2). The staff concludesconcludes that this edition of the.ASME theASME Code Section XI is consistent recommended edition in the GALL consistent with the recommended GALL Report.

Based on its review, the staff finds the applicant's response response to RAI B.2-2 acceptable acceptable because because the applicant has clarified that it will credit the ASME Code Section Section XI, 2001 Edition, including including 3-142 3-142

the 2002 andand 2003 addenda, for aging management. Therefore, the the staff's concern described described in in RAI B.2-2 is RAI is resolved.

resolved.

The staff also reviewed the operating experience reports to confirm that the plant-specific The plant-specific experience and interviewed the applicant's technical staff to confirm that the operating experience the plant-specific plant-specific operating experience did not reveal any degradation not bounded by industry by experience. The reports indicated that in 2006, RFOs 11R17 included reactor head R17 and 2R12 included examinations which both resulted in no undesirable indications. The reports further studs UT examinations indicated that there is no no history of RV studs, nuts, and washers with with cracks or anything more significant than "minor nicks and scratches".

UFSAR Supplement. The applicant provided the UFSAR supplement UFSAR supplement for the Reactor Head Closure Studs Program in LRA Section A.1.34. The staff reviewed Closure reviewed this Section and determines determines that the information information in the UFSAR supplement supplement is an adequateadequate summary description of the summary description the program, as required by 10 CFR 54.21(d).

program, Conclusion. The staff reviewed the information Conclusion. information provided by the applicant applicant in LRA Section B.2.34.

Based on its review, the staff concludes that the applicant demonstrated that effects of applicant has demonstrated aging on reactor head closure studs and huts nuts constructed from materials materials with aa maximum tensile strength strength limited to less than 170 ksi, will be adequately managed managed so that the intended intended functions of these components components will be maintained consistent consistent with the CLB for the period of extended extended operation, as required by 10 CFR 54.21 (a)(3).

Monitoring Program 3.0.3.2.12 Structures Monitoring Technical Information Summary of Technical Information in the Application. In LRA Section Section B.2.39, the applicant applicant described the Structures Monitoring Structures Monitoring Program. This program implements program implements the requirements of 10 CFR 50.65 (the Maintenance Maintenance Rule). The applicant stated that this program follows the the guidance provided in RG 1.160 1.160 and NUMARC NUMARC 93-01. 93-01. These two documents provide guidance provide guidance for development development of licensee-specific licensee-specific programs to monitor the condition of structures and and structural components within the scope of the Maintenance structural components Maintenance Rule, to ensure no loss of structure or structural component intendedintended function.

Staff Evaluation.

Evaluation. In the LRA, the applicant applicant stated stated that its Structures Monitoring Program Structures Monitoring Program is an an existing existing plant program program that is consistent consistent with GALL GALL AMP XI.S6, "Structures Monitoring Monitoring Program," with enhancements.

enhancements.

The The staff reviewed the applicant's applicant's onsite documentation documentation to determine determine whether whether the program program elements elements are consistent consistent with the elements elements in the GALL Report Report program. The staff staff also also reviewed the enhancements enhancements and and the associated justifications justifications to determine determine whether whether the AMP, with the the enhancements, enhancements, remains adequate adequate to manage manage the aging effects aging effects for which it is credited. The staff staff interviewed interviewed the applicant's technical applicant's technical staff and reviewed the documents documents related to the StructuresStructures Monitoring Program, Monitoring including the license renewal program Program, including program evaluation evaluation report report in which the the applicant applicant assessed assessed whether whether the program program elements elements are are consistent with GALL GALL AMP XI.S6.

The staff staff noted noted that the Structures Structures Monitoring Monitoring Program Program manages manages cracking, cracking, loss loss of material, material, andand change change in in material properties by monitoring material properties monitoring the the condition of structures structures andand structural structural supports supports within the the scope of of license license renewal. The The program program provides inspection guidelines provides inspection guidelines and walkdown walkdown checklists checklists for concrete concrete elements, structural structural steel, masonry masonry walls, structural structural features (e.g.,(e.g.,*

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caulking, sealants, roofs, etc.), structural supports, and miscellaneous miscellaneous components components like doors.

The program includes masonry walls within the scope of license includes all masonry inspects license renewal and inspects supports equipment; piping; conduit; cable tray; heating, ventilation, supports for equipment; ventilation, and air conditioning conditioning (HVAC); and instrument components.

(HVAC); components. Although coatings may be applied applied to the external surfaces surfaces of structural members, no credit credit was taken for these coatings when determining the determining the effects of aging on underlying underlying materials. The staff noted that failure of coatings could result in in aging effects for the steel shell in containment. The failure of coatings coatings could also result in the the failure failure of safety systems to perform their intended intended functions.

In RAI B.2.39-1, B.2.39-1, dated dated April 30, 2008, the staff requested that the applicant justify not having an AMP for coatings.

In its response to RAI B.2.39-1, B.2.39-1, dated dated June 6, 2008, the applicant applicant stated:

The potential potential for containment containment sump blockage blockage due to debris is an event-driven event-driven concern that is addressed by the plants' current licensing basis. Aging of coatings does not affect the assumptions assumptions used in the evaluation evaluation of potential sump blockage. Coatings do not perform perform or support any of the intended functions functions listed listed in 10 CFR 54.4. Therefore, management containment coatings as a separate management of aging for containment separate subcomponent sUbcomponent is not required required for compliance with 10 CFR 54.4, and a program corresponding corresponding to NUREG-1801 NUREG-1801 XLS8, XI.S8, Protective Coating Monitoring Monitoring and Maintenance Maintenance Program, Program, is not not credited in the BVPS LRA.

Based Based on its review, the staff finds the applicant's applicant's response response to RAI B.2.39-1 acceptable because acceptable because the applicant applicant has adequately justified its basis for not having an AMP for coatings. The staff staff reviewed the applicant's responses reviewed responses and concludes concludes that since there are no GALL line items that specify use of a coatings AMP, there is no need for this program. The staff determines determines that the the aging of coatings in containment containment will be managed managed using the ASME Code Section XI, Subsection IWE Subsection Program. Therefore, the staffs IWE Program. described in RAI B.2.39-1 is resolved.

staff's concern described The staff finds the applicant's applicant's responses and its Structures Monitoring Program acceptable acceptable because it conforms because conforms to the recommended recommended GALL GALL AMP XI.S6,XLS6, with enhancements enhancements as described below.

Enhancement 1. For license renewal, the scope will be enhanced Enhancement enhanced to include include additional structures structures and structure components components which were identified in the license renewal agingaging management review report.

management The staff reviewed applicant's Structures reviewed the applicant's Monitoring Program Structures Monitoring Program and its AERM, AERM, under the under the "scope of "scope of the program" element the program" element of of the Structures Monitoring the Structures Monitoring Program.

Program. The staff finds that by including as in-scope the main intake structure, structure, roofs, and manholes manholes for degradation degradation of concrete, steel, conduit, trays, and supports, the enhancement enhancement acceptable because is acceptable because when implemented, implemented, the applicant's Structures Monitoring Program Structures Monitoring Program will be consistent with GALL AMP XLS6.

XI.S6. This enhancement enhancement provides provides additional assurance assurance that the effects of aging will be be adequately managed.

adequately managed.

Enhancement 2. In the LRA, the applicant Enhancement applicant credits credits an enhancement enhancement to the GALL Report Report program element "parameters monitored monitored / inspected." Specifically, the enhancement enhancement states that the the 3-144

applicant will "provide inspection guidance guidance in program implementing procedures program implementing procedures to detect significant cracking concrete surrounding cracking in concrete surrounding the anchors anchors of vibrating vibrating equipment."

The staff reviewed applicant's Structures reviewed the applicant's Structures Monitoring Program, and the AERM under under the the "parameters "parameters monitored/inspected" monitored/inspected" elementelement of of the the Structures Structures Monitoring Program. The staff Monitoring Program. staff found this element element is not clear in how the applicant applicant satisfies the GALL Report Report recommendations. Specifically, the GALL Report program element element suggests American American Concrete Concrete Institute (ACI) 349.3R-96 Institute (ACI) 349.3R-96 and ANSI/American ANSl/American Society of Civil EngineersEngineers (ASCE) 11-90 as an acceptable basis acceptable basis for the selection selection of parameters parameters to be monitored monitored or inspected, but the LRA does does not mention mention these standards.

In RAI B.2.39-4, dated dated April 30, 2008, the staff requested requested that the applicant applicant explain how large large must a crack crack be for consideration consideration as "significant" "significant" and which industry codes, standards, and industry guidelines form the basis for this program element.

In its response response to RAI B.2.39-4, dated dated June 6, 2008, the applicant stated:

Monitoring Program The BVPS Structures Monitoring Program does not directly directly cite ACI 349.3R-96 349.3R-96 or ANSI/ASCE ANSI/ASCE 11-90 as the basis for selection selection of parameters parameters to be monitored. The The structural parameters monitored under the current BVPS Maintenance structural parameters Maintenance Rule structural inspection program were identified in 1996 1996 using the guidance guidance existing at that time; primarily NEI 96-03, Revision Revision D, and Westinghouse Westinghouse Owner's Group, "Life cycle cycle management management Aging AssessmentAssessment Field Guide." fundamental attributes Guide." The fundamental attributes of structural deficiency deficiency types and documentation documentation are consistent between the BVPS Structures Structures Monitoring Program and ACI 349.3R-96, which NEI 96-03 references.

Monitoring Based Based on its review, the staff finds the applicant's applicant's response to RAI 8.2.39-4B.2.39-4 acceptable acceptable because because the applicant has adequately adequately justified that since the structural parametersparameters monitored were identified identified inin1996 1996 using the guidance guidance existing existing at that time, there is no need need to refer back to to ACI 349.3R-96 or ANSI/ASCE ANSI/ASCE 11-90. Therefore, Therefore, the staff's concern concern described in RAI B.2.39-4B.2.39-4 is resolved.

The staff finds the applicant responses and the enhancement enhancement acceptable, because because when the the enhancement is implemented, enhancement implemented, the applicant's Monitoring Program applicant's Structures Monitoring consistent Program will be consistent with GALL AMP XI.S6 XI,S6 and will provide additional additional assurance assurance that the effects of aging will be be adequately managed.

adequately Enhancement Enhancement 3. In the LRA, the applicant credits an enhancement enhancement to the GALL GALL Report Report program element "parameters monitored I/ inspected." Specifically, the enhancement enhancement states the applicant applicant will "perform opportunistic inspections opportunistic inspections of normally inaccessible below-grade normally inaccessible below-grade concrete when when excavation work uncovers excavation uncovers a significant significant depth."

The staff reviewed the applicant's applicant's Structures Monitoring Program Structures Monitoring Program and the AERM, under the the "parameters "parameters monitored/inspected" monitoredlinspected" element element of of the the Structures Structures Monitoring Program. The staff finds Monitoring Program. finds this enhancement acceptable to perform opportunistic enhancement acceptable inspections of normally inaccessible opportunistic inspections inaccessible below-grade concrete below-grade concrete structures when excavation excavation occurs. The staff concludes that more more frequent inspections frequent inspections may be based on past inspection inspection results, industry experience, or exposure exposure to a significant significant event (i.e., tornado, earthquake, earthquake, fire, or chemical spill). On this basis, the staff staff finds this enhancement enhancement acceptable acceptable because when implementedimplemented the Structures Monitoring Structures Monitoring 3-145

Program will be consistent with GALL GALL AMP XI.S6 and provide provide additional assurance assurance that the the effects effects of aging will be adequately adequately managed.

managed.

Enhancement 4. In the LRA, the applicant credits an enhancement Enhancement enhancement to the GALL Report program element monitored/inspected." Specifically, the enhancement element "parameters monitored/inspected." enhancement states the applicant applicant will "perform periodic periodic sampling of groundwater groundwater for pH, chloride concentration, concentration, and sulfate sulfate concentration."

The staff reviewed reviewed the applicant's Structures Monitoring Monitoring Program, and the AERM under under the the "parameters monitored / inspected" element of the Structures Monitoring Program. Program. The staff staff found it is not clear how the applicant applicant satisfies the GALLGALL Report recommendations recommendations for this this element, because the applicant does not include the frequency frequency of periodic sampling of ground water for pH, pH, chloride, and sulfate concentration.

concentration.

In RAI B.2.39-2, B.2.39-2, dated April 30, 2008, the staff requested requested that the applicant provide the time time frame for the "periodic" sampling, and the results for the last two samplings samplings of groundwater.

In its response to RAI B.2.39-2, dated dated June June 6, 2008, the applicant license applicant indicated that the license renewal commitment item renewal future commitment item number number 20 in the LRA table A.4-1 (Unit (Unit 1),

1), and future commitment item 22 in the LRA table A.5-1 (Unit 2), are revised to state that the implementation implementation schedule schedule for groundwater groundwater monitoring will begin five years prior to entering entering the period period of extended extended operation operation in 2016 for Unit 1 and in 2027 for Unit 2, then continue on a 5- year interval interval thereafter. The applicant applicant also provided the groundwater groundwater results for 2003 and 2007 as as follows: pH 6.87 and 6.83; chlorides 44.6 ppm and 208 ppm; sulfates 1.2 ppm and 187 ppm, respectively.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.39-2 B.2.39-2 acceptable acceptable because because the applicant has provided provided the time frame for the "periodic" sampling, sampling, and the results for the last two samplings of groundwater. The staff reviewed reviewed the applicant's responses responses and confirms that that the applicant's 5-year interval interval for monitoring the BVPS groundwater groundwater for non-aggressive non-aggressive water chemistry chemistry is in accordance accordance with the industry's standards standards and the results for pH were greater than 5.5; chlorides chlorides less than 500 ppm; and sulfates were were less than 1500 ppm. Therefore, the the staff's concern described described in RAI B.2.39-2 is resolved.

The staff notes that when the enhancement enhancement is implemented, implemented, the applicant's Structures applicant's Structures Monitoring Program will be consistent with GALL AMP XI.S6 and provide additional additional assurance assurance that the effects effects of aging will be adequately managed.

adequately managed.

Enhancement 5. In the LRA, the applicant Enhancement applicant credits an enhancement enhancement to the GALLGALL Report Report program program element element "parameters monitored/inspected."

monitored/inspected." Specifically, the enhancement enhancement states that the the applicant will "monitor elastomeric materials used in seals and sealants, including elastomeric materials including compressible compressible joints and seals, waterproofing waterproofing membranes, etc., associatedassociated with in-scope in-scope structures structures and structural structural components for cracking and change in material properties."

The staff reviewed reviewed the applicant's Structures Structures Monitoring Monitoring Program, Program, and the AERMAERM under the the "parameters monitored/inspected" element of the Structures "parameters monitored/inspected" element of the Structures Monitoring Program. The staff staff enhancement is to ensure that aging degradation found this enhancement degradation leading to loss of intended functions functions will be detected and the extent of degradation degradation can be determined.

determined. The staff finds this this enhancement acceptable enhancement acceptable because implemented, the applicant's because when it is implemented, applicant's Structures Monitoring Monitoring 3-146

Program Program will be consistent consistent with GALL AMP XI.S6 and provide provide additional additional assurance assurance that thethe effects of aging will be adequately managed.

In a letter dated September 8,2008, 8, 2008, the the applicant added added to LRA Commitment No. No. 22, to include include enhancements under new program enhancements under program elements "detection of aging effects," "monitoring and trending," and "acceptance criteria," as described below.

Enhancement 6. In LRA Enhancement LRA Commitment No. 22, the applicant credits an enhancement enhancement to the GALL Report program element "detection of aging effects." Specifically, the enhancement enhancement states measurements and/or characterizations that the applicant will "perform specific measurements characterizations of structural deficiencies based deficiencies based on the results of previous inspections and guidance from ACI 349.3R-96, 349.3R-96, Section 5.1.1, Section 5.1.1, and ACI201.1-68."

ACI 201.1-68."

The staff reviewed the applicant's applicant's Structures Monitoring Program, and the AERM under the the "detection of aging effects" element of the Structures Monitoring Program. The staff found this Structures Monitoring this enhancement acceptable because when the enhancement enhancement enhancement is implemented, the applicant's applicant's Structures Monitoring Monitoring Program Program will be consistent consistent with GALL AMP XI.S6 and will provide provide additional assurance assurance that the effects of aging will be adequately managed. managed.

Enhancement 7. In LRA Commitment No. 22, the applicant credits an enhancement Enhancement enhancement to the the program element "monitoring and trending." Specifically, the enhancement GALL Report program enhancement states states that the applicant will "document in the program inspection report a comparison of the results of the program inspections with the results of the previous program inspection, and to file the the Structures Monitoring Program inspection inspection reports in the BVPS document control system so that inspection results can be more effectively inspection effectively monitored."

The staff reviewed the applicant's applicant's Structures Monitoring Monitoring Program, and the AERM under the the "monitoring "monitoring andand trending" trending" element element ofof the the Structures Monitoring Program.

Structures Monitoring Program. The staff found this this enhancement acceptable enhancement because when the enhancement acceptable because enhancement is implemented, implemented, the applicant's applicant's Structures Monitoring Program will be consistent with GALL AMP XI.S6 and provide additional Structures Monitoring assurance assurance that the effects of aging will be adequately adequately managed.

managed.

Enhancement 8. In LRA Commitment Enhancement Commitment No. 22, the applicant enhancement to the applicant credits an enhancement the GALL Report program GALL Report program element "acceptance criteria." Specifically, the enhancement enhancement states states that the applicant will "apply inspection inspection acceptance acceptance criteria criteria based based on the results of past inspections inspections and guidance from ACI 349.3R-96, Section 5.1.1, and guidance 5.1.1, and ACI 201.1-68, and the deficiencies deficiencies will be be reported using the corrective action program."

program."

The staff staff reviewed reviewed the applicant's applicant's Structures Monitoring Monitoring Program, and and their their AERM AERM under the the "acceptance criteria" element of the Structures Monitoring Program. The staff this "acceptance criteria" element of the Structures Monitoring Program. found this enhancement enhancement acceptable acceptable because because when the enhancement enhancement is implemented, implemented, the applicant's applicant's Structures Structures Monitoring Program will be consistent Monitoring Program consistent with GALL GALL AMP XI.S6XI.S6 and provide provide additional assurance assurance that the effects effects of aging aging will be adequately adequately managed.

managed.

Operating Operating Experience.

Experience. TheThe staff also reviewed reviewed the operating operating experience experience provided provided in the LRA and Operation Operation Experience Experience Review Review Report, and interviewed interviewed the the applicant's applicant's technical technical staff staff to to confirm confirm that the plant-specific plant-specific operating operating experience experience has has been reviewed reviewed byby the the applicant applicant and and is evaluated evaluated in thethe GALL GALL Report. During its audit, the staffstaff noted noted that the applicant applicant does notnot include include the 2006 inspection inspection results.

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In RAI B.2.39-3, dated April 30, 2008, the staff requested requested that the applicant provide 2006 _

inspection inspection results versus versus the 1996 1996 baseline inspection inspection and 2001 inspection results versus 2006 inspection inspection results. The staff also requested requested that the applicant provide the location, location, size, and depth of the reappearing reappearing corroded steel found in the 2001 inspection, inspection, which was painted as a result of the 1996 baseline inspection.

In its response response to RAI B.2.39-3, dated June June 6, 2008, the applicant stated stated that the 2006 inspection report concluded, concluded, overall, that plant structures were in good condition and performing performing well. The inspection inspection found no conditions requiring immediate maintenance or repair. Minor immediate maintenance Minor conditions were noted and did not affect the structural structural integrity of any of the structures structures reviewed.

Many of the observed Many observed conditions were were noted for further review during the next inspection schedule. Conditions noted in the 2001 and 1996 inspections inspections and later revisited revealed that, in most cases, little or no change occurred from the previous observations. The applicant change had occurred applicant also stated that since little change change was evident from the 1996 1996 and 2001 inspections, inspections, and thethe conditions identified were considered considered minor in nature, the scheduled programmatic programmatic maintenance maintenance rule inspections provide reasonable reasonable assurance assurance that the effects effects of aging will be managed managed to ensure that the structural integrity integrity of plant systems, structures, and components will be be maintained during the period of extended maintained extended operation.

operation.

Based Based on its review, the staff finds that applicant's response B.2.39-3 acceptable response to RAI B.2.39-3 acceptable because because the applicant Structures Monitoring applicant verified that its Structures Monitoring (maintenance rule) Program is consistent with GALL ReportReport and provides additional assurance that the effects of aging will be be adequately managed.

adequately managed. Furthermore, the staff confirmed confirmed that the applicant applicant has has addressed experience identified operating experience identified after after the issuance issuance of the GALLGALL Report. The staff also finds that the applicant's Structures Monitoring Monitoring Program, with the corrective corrective actions discussed discussed in the LRA, has been been effective in identifying, monitoring, monitoring, and correcting correcting the effects effects of structures monitoring structures monitoring and can be expected expected to ensure that existing experience revealed no existing program operating experience no degradation degradation not bounded bounded by industry experience.

experience. Therefore, Therefore, the staffs staff's concern described described in RAI B.2.39-3 B.2.39-3 is resolved.

Based on its review review of the operating experience experience and discussions discussions with the applicant's technical staff, the staff concludes that the applicant's applicant's Structures Monitoring adequately Monitoring Program will adequately manage the aging effects that are identified identified in the LRA for BVPS for which this AMP is credited.

The staff confirmed that the "operating experience" program program element satisfies the criterion defined defined in the GALL Report and in SRP-LR Section A.1.2.3.1 A. 1.2.3.10.

O. The staff finds this program program acceptable.

element acceptable.

UFSAR Supplement. The applicant applicant provided the UFSAR UFSAR supplement supplement for the Structures Structures Monitoring Program Program in LRA Section A. 1.39. The staff reviewed this Section A.1.39. Section and finds the the supplement information an adequate UFSAR supplement adequate summary description of the program, program, as required by 10 CFR 54.21(d).

Conclusion, Based Conclusion. Based on its audit and review of the applicant's Structures Monitoring Program, Structures Monitoring Program, thethe staff determines program elements for which the applicant determines that those program applicant claimed consistency with the GALL Report Report are consistent. Also, the staff reviewed reviewed the enhancements enhancements and confirms that their implementation implementation prior to the period of extended operationoperation would make the existing AMP consistent Report AMP to which itit was compared. The staff concludes that consistent with the GALL Report that 3-148

the applicant demonstrated that effects applicant has demonstrated effects of aging will be adequately managedmanaged so that thethe intended function(s) will be maintained intended maintained consistent with the CLB for the period of extended operation, as required required by 10 CFR 54.21(a)(3). The staff staff also reviewed the UFSAR supplement supplement for this AMP and concludes concludes that it provides an adequate adequate summary summary description description of the program, as required required by 10 CFR 54.21(d).

3.0.3.2.13 Water Chemistry Program Program Technical Information Summary of Technical Information in the Application. In LRA Section Section B.2.42, B.2.42, the applicant applicant described described the existing Water Chemistry Program as consistent, with enhancement, with GALL Chemistry Program AMP XI.M2, "Water Chemistry."

Chemistry."

The Primary and Secondary Secondary Water Chemistry Chemistry Program Program mitigates damage caused by corrosion and SCC. The Water Chemistry Program monitors and controls water chemistry chemistry based on EPRI TR-105714, TR-105714, Revision 5 (TR-1002884), "PWR Primary Water Chemistry Chemistry Guidelines," EPRI Guidelines," and EPRI TR-1 02134, Revision 6 (TR-1 008224), "PWR Secondary (TR-1008224), Secondary Water Water Chemistry Chemistry Guidelines."

The One-Time One-Time Inspection Inspection Program Program will verify the effectiveness effectiveness of the Water Chemistry ProgramProgram circumstances described in the GALL Report that require augmentation for circumstances augmentation of the program.

Evaluation. In LRA Section B.2.42, the applicant Staff Evaluation. applicant stated that the Water Chemistry Program Chemistry Program is an existing existing program that is consistent with GALL Report AMP XI.M2, "Water Chemistry," with enhancement.

The staff reviewed those portions of the applicant's applicant's Water Chemistry Program that the applicant applicant claimed claimed consistency with GALL GALL AMP XI.M2 and found they are consistent with this GALL GALL AMP.

The staff also confirmed that the plant program program contains all of the elements of the referenced referenced GALL GALL program and the conditions conditions at the plant are bounded by the conditionsconditions for which the the GALL GALL Report Report is evaluated.

evaluated. The staff conducted conducted onsite interviews interviews with the applicant's applicant's technical staff to confirm these results.

The staff finds the applicant's applicant's Water Water Chemistry Chemistry Program, Program, as confirmed confirmed by the One-Time One-Time Inspection Program Program acceptable because it acceptable because conformsconforms to the recommended recommended GALL AMP XI.M2.

The staffs staffs review of the enhancement enhancement of the AMP that are taken against the program elements program elements in GALL AMP XI.M2 are evaluated in the subsections that follow.

Enhancements. In comparing the elements in the applicant's Water Chemistry Program, the Enhancements.

staff found that the applicant has taken enhancements enhancements as follows:

Change Change monitoring frequency for reactor coolant silica in "Monitoring and Trending." The The silica monitoring monitoring will be increased to once per week during Modes Modes 1 and 2, and once per day during heatup in Modes Modes 3 and 4.

The staff reviewed the enhancement enhancement and compared compared the changes with the GALL AMP XI.M2 XI.M2 recommendations for the enhanced element. The staff also reviewed the basis documents recommendations documents referenced referenced in the enhancements.

enhancements. The staff determined determined that implementation implementation of this enhancement enhancement will make the applicant's Water Chemistry applicant's Water Chemistry ProgramProgram consistent with the GALL AMP XI.M2.

XI.M2. The The applicant adopted more restrictive restrictive requirements for sampling sampling silica than those recommended recommended in in the GALL GALL Report. On this basis, the staff finds the enhancement enhancement acceptable.

acceptable.

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Operatingq Experience. In LRA Section B.2.42, the applicant Operating Experience. applicant provided the following operating operating experience experience evaluation evaluation for BVPS:

The BVPS Water Chemistry Program is based based on EPRI primary primary and secondary water chemistry guidelines, and and as such, is sensitive to industry operating operating experience. Operating experience experience events events are evaluated evaluated for potential potential inclusion in in subsequent revisions of the EPRI guidelines based on significance significance and frequency of occurrence. implementation of the EPRI occurrence. The implementation EPRI guidelines at BVPS is monitored using monitored using the Corrective Corrective Action Program and is validated using Nuclear using Nuclear Quality Assurance audits. During the interim interim between revisions to the EPRI EPRI experience from INPO is evaluated documents, operating experience evaluated for applicability applicability to to BVPS.

BVPS Unit 1 RCS zinc concentration occasionally out of specification concentration was occasionally specification between September of 2004 and November between November of 2006. Industry Industry operating operating experience demonstrated experience demonstrated that cracking in alloy-600alloy-600 is minimized minimized if zinc zinc concentration concentration is maintained at an optimumoptimum value. EvidenceEvidence at BVPS Unit 1 supports supports this assertion. The number number of PWSCC indications indications during the Unit 1 Cycle 16 Refueling Refueling Outage (October - November 2004) (following zinc injection) decreased decreased from a predicted predicted number of 25, to 5 actual indications.

Between July 2000 and September September 2006, secondary secondary chemistry parameters at*

chemistry parameters at both BVPS units were occasionally out-of-spec for sulfate, sodium, dissolved dissolved oxygen, oxygen, pH, and chloride concentration, concentration, resulting in potential chemistry action action level 1 conditions. The Corrective Corrective Action Program Program was used used to document and investigate investigate the reason(s) for these out-of-spec out-of-spec conditions and to recommend corrective corrective actions to restore the affected parameter(s) parameter( s) to an acceptable acceptable value value before aa plant shutdown is required.

demonstrated its responsiveness In December, 2002, BVPS demonstrated responsiveness to industry operating operating experience by applying experience applying a significant lesson lesson learned learned from a human-performance human-performance chemistry addition error which chemistry which occurred occurred several days earlier at another another plant. At BVPS, a chemistry technician independently chemistry technician independently performed a performed a self-check and determined determined that he was obtaining the wrong wrong chemical for addition to the the feedwater system. He was motivated to perform this self-check as aa result of a recent review review of an INPO operating experience INPO operating document which described a experience document similar error at another another plant in which the incorrectly incorrectly obtained chemical was was actually added to the secondary secondary system resulting in an unplanned unplanned plant plant shutdown. The technician's application of pertinent operating experience experience prevented this near miss from becoming a significant.

prevented significant plant plant event.

A Quality Assurance Assurance audit of the primary and secondary plant chemistry program program was conducted conducted in 2006. This audit revealed revealed that monitoring and action requirements for Primary requirements Primary and Secondary Secondary water water chemistry complied with BVPS BVPS Specifications, implementing Technical Specifications, implementing procedures, and the Licensing Requirements Manual (LRM). The BVPS chemistry sampling Requirements sampling guidelines and limits were consistent with industry guidelines endorsed by EPRI, EPRI, and were designed to extend the operating operating life of primary primary and secondary secondary systems and components. An example example of the BVPS adherence to chemistry control control is evident evident 3-150 3-150

primary chemistry from the primary chemistry performance performance indicator (percent of time that RCS RCS hydrogen, lithium, & & zinc concentrations concentrations were within spec), which for Unit 1 and Unit 2 (no zinc) during 2005, were 97% and and 99.8%,

99.8%, respectively.

Conformance procedural requirements Conformance to procedural requirements and industry guidelines, guidelines, and sensitivity to operating experience reports provide reasonable assurance provide reasonable assurance that the Water Chemistry program program will effectively manage loss of material, effectively manage material, cracking, cracking, and reduction reduction of heat transfer transfer for in-scope in-scope components components during the period of extended operation.

operation.

The staff noted noted that the applicant's applicant's operating operating experience demonstrates that the experience discussion demonstrates the applicant applicant has been effective in maintaining acceptable effective maintaining acceptable primary primary and secondary water quality quality at at Units 1 and 2, consistent with the applicable applicable EPRI guidelines guidelines for primary secondary water primary and secondary chemistry control and implements appropriate appropriate corrective corrective actions, self assessments and quality assurance assurance audits audits of the program. Based on its review and of industry and plant-specificplant-specific operating experience and discussions operating experience discussions with the applicant's technical personnel, the staff staff concludes concludes that the applicant's applicant's Water Chemistry Chemistry Program, will adequately manage manage the aging aging effects effects identified in the LRA for which this AMP is credited because: (a) the applicant is credited because:

implementing its program in accordance implementing accordance with appropriate appropriate EPRI guidelines guidelines on primary primary and secondary secondary water chemistry controls, (b) (b) operating experience over the last five years has operating experience has demonstrated demonstrated excellent conformance to the EPRI primary and secondary excellent conformance secondary water chemistry guidelines, guidelines, (c) the applicant appropriately appropriately takes promptprompt corrective actions when the water parameters for the primary chemistry parameters primary or secondary secondary coolants are out of specification specification with the the EPRI water water chemistry guidelines, and (d) (d) the program program includes includes periodic self assessments assessments and QA that are used to adjust and improve the programs based on past performance. performance.

UFSAR Supplement. The applicant provided the UFSAR supplement supplement for the Water Chemistry Program Program in LRA Section A.1.42. The staff reviewed reviewed this Section and determines determines that the the information in the UFSAR UFSAR supplement supplement provides an adequate adequate summary description the description of the program, consistent consistent with that provided provided in SRP-LR SRP-LR Table 3.1-2.

The staff reviewed the applicant's commitment commitment list in LRA Section A.4-1 for BVPS Unit 1 and Table Table A.5-1 for BVPS BVPSUnitUnit 2 in the UFSAR UFSAR supplement and confirms that the enhancementenhancement to the Water Chemistry Program is reflected in UFSAR Table A.4-1 for Unit 1 (Commitment No.23) and in UFSAR Table A.5-1 for Unit 2 (Commitment (Commitment No. 25).

The staff determines determines that the information in the UFSAR UFSAR supplement supplement provides an adequate adequate summary description of the program consistent consistent with the SRP-LR because the UFSAR SRP-LR because conforms to the guidance supplement conforms guidance in SRP-LR SRP-LR Table 3.1-2 and because the enhancement enhancement to to the program program has been reflected reflected in appropriate commitments appropriate commitments in the UFSAR supplement.

Conclusion. The staff reviewed reviewed the information provided provided by the applicant applicant in LRA Section Section B.2.42.

Based on its review, the staff finds the applicant's applicant's Water Water Chemistry Program Program acceptable acceptable because itit is consistent because consistent with the GALL Report, with enhancements, enhancements, and the plant is bounded by by the conditions set forth in the GALL GALL Report Report for this AMP. The staff finds that the program will adequately manage the aging adequately aging effects so that the intended functions will be maintainedmaintained consistent consistent with the CLB for the period of extended extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP finds that itit adequate summary provides an adequate description of the program, as required by 10 CFR 54.21(d).

summary description 54.21(d).

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3.0.3.3 AMPs Not Consistent 3.0.3.3 Consistent with or Not Addressed Addressed in the GALL GALL Report In LRA Appendix B, the applicant applicant identified the following AMPs as plant-specific:

" Electrical Cable Electrical Cable Connections Not Subject Subject to 10 CFR 50.49 Environmental Qualification 50.49 Environmental Qualification Requirements One-Time Inspection Requirements Inspection Program

• Electrical Wooden Poles/Structures Electrical Poles/Structures Inspection Inspection Program (Unit 2) 2)

• Reactor Reactor Vessel Vessel Integrity Integrity Program Program

• Settlement Monitoring Program (Unit Settlement Monitoring (Unit 2)

• Selective Leaching of Materials Selective Materials Program Program For AMPs not consistent consistent with or not addressed addressed in the GALL Report the staff's staffs complete complete review determined their adequacy determined adequacy to monitor or manage manage aging.

aging. The staffs review of these plant-specific AMPs is documented documented in the following sections.

3.0.3.3.1 Connections Not Subject to 10 CFR 50.49 Environmental 3.0.3.3.1 Electrical Cable Connections Qualification Qualification Requirements Requirements One-Time Inspection Inspection Program Program Summary Summary of Technical Information in the Application.

Technical Information Application. In LRA Section Section B.2.10, the applicant applicant described described the Electrical Cable Connections Connections Not Subject to 10 CFR 50.49 Environmental Environmental Qualification Qualification Requirements One-Time Inspection Program as a new plant-specific Requirements One-Time plant-specific AMP developed developed as an alternative alternative to GALL AMP XI.E6, XI,E6, "Electrical Cable Connections not Subject to 10 CFR 50.49 Environmental Environmental Qualification Qualification Requirements."

Requirements." This program will be be implemented prior to the period of extended operation.

implemented Evaluation. The staff reviewed the Electrical Cable Connections Staff Evaluation. Connections Not Subject to Subject to 10 10 CFR 50.49 Environmental Qualification Requirements Environmental Qualification Requirements One-Time One-Time Inspection Inspection Program against against the AMP elements found in SRP-LRSRP-LR Section A.1.2.3, and in SRP-LR Table Table A.1-1, A.1-1, focusing on how the program manages aging effects effects through the effective incorporation of 10 elements (i.

effective incorporation (i.e.,

e.,

"Scope of the Program," "Preventive Actions," "Parameters Monitored or Inspected," "Detection of Aging Effects," "Monitoring "Monitoring and Trending,"

Trending," "Acceptance Criteria," "Corrective Actions,"

"Confirmation Process," "Administrative Controls," and "Operating Experience").

Experience").

The program program elements (7) "Corrective Actions," (8) "Confirmation Process," and (9) site-controlled QA program. The staff's evaluation "Administrative Controls" are parts of the site-controlled evaluation of 7, 8, and 9 can be found in SER Section elements 7,8, Section 3.0.4. Evaluation of the remaining remaining seven elements follows:

Scope of Program. The "Scope of Program" program element criterion in SRP-LR SRP-LR Section Appendix A. 1.2.3.1 Appendix A.1.2.3.1 states that the program scope should include specific structures structures and components addressed by this program.

The applicant stated in the Electrical Cable Connections Connections Not Subject to 10 CFR 50.49 Environmental Qualification Environmental Requirements One-Time Qualification Requirements One-Time Inspection Program, for the "Scope of 3-152

program element, that this program Program" program program applies to Non-EQNon-EQ connections connections associated associated withwith cables within the scope of license renewal. This program does not include include the high-voltage high-voltage (>35 kV) switchyard connections. In-scope connectionsconnections are evaluated evaluated for applicability of thisthis program. The criteria for including including connections connections in the program program are that the connection is a bolted connection connection and is not covered under under the EQ program or an existingexisting preventive preventive maintenance maintenance program.

The staff staff determined determined that the specific commodity commodity groups groups for which the program program manages manages aging effects effects are identified (Non-EQ bolted cable identified (Non-EQ connections associated with cables within the scope cable connections scope of license renewal), which satisfies satisfies the criterion defined defined in SRP-LR Section A.1.1 O. The staff A. 1.10. staff also determined determined that the exclusion high-voltage (>35 kV) switchyard exclusion of high-voltage switchyard connections, connections covered under EQ program and an existing existing preventive maintenance program, preventive maintenance program, is acceptable. Switchyard Switchyard connections are addressedaddressed in SER Section 3.6.2.2.3. EQ cable cable connections connections are covered in accordance accordance with 10 10 CFR 50.49. Cable connections under preventive connections under preventive maintenance program maintenance periodically inspected.

program are periodically inspected. On this basis, the staff finds that the the applicant's applicant's scope of program program acceptable.

acceptable.

Preventive Actions. The "preventive actions" program Preventive program element element criterion in SRP-LR SRP-LR Section A.1.2.3.2 states that the activities activities for prevention prevention and mitigation mitigation programs programs should be be described. These actions should mitigate or prevent prevent aging degradation degradation and for condition or performance monitoring performance monitoring programs, preventive actions and thus, this programs, they do not rely on preventive this information information need not be provided. More More than one type of AMP may be implemented implemented to ensure that aging effects aging effects are managed.

applicant states The applicant Electrical Cable Connections states in the Electrical Connections Not Subject to 10 10 CFR 50.49 Environmental Qualification Requirements Environmental Qualification Requirements One-Time Inspection Program One-Time Inspection Program for the "preventive "preventive actions" program program element element that this one-time inspection program is a condition monitoring condition monitoring program; program; therefore, therefore, no actions are taken as part of this program program to prevent prevent or mitigate aging degradation.

degradation.

The staff determined determined that the preventive preventive actions program element element satisfies the criterion criterion defined in SRP-LR Section B.1.2.3.2. The staff finds this program element acceptable because because it is aa monitoring program and there is no need for preventive actions. On this basis, the condition monitoring the staff finds the applicant's applicant's preventive preventive actions acceptable.

acceptable.

Parameter Monitored/Inspected.

Monitoredllnspected. The "parameter monitored or inspected" program program element criteria in SRP-LR A. 1.2.3.3 states that the parameter SRP-LR Section A.1.2.3.3 parameter to be monitored monitored or inspected should be identified identified and linked to the degradation degradation of the particular particular structure and component component intended intended function(s). The parameter monitored parameter monitored or inspected inspected should detect the presence and extent of aging effects.

The applicant applicant states in the Electrical Electrical Cable Connections Not Subject Subject to 10 CFR 50.49 Environmental Qualification Requirements Environmental Qualification Requirements One-Time Inspection Program Program for the "parameters monitored/inspected" monitoredlinspected" program program element element that this program will focus on the metallic parts of the the cable connections. The one-timeone-time inspection verifies that loosening of bolted connections connections due to thermal cycling, cycling, ohmic heating, electrical electrical transients, vibration, chemical contamination, corrosion, and oxidation oxidation is not an issue that requires a periodic AMP.

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determined that the "parameters monitored/inspected" The staff determined monitored/inspected" program element satisfies satisfies the the criterion defined SRP-LR Section A.1.2.3.3. Loosening defined in SRP-LRSection Loosening (or high resistance) cable resistance) of bolted cable connections are potential aging effects due to thermal cycling, connections cycling, ohmic heating, heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. The design of bolted bolted cable connections usually usually account account for the above stressors. The one-time inspeCtion inspection is to confirm that these stressors are not an issue that requires a periodic AMP. On this basis, the staff finds finds that the applicant's applicant's parameters monitored or inspected parameters monitored inspected acceptable.

Aqing Effects. The "detection of aging effects" program element Detection of Aging SRP-LR element criteria in SRP-LR Section Section A.1.2.3.4 states that information information should be provided provided that links the parameters parameters to be be monitored monitored or inspected to the aging effects being managed; managed; describe describe when, where, and how program program data are collected collected (i.e., all aspects of activities to collect data data as part of the program);

link the method for the inspection population and sample size when sampling sampling is used to inspect inspect a group group of structures and components (SCs) and the inspection population population should be based on such aspects of the SCs as a similarity of materialsmaterials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

installation, operating The applicant states in the Electrical Electrical Cable Connections Connections Not Subject to 10 10 CFR 50.49 Environmental Qualification Environmental Qualification Requirements Requirements One-Time Inspection Program, the "detection of aging effects" program element, that aa representative representative sample of electrical connections connections within the the scope of license renewal, and subject to an AMR AMR will be inspected inspected or tested prior to the period period of extended extended operation, operation, to verify that there are no aging effects requiring managementmanagement during the the period of extended operation. The factors considered considered for sample selection will be application (medium (medium and low voltage), circuit loading (high (high load), and location (high(high temperature, high high humidity, vibration, etc.). The technical basis for the sample selected is to be documented.

sample selected Inspection methods Inspection methods may include include thermography, contact resistance testing, or other other appropriate appropriate methods, including visual, based on plant configuration configuration and industry guidance. The one-time one-time confirmation to support operating inspection provides additional confirmation experience that shows electrical operating experience connections connections have not experienced experienced a high degree degree of failures, and that existing installation installation and maintenance practices maintenance effective.

practices are effective.

GALL AMP XI.E6 states that testing may include thermography, contact resistance testing, and other appropriate testing methods. In the Electrical other appropriate Electrical Cable Connections Connections Not Subject Subject to 10 10 CFR 50.49 Environmental Environmental Qualification Qualification Requirements Requirements One-Time One-Time Inspection Inspection Program, the the applicant states that inspection inspection methods may include thermography, contact contact resistance resistance testing, or other appropriate including visual inspection appropriate methods including inspection based on plant configuration and industry guidance.

guidance. The staff determined determined that a one-time visual inspection may not be adequate adequate to detect heat or high resistance of loose cable connections.

In RAI B.2.10-1, B.2.1 0-1, dated May 15, 2008, the staff requestedrequested that the applicant provide provide a technical justification of how visual inspection, if used alone, will be sufficient justification sufficient to detect loss of preload or or loosening of bolted connections.

In its response to RAI B.2.10-1, B.2.10-1, dated June 17, 2008, the applicant stated the BVPS program program described described in LRA Section B.2.10 is revised to delete "visual inspection" as an alternative alternative toto thermography thermography or contact resistance resistance testing, because detection of aging effects for electrical cable cable connection connection is difficult using visual inspection inspection techniques. The applicant applicant further stated that LRA Section Section B.2.10 is revised revised to read:

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Detection Effects Detection of Aging Effects representative sample A representative sample of electrical electrical connections with the scope of licenselicense renewal, and subject to AMR review will be inspected or tested prior to the period extended operation to verity there are no aging effects requiring management of extended management during the period period of extended extended operation. The factors factors to be considered considered for sample sample selection will be application selection application (medium (medium and low voltage), circuit loading (high load),

and location (high temperature, temperature, high humidity, vibration, vibration, etc.). The technical basis technical basis for the sample selected selected is to be documented.

documented. Inspection methods methods will include include quantitative measurements such as thermography, contact quantitative measurements contact resistance resistance testing, or other appropriate appropriate methods based on plant configuration configuration and and industry guidance.

The one-time one-time inspection provides additional additional confirmation confirmation to support support industry experience that shows electrical operating experience electrical connections experienced a connections have not experienced high degree degree of failures, and that existing installation and maintenance maintenance practices practices are effective.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.10-1 B.2.1 0-1 acceptable because acceptable because that applicant applicant has verified that resistance measurement measurement or thermography thermography is a preferred preferred method for testing loose connections and these test methods are consistent with those in the loose cable connections the GALL AMP XI,E6.XI.E6. The staff confirms that the applicant has revised the LRA to reflect this this change. Therefore, described in RAI B.2.10-1 Therefore, the staff's concern described B.2.10-1 is resolved.

On this basis, the staff finds that the applicant's description description of parameters parameters monitored or inspected acceptable.

inspected acceptable.

Monitorinq Monitoring and Trendinq.

Trending. The "monitoring and trending" program program element element criteria in SRP-LR Section A.1.2.3.5 states that monitoring monitoring and trending activities should be described described and provide provide predictability predictability of the extent of degradation degradation and thus effect effect timely corrective corrective or mitigative mitigative actions.

This program describes how the data program element describes data collected collected are evaluated and may also include include parameter or indicator trended trending for a forward look. The parameter trended should be described.

described.

The applicant stated in the Electrical Electrical Cable Connections Not Subject to 10 10 CFR 50.49 Environmental Qualification Environmental Requirements One-Time Qualification Requirements Inspection Program for the "monitoring One-Time Inspection "monitoring and trending" program program element, that in this program, trending trending actions are not included because this is a one-time one-time inspection. The staff determined determined that absence absence of trending for testing is acceptable, acceptable, since the test is a one-time one-time inspection inspection and the ability to trend inspection inspection results is limited by the available data.

Furthermore, Furthermore, the staff determined determined no need for such activities. On this basis, the staff finds the the applicant's monitoring applicant's monitoring and trending acceptable.

acceptable.

Acceptance Criteria. The "acceptance criteria" program element criteria found in SRP-LR Section A.1.2.3.6 A.1.2.3.6 states that the acceptance acceptance criteria of the program program and its basis should be be described. The acceptance acceptance criteria, against which the need for corrective actions will be be evaluated, should ensure ensure that the SC intended intended function(s) are maintained under all CLB design conditions, during the period of extended extended operation. The program program should include methodology include a methodology for analyzing analyzing the results against applicable acceptance acceptance criteria. Qualitative inspections inspections should should be performed performed to the same predetermined predetermined criteria as quantitative inspections inspections in compliance compliance with ASME Code and through approved site-specific programs.

approved site-specific 3-155

The applicant applicant stated in the Electrical Electrical Cable Connections Not Subject Subject to 10 10 CFR 50.49 Environmental Environmental Qualification Requirements One-Time Inspection Qualification Requirements Inspection Program Program for the "acceptance criteria" program element, that the acceptance acceptance criteria criteria for each each inspection and/or and/or surveillance is defined by the specific type of inspection inspection or test performed performed for the specific type of cable cable connections. Acceptance Acceptance criteria ensure ensure that the intended functions of the cable connections cable connections can be maintained consistent with the CLB.

The staff determined that this program element satisfies the criteria criteria defined in SRP-LR Section A. 1.2.3.6. The staff finds exception A.1.2.3.6. exception acceptable on the basis that acceptance acceptance criteria criteria for inspection and/or surveillance are defined and/or surveillance defined by the specific specific type of inspection or test perform for the specific type of connection.

connection. When implemented, implemented, this program program will ensure that the license license renewal intended functions of the cable connections maintained consistent connections will be maintained consistent with the CLB.

OperatinQ Experience. The "operating experience" program element criterion in SRP-LR Operating SRP-LR Section A. 12.3.100 states that operating experience A.1.2.3.1 experience should provide objective evidence to to support the conclusion that the effects effects of aging will be managed adequately adequately so that the structure structure and component and intended function(s) will be maintained during component intended during the period of extended extended operation.

The applicant stated in the LRA supplement supplement for "operating experience" program program element, that the Electrical Cable Connections Connections Not Subject to 10 CFR 50.49 Environmental Environmental Qualification Qualification Requirements One-Time Requirements One-Time Inspection Inspection Program is a new AMP for which there is no plant-specific plant-specific experience for program program operating experience program effectiveness.

effectiveness. Industry Industry and plant-specific plant-specific operating operating experience will be evaluated in the development experience development and implementation implementation of this program.

program. Future operating experience will be appropriately operating experience appropriately incorporated incorporated into the program. IndustryIndustry operating operating experience that forms the basis for the program is described experience described in the operating experience experience element element of the GALL AMP XI.E6 program description. description.

In RAI B.2, dated May 22, 2008, the staff requestedrequested that the applicant applicant justify why there are no no operating experiences experiences for components under the new new programs.

In its response to RAI B.2, dateddated August 22, 2008, the applicant stated that the 2001 BVPS BVPS condition report report identified identified the failure of aa motor lead cable to lug connection connection and nearby nearby lug joint due to long-term heating and corrosion.

corrosion. The corrective actions from the condition report included an extent included extent of condition inspection of similar motor motor lead cable connections; this cable to lug connections; this inspection determined determined that the connections connections were satisfactory. Additionally, a self-assessment self-assessment of the entire entire splice program, including engineering specifications, including engineering specifications, procedures, work practices, training, and stock review was performed. The self-assessment self-assessment identified identified areas areas of concern and improvement that were entered into ,and improvement and resolved through the FENOe FENOC Corrective Action Corrective Action Program.

Program. The corrective actions from the self-assessment self-assessment resulted resulted in revisions to work and and training procedures, drawing changes, stock procurement procurement practices, and increased site site awareness. The applicant also stated that LRA Section B.2.1 B.2.10, Electrical Cable Connections 0, Electrical Connections Not Subject Subject to 10 CFR 50.49 Environmental Qualification Requirement Environmental Qualification Requirement One-Time Inspection, under under the operating experience, experience, states that "industry and plant-specific experience will plant-specific operating experience be evaluated evaluated in the development development and implementation implementation of this program. Future operating operating experience will be appropriately experience appropriately incorporated incorporated in the program." This second sentence differs sentence differs statement in other new AMP. Therefore, the applicant revised the LRA to make slightly from a statement this operating operating experience experience statement consistent with the corresponding corresponding statement statement in the other other new AMPs. The applicant revised LRA Section B.2.10, Section B.2.1 0, subsection subsection "Operating Experience",

second paragraph, second sentence, to read:

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Industry and plant-specific plant-specific operating operating experience will be evaluated evaluated in thethe development and implementation development implementation of this program. As additional operating operating experience experience is obtained, obtained, lesson learned will be appropriately incorporated into the appropriately incorporated the program.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2 acceptable because the acceptable because the applicant has identified applicant identified the operating operating experience experience with components components associated with the new AMP. The applicant's response included past corrective actions that provide evidence provide objective evidence to support the conclusion that the effects effects of aging will be adequately managed so that the the intended function(s) will be maintained during the period of extended extended operation.

operation. In addition, the the applicant will evaluate evaluate industry operating in the development industry and plant-specific operating development and implementation of this program implementation program and will incorporate incorporate lessons lessons learned into the program, program, as as additional additional operating experience experience is obtained.

obtained. On this basis, the staff concludes concludes that the the applicant's operating experience element operating experience element acceptable.

UFSAR Supplement.

Supplement. The applicant provided the UFSAR supplement supplement for the Electrical Cable Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Connections Environmental Qualification Requirements Requirements One-Time One-Time Inspection Program in LRA Sections A.

Inspection 1.100 and in supplemental A.1.1 supplemental LRA Appendix A.2.1.40. The The reviewed the UFSAR supplement staff reviewed supplement and determines determines that it provides provides an adequate adequate summary description of the program description program as required required by 1010 CFR 54.21 54.21(d).

(d). The staff also verified verified that applicant applicant has committed (Commitment No.3 No. 3 in UFSAR Supplement Supplement Table AA*1 A.4-1 and Commitment Commitment No.3 No. 3 in UFSAR Supplement Supplement Table A.5-1)A.5-1) to implement its new Electrical Cable Connections Connections Not Subject to 10 CFR 50.49 Environmental Qualification Qualification Requirements Requirements One-Time One-Time Inspection Inspection Program.

Program.

Conclusion. Based Based on its audit and review of the applicant's applicant's Electrical Electrical Cable Connections Connections Not Not Environmental Qualification Subject to 10 CFR 50.49 Environmental Qualification Requirements Requirements One-Time One-Time Inspection Inspection Program and RAI response, the staff finds that the applicant has demonstrated demonstrated that the effectseffects of aging will be adequately adequately managed so that the intended intended functions will be maintained maintained during the the period of extended operation, as required by 10 CFR 54.21(a)(3). 54.21(a)(3). Based on its review of the the UFSAR supplement supplement for this program, program, the staff finds that it provides an adequate summary description of the program, as required by 10 description 10 CFR 54.21(d).

3.0.3.3.2 Electrical Poles/Structures Inspection Electrical Wooden Poles/Structures Inspection Program (Unit 2) 2)

Summary of Technical Information in the Application. In LRA Section B.2.13, the applicant Technical Information applicant described the Electrical Wooden Poles/Structures Wooden Poles/Structures Inspection Program (Unit (Unit 2 only) as a new plant-specific program that will be implemented plant-specific implemented prior to the period of extended operation. This This program is applicable applicable only to Unit 2. There are no in-scope in-scope electrical electrical wooden poles/structures poles/structures at Unit 1.

Staff Evaluation. In accordance accordance with 10 10 CFR 54.21 (a)(3), the staff reviewed the information in LRA Section B.2.13 on the applicant's applicant's Electrical Wooden Wooden Poles/Structures Inspection Program Poles/Structures Inspection (Unit (Unit 2 only) to ensure that the effects of aging, will be adequately managed so that the intended adequately managed intended function(s) will be maintained maintained consistent with the CLB for the period of extended extended operation. The The staff reviewed reviewed the Electrical Wooden Poles/Structures Inspection Wooden Poles/Structures Inspection Program Program against against the the AMP elements elements found in SRP-LR SRP-LR Section A.1.2.3 A.1.2.3 and in SRP-LR A.1-1, focusing on how SRP-LR Table A.1-1, how the program manages manages aging effects through through effective incorporation of 10 elements (i.e.,

effective incorporation (Le., "scope 3-157 3-157

of the program," "preventive actions," "parameters monitored or inspected," "detection of aging aging effects," "monitoring and trending," "acceptance criteria," "corrective actions," "confirmation "confirmation process," "administrative controls," and "operating experience").

experience").

applicant indicated that program The applicant program elements elements (7)(7) "corrective actions," (8) "confirmation process," and (9) "administrative controls" are part of the site-controlled site-controlled QA program. The staff's evaluation of the QA program is found in in SER Section Section 3.0.4. The staff's evaluation evaluation of the the applicant's program elements follows:

applicant's 10 program Scope of the Program. The "scope of the program" program element criterion found in in SRP-LR SRP-LR Section A.1.2.3.1 states that the program program scope should include include the specific structures and addressed with this program.

components addressed program.

The staff reviewed reviewed the applicant's applicant's program program basis documents documents for this program element and found that a total of six poles comprise three H-frame structures (340436,340437,340438,340439, (340436, 340437, 340438, 340439, 340441) and are all within the scope of the program. The staff found this program 340440, 340441) element acceptable acceptable since it specifically specifically identifies identifies the components within the scope of the the Electrical Wooden Electrical Poles/Structures Inspection Wooden Poles/Structures Inspection Program.

The staff determined determined that the specific components for which manages aging effects which the program manages effects identified, which satisfies the criterion defined are identified, defined inin SRP-LR SRP-LR Section Section A.1.2.3.1.

A.1.2.3.1. On this basis, the staff finds the applicant's "scope of the program" elementelement acceptable.

Preventive Actions. The "preventive actions" program Preventive program element criterion in in SRP-LR SRP-LR Section A.1.2.3.2 states that condition monitoring programsprograms do not rely on preventive actions, preventive actions need not be provided.

and thus, preventive provided.

The applicant described this AMP as a condition applicant described condition monitoring AMP. The program does not support preventive preventive or mitigating actions. No actions actions are taken as part of this inspection inspection to prevent mitigate aging degradation.

prevent or mitigate degradation. The staff considers inspection activities activities a means means of detecting, preventing, aging and, therefore, agrees that no preventive actions are associated detecting, not preventing, inspection activity and none are required.

with the wooden pole inspection The staff confirmed confirmed that the "preventive "preventive actions" program elementelement satisfies satisfies the criterion defined defined in SRP-LR in SRP-LR Section A.1.2.3.2. On this basis, the staff finds this program element acceptable.

Parameters Monitored Parameters Monitored or Inspected. The "parameters monitored/inspected" monitored/inspected" program elementelement criterion in SRP-LR criterion in SRP-LR Section A.1.2.3.3 can be summarized summarized as follows:

The parameters parameters to be monitored or inspected inspected should be identified identified and linked to the degradation degradation of the particular particular SC intended function(s).

• monitoring programs, the parameter For condition monitoring parameter monitored or inspected inspected should detect the presence presence and extent of aging effects.

• For performance performance monitoring programs, a link should be established established between degradation degradation of the particular structure or component component intended function(s) and the the parameter being monitored.

parameter 3-158 3-158

• prevention and mitigation For prevention mitigation programs, the parameter monitoredmonitored should be the specific specific parameter parameter being controlled to achieve achieve prevention prevention or mitigation of aging effects.

The applicant applicant stated inin the Electrical Wooden Wooden Poles/Structures Inspection Program (Unit Poles/Structures Inspection (Unit 2 only) that the wooden poles are inspected inspected for loss of material due to insect and woodpecker woodpecker damage, reduced circumference, and moisture intrusion, and inspected inspected for change in in material material properties properties due to moisture damage. The visual inspection inspection portion of the activity activity also includes includes the the cross-arms, guys, hardware, hardware, static supports, and insulators.

In RAI In B.2.13-1, dated RAI B.2.13-1, dated April 30, 2008, the staff requested that the applicant applicant clarify thethe parameters of electrical parameters electrical wooden poles and/or structures structures that require inspection for aging effects effects and aging aging effects mechanisms mechanisms affecting the ability of the wooden poles to perform perform their intended function and to explain explain how the buried part of the wooden pole would be monitored monitored or or inspected.

inspected.

In In its response to RAI B.2.13-1, B.2.13-1, dated June 6, 2008, the applicant applicant stated that the buried portionportion of the pole will be partially excavated excavated for cleaning, inspection, and preservative preservative treatment.

Based Based on its review, the staff finds the applicant's response response to RAI B.2.13-1 acceptable acceptable because the applicant has confirmed that it it will provide guidance for visual inspections inspections (entire exposed portion and ground-level/below ground-level/below grade), sounding, sounding, and boring (as necessary necessary or select poles) to degradation that jeopardize detect aging and other degradation jeopardize the poles integrity and intended function such as, pole leaning leaning or tilt; physical mechanical damage; physical or mechanical damage or infestations damage; insect damage infestations (wood pole); change in in original grade; shell, butt, or internal internal rot or decay (wood pole); ground-ground-line or below grade degradation; degradation; failure or degradation degradation of reinforced portions; portions; broken or damaged damaged electrical electrical equipment; equipment; oxide formations in in advanced advanced stages; delamination delamination of steel plates; cracking (fatigue, stress, toe) caused by vibrations or manufacturingmanufacturing defects. Therefore, the staff's concern concern described in RAI B.2.13-1 in RAI B.2.13-1 is resolved.

The staff confirmed confirmed that the "parameters monitored monitored or inspected" program element element satisfies the the criterion defined defined inin SRP-LR Section Section A.1.2.3.3. On this basis, the staff finds this program program element element acceptable.

Detection Agingq Effects. The "detection of aging effects" program element criterion in Detection of Aging in SRP-LR SRP-LR Section A.1.2.3.4 A.1.2.3.4 can be summarized summarized as follows:

"

• Describe Describe when, where, and how program program data are collected collected (i.e.,

(Le., all aspects of activities activities to collect data as part of the program).

• • Link the method or technique and frequency, if if applicable, to plant-specific plant-specific or industry wide operating experience.

operating experience.

The applicant stated in in the Electrical Electrical Wooden Poles/Structures Poles/Structures Inspection Program (Unit 2 only)

Inspection Program that based on industry experience, experience, the typical life of a wooden pole is 30-40 years. The The applicant applicant also stated that industry experience experience over several decades decades indicates that a 10-year 10-year inspection interval is adequate.

The staff reviewed the applicant's program basis documents for this program element and finds The staff reviewed the applicant's program basis documents for this program element and finds that the applicant's inspection activity manages applicant's new inspection manages the aging for the electrical electrical poles and 3-159 3-159

structures within the scope structures scope of of license license renewal renewal and includes direction on 'when', 'where', and includes direction and

'how'.

'how'. Specifically, Electrical Wooden Specifically, the Electrical Wooden Poles/Structures Poles/Structures Inspection Program (Unit Inspection Program (Unit 22 only) only) will schedule visual schedule visual inspections inspections and testing testing for the the poles poles and and structures structures everyevery ten (10) years ten (10) years

('when'). The new inspection inspection activity activity shall outline components to outline the scope of components to be be inspected, inspected, including including those identified scope of license identified within the scope license renewal renewal ('where'). Finally, as stated stated in in the the other elements, elements, thethe new new activity activity shall provide inspection inspection guidance guidance such as visual, effective effective circumference, sounding, circumference, sounding, boring, excavation ('how'). The staff finds boring, and excavation finds the applicant's applicant's proposed 10-year proposed 1O-year inspection interval acceptable inspection interval because it is based on plant and industry acceptable because experience.

experience.

The The staff confirmed confirmed that the the "detection of aging effects" program program element element satisfies the the criterion criterion defined defined inin SRP-LR SRP-LR Section Section A.1.2.3.4. On this basis, finds this program basis, the staff finds program element element acceptable.

acceptable.

Monitoring and Monitoring "monitoring and trending" program Trending. The "monitoring and Trending. program element element criterion criterion in SRP-LR Section A.1.2.3.5 can be summarized summarized as follows:

"

• Monitoring Monitoring and trending activities should be described trending activities described and provideprovide predictability predictability of the the extent of degradation degradation and and thus effect timely corrective corrective or mitigative actions.

mitigative actions.

"

• This program program element describes how the data element describes data collected evaluated and may collected are evaluated may also also include include trending trending for aa forward look. The parameter parameter or indicator indicator trended trended should should be be described.

described.

The applicant applicant stated in the Electrical Poles/Structures Inspection Program (Unit 2 only)

Electrical Wooden Poles/Structures that this is not a trending activity. The The applicant applicant further stated the 1 10-year inspection provides O-year inspection provides identification of aging effects, with reports for timely identification reports generated responded to in a timely generated and responded timely manner. The first inspection performed within a 5-year period, prior to the expiration inspection will be performed expiration of the current license.

The staff determined inspection, this program element satisfies the criteria Of determined that for visual inspection, of SRP-LR SRP-LR Section A. 1.2.3.5.

A.1.2.3.5. The staff finds that the applicant's first inspection inspection will be performed 5-year period prior to the expiration of the current license and every 10 years after, within a 5-year In-house reviews of the results shall be performed industry experience. In-house based on industry performed to confirm that the wooden poles are capablecapable of continuing to perform their intended intended functions through the next inspection cycle. For these reasons, the staff finds the applicant's inspection applicant's "monitoring and trending" program element acceptable.

program acceptable.

Acceptance Criteria. The "acceptance criteria" program element criterion in SRP-LR Acceptance SRP-LR Section A.1.2.3.6 can be summarized summarized as follows:

• " acceptance criteria of the program and its basis should be described.

The acceptance described. The The acceptance acceptance criteria, against which the need for corrective actions will be evaluated, evaluated, should ensure that the SC intended function(s) are maintained maintained under all CLB design conditions during the period of extended operation. operation.

• " The program should include a methodologymethodology for analyzing the results against applicable applicable acceptance criteria.

acceptance 3-160

• • inspections should be performed Qualitative inspections performed to the same predetermined predetermined criteria criteria as as quantitative inspections inspections by personnel personnel in accordance accordance with the ASME Code and through through site-specific programs.

approved site-specific The applicant applicant stated in the Electrical Wooden Poles/Structures Poles/Structures Inspection Inspection Program (Unit(Unit 2 only) that the acceptance acceptance criteria criteria is no unacceptable unacceptable indications indications of loss of material, or change in material properties are found as determined determined by a qualified qualified inspector.

During the audit and review, the staff reviewedreviewed this program element from the applicant's applicant's documents to determine whether program basis documents whether it satisfies the criteria of SRP-LR SRP-LR Section A. 1.2.3.6. The staff found that the applicant's A.1.2.3.6. applicant's Electrical Wooden Poles/Structures Poles/Structures Inspection Program (Unit 2 only) procedure Inspection procedure specified the inspection methods and any applicable applicable acceptance acceptance or rejection criteria.

criteria. In addition, the applicant applicant will develop detailed qualification qualification and experience experience requirements requirements for personnel inspection results will be personnel performing the inspections. The inspection be used to evaluate the capability of a degradeddegraded pole to assess its ability to continue performing performing its load-carrying intended intended functions. The staff confirmed confirmed that the "acceptance "acceptance criteria" program program element element satisfies the criterion defined in SRP-LR Section A.1.2.3.6. On this basis, the staff finds finds this program program element acceptable.

Corrective Actions. The adequacy Corrective adequacy of the applicant's applicant's 10 CFR Part 50 Appendix B Program, associated with this program program element, is discussed discussed in SER Section 3.0.4.

The staff reviewed the other aspects of this program to determine determine whether or not itit satisfies the satisfies the criteria defined in SRP-LR Section A.1.2.3.7.A.1.2.3.7. The staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable acceptable to address corrective corrective actions. On this basis, the staff finds this this program element program element acceptable.

Confirmation Process. The adequacy adequacy of the applicant's applicant's 10 CFR Part 50, Appendix Program, Appendix B Program, associated with this program program element, is addressed addressed in SER Section 3.0.4.

The staff reviewed the other aspects of this program to determine whether or not it satisfies satisfies the the criteria defined in SRP-LR Section Section A. 1.2.3.8.

A.1.2.3.B. The staff finds the requirements requirements of 10 CFR Part 50, Appendix B, acceptable acceptable to address a confirmation confirmation process. On this basis, the staff finds this this program element element acceptable.

Administrative Controls. The adequacy Administrative adequacy of the applicant's applicant's 10 CFR Part 50, Appendix B Program, associated with this program program element, is addressed addressed in SER Section Section 3.0.4.

The staff reviewed reviewed the other aspects of this program element element to determine determine whether or not it satisfies the criteria defined in SRP-LR SRP-LR Section A.1.2.3.9.

A.1.2.3.9. The staff finds the requirements requirements of 10 CFR Part 50, Appendix B, acceptableacceptable to address administrative administrative controls. On this basis, the the staff finds this program program element element acceptable.

Operatingq Experience. The "operating experience" program Operating Experience. program element element criteria in SRP-LR Section A.1.2.3.100 can be summarized Section A.1.2.3.1 summarized as follows:

• Operating experience should provide objective Operating experience objective evidence to support the conclusion that the effects of aging aging will be managed managed adequately adequately so that the SC intended function(s) function(s} will be maintained maintained during the period period of extended extended operation.

operation.

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• The applicant may have to commit experience in the future for commit to providing operating experience new programs to confirm their effectiveness.

effectiveness.

The applicant stated in the Electrical Wooden Wooden Poles/Structures Inspection Program Poles/Structures Inspection Program that thisthis AMP is a new program and there is no plant-specific program operating plant-specific program operating experience for program program experience that forms the basis for the program effectiveness. Industry operating experience effectiveness. described in program is described the operating experience element of the SRP-LR. Industry and plant-specific operating experience plant-specific operating experience will be evaluated in the development experience implementation of this program. As development and implementation As operating experience is obtained, lessons learned will be appropriately additional operating appropriately incorporated incorporated into the program.

reviewed the operating During the audit and review, the staff reviewed experience evaluation operating experience evaluation reports and applicant's technical interviewed the applicant's also interviewed personnel and confirmed technical personnel plant-specific operating confirmed that plant-specific operating experience revealed no degradation experience revealed degradation not bounded applicant also bounded by industry experience. The applicant indicated that as additional operating indicated operating experience lessons learned will be experience is obtained, lessons be appropriately incorporated into the program. The staff determined appropriately incorporated that these operating determined that operating experience provide objective experience events provide evidence that the Electrical objective evidence Poles/Structures Electrical Wooden Poles/Structures Inspection Program will provide timely detection of aging degradation corrective action.

degradation and corrective The staff confirmed that the "operating experience" programprogram element satisfies the criterion criterion defined in SRP-LR Section A.1.2.3.1 defined A.1.2.3.10.O. On this basis, the staff finds this program element acceptable.

acceptable.

Based on its review of the operating experience and discussions with the applicant's operating experience applicant's technical staff, the staff concludes that the applicant's Electrical Wooden applicant's Electrical Poles/Structures Inspection Wooden Poles/Structures Program will adequately manage the aging effects identified in the LRA for which this AMP is adequately manage credited.

UFSAR Supplement. The applicant provided the UFSAR supplement Electrical Wooden supplement for the Electrical Poles/Structures Inspection Program in LRA Section A.1.13. The staff reviewed Poles/Structures reviewed this Section Section and finds the UFSAR supplement information an adequate supplement information adequate summary description program, as description of the program, as required by 10 CFR 54.21(d).

applicant's Electrical Wooden Conclusion. Based on its review of the applicant's Wooden Poles/Structures Poles/Structures demonstrated that effects of Inspection Program, the staff concludes that the applicant has demonstrated Inspection adequately managed aging will be adequately maintained consistent managed so that the intended function(s) will be maintained with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

of extended 54.21(a)(3). The staff staff UFSAR supplement for this AMP and concludes that it provides an adequate also reviewed the UFSAR adequate summary description description of the program, program, as required by 10 CFR 54.21 (d).

54.21(d).

3.0.3.3.3 Nozzles and Penetrations 3.0.3.3.3 Nickel-Alloy Nozzles Penetrations Program Summary Summary of Technical Information in the Application.

Technical Information B.2.28, the applicant Application. In LRA Section B.2,28, applicant described described the Nickel-Alloy Penetrations Program as a condition monitoring Nickel-Alloy Nozzles and Penetrations monitoring program designed program manage the effects designed to manage effects of PWSCC in nickel-alloy components (other in nickel-alloy RCPB components nozzles) for Units 1 and 2.

penetration nozzles) the RV closure head penetration Regulatory Assessment Evaluation - Regulatory Staff Evaluation Assessment Criteria. In the GALL Report, Volume 2, Tables IV.A2 IV.A2 applicant's Water recommends that an applicant's and IV.C2, the staff recommends Water Chemistry Program and ASME ASME 3-162 3-162

Code Section Section XI, Subsections IWB, IWC, and IWD Program be credited credited to manage manage cracking cracking due due to PWSCC of nickel-alloy nickel-alloy RV components, piping components, pressurizer components, components, and some SG components (including any associated components (including associated nickel-alloy welds) in the RCPB. For these these components, the staff also recommends recommends that an applicant provide applicant provide a a commitment on the the application to:

Comply with applicable NRC Orders Orders and provide a commitment commitment in the FSAR supplement supplement to submit a plant-specific AMP to implement applicable (1) Bulletins Bulletins and Generic Generic Letters and (2) staff-accepted staff-accepted industry industry guidelines.

This approach approach to aging management management conforms conforms to the staffs recommended aging staff's recommended management aging management guidelines guidelines provided provided in the following sections sections of the SRP-LR:

• • Section 3.1.2.2.13 - Cracking Cracking due to Primary Water Stress Corrosion Cracking Cracking (PWSCC)

• " Section 3.1.2.2.16 - Cracking Cracking due due to Primary Water Water Stress Corrosion Cracking Cracking (PWSCC) (applicable (applicable to steel steam generator generator upper and lower lower heads, tubesheets, and tube-to-tube tube-to-tube sheet welds made or clad with nickel-alloy nickel-alloy and nickel-alloy nickel-alloy pressurizer pressurizer spray heads)

This recommended recommended aging management management approach approach does not apply to the nickel-alloy nickel-alloy materials materials used in the fabrication of upper penetration nozzles upper RV closure head penetration nozzles and welds, SG tubes, SG sleeves, SG plugs, or SG divider plates. For these nickel-alloy nickel-alloy components, the GALL Report management recommendations has different aging management recommendations which may be found in the applicable AMRs AMRs in GALL Report Report Tables IV.A2 for RV components or IV.D1 for recirculating recirculating SG designs.

Staff Evaluation. The staff reviewed information in LRA Section B.2.28, the applicant's reviewed the information applicant's license renewal basis document for this AMP, and other supporting information and documents documents that pertain pertain to the procedural p~ocedural and implementation implementation controls for this AMP, against the regulatory criteria summarized summarized in the above Staff Evaluation section.

The staff noted noted that, in LRA Tables 3.1.2-1 3.1.2-3, the applicant credited its Nickel-AlloyNickel-Alloy Nozzles and Penetrations Nozzles Penetrations Program, as the basis for managing cracking cracking due due to PWSCC in the the nickel-alloy component majority of the nickel-alloy component commodity groups groups used in the fabrication of the RVs, pressurizers, Class 1 piping systems, and SGs for Units 1 and 2. The staff also noted that the pressurizers, the applicant's applicant's Nickel-Alloy Nozzles and Penetration Program does not have a specific specific corresponding program in the GALL Report, Volume 2, Chapter XI. The staff determined corresponding determined that that ifif the applicant was tying its basis for aging management Nickel-Alloy Nozzles and management to the Nickel-Alloy Penetrations Program, Penetrations Program, then the AMP must be defined as plant-specific plant-specific in the LRA.

In RAI B.2.28-1, B.2.28-1, dated June requested that the applicant June 5, 2008, the staff requested applicant justify why the the Nickel-Alloy Nozzles Nickel-Alloy Nozzles and Penetration Penetration Program Program had not been identified as a plant-specific plant-specific AMP and the programprogram elements elements for this AMP provided in the LRA. (Note: The staff evaluates evaluates the applicant's applicant's response to RAI B.2.28-1 B.2.28-1 later in this evaluation in conjunction with the staff's staff's evaluation evaluation of the applicant's applicant's response to RAI B.2.28-2).

The staff reviewed the applicant's response and finds that it adequately identified that intent of The staff reviewed the applicant's response and finds that it adequately identified that intent of the Nickel-Alloy Nickel-Alloy Nozzles and Penetrations Penetratio"ns Program was to commit toward development of aa toward development 3-163 3-163

plant-specific plant-specific AMP as stated in LRA Section A.1.28. A.1.2B. The commitment includesincludes the the implementation implementation of NRC Orders, Bulletins and GLs, and staff-accepted staff-accepted industry guidelines.

guidelines. ThisThis clarification clarification removed removed the perceived linkage to the applicant's Nickel-Alloy Nozzles applicant's stated Nickel-Alloy Nozzles and Penetrations Penetrations Program, which was only included included as a review guide and therefore no program elements are described. Therefore, Therefore, the staffs concern concern described described in RAI B.2.2B-1 B.2.28-1 is resolved.

The staff noted noted that in the specific AMR items for PWR nickel-alloy components in GALL Report nickel-alloy components Tables IV.A2, IV.C2, and IV.D1,IV.D1, the staff recommends recommends that the type of commitment mentioned mentioned in the staff evaluation evaluation be credited, in part, as the basis for managing managing the effects of agingaging for the the a vast majority of the nickel-alloy nickel-alloy components within the scope of the LRA. The staff reviewed reviewed the technical and regulatory information information in the Nickel-Alloy Nickel-Alloy Nozzles and Penetrations Penetrations Program and verified that the applicant applicant had provided the following commitments commitments for its nickel-alloy nickel-alloy components in LRA Table A.4-1 for Unit 1 (Commitment (Commitment No. 15) 15) and in LRA Table Table A.5-1 for for Unit 2 (Commitment (Commitment No. 17): 17):

For the Nickel-Alloy Nickel-Alloy Nozzles Nozzles and Penetrations Penetrations Program, Program, regarding regarding activities for managing the aging of nickel-alloy nickel-alloy components and nickel-alloy nickel-alloy clad components components susceptible to primary primary water stress corrosion corrosion cracking - PWSCC (other than upper reactor vessel closure head head nozzles nozzles and penetrations),

penetrations), BVPS commits to to management program that will implement develop a plant-specific aging management implement applicable: 1. NRC Orders, Bulletins and GenericGeneric Letters; and, 2. Staff-accepted Staff-accepted industry guidelines.

guidelines.

The staff noted, however, that the applicant applicant did not specifically nickel-alloy specifically identify which nickel-alloy component commodity commodity groups at Units 1 and 2 were specifically within the scope of the the Nickel-Alloy Nozzles and Penetrations applicant's Nickel-Alloy Penetrations Program and these regulatory commitments.

In RAI B.2.2B-2, B.2.28-2, dated June 2008, the staff requested June 5, 200B, requested that the applicant clarify which nickel-alloy component nickel-alloy component commodity groupsgroups at Units 1 and 2 are within the scope scope of the the applicant's Nickel-Alloy Nickel-Alloy Nozzles and Penetrations Program and the scope of LRA Commitments Commitments No. 15 and No. 17 for Unit 1 and Unit 2, respectively.

In its response to RAls RAIs B.2.2B-1 B.2.28-1 and B.2.2B-2, B.2.28-2, dated July 21, 2008 the applicant 21, 200B applicant stated that the the Nickel-Alloy Nickel-Alloy Nozzles and Penetrations intended to be defined Penetrations Program was not intended defined as an AMP with program elements the 10 program elements recommended recommended in SRP-LRSRP-LR Section A. 1.2.3. The applicant clarified A.1.2.3. clarified that, instead, the Nickel-Alloy Nickel-Alloy Nozzles and Penetrations Penetrations Program Program was intended to identifyidentify and establish the applicable commitment commitment for nickel-alloy nickel-alloy components other than those in the upper upper RV closure closure head, as recommended recommended in GALL Report Tables IV.A2 for PWR RV components, Report IV.C2 IV.C2 for PWR piping piping and pressurizer components, and IV.D1 pressurizer components, IV.D1 for recirculating recirculating SG components.

explained that Nickel-Alloy The applicant explained Nozzles and Penetrations Nickel-Alloy Nozzles Penetrations Program was incorporated incorporated into the LRA only to establish the wording for the LRA's commitments commitments for ASME ASME Code Class 1 nickel-alloy components nickel-alloy components and pressure pressure retaining welds and to simplify identification identification and review of the relevant AMRs in the application.

application.

The applicant explained that in order to resolve this issue, itit amended amended the LRA for BVPS to to delete the Nickel-Alloy Nozzles and Penetrations Nickel-Alloy Nozzles Penetrations Program Program and to revise UFSAR UFSAR Supplement Supplement Section A. 1.28. The applicant A.1.2B. applicant also stated that, in order to properly properly cross-reference cross-reference to the the appropriate commitments, the relevant AMRs in LRA Tables 3.1.2-1 are amended appropriate delete amended to delete references to the Nickel-Alloy Nozzles and Penetrations Program, references Program, and instead, include include 3-164 3-164

references to the commitments references commitments provided in UFSAR Supplement Supplement Tables A.4-1 for Unit 1 (Commitment (Commitment No. 15) and A.5-1 for Unit 2 (Commitment (Commitment No. 17). The staff verifiedverified that the the applicant has made the applicable applicable amendments amendments of the LRA.

Based on its review, the staff finds that the applicant's applicant's responses to RAls RAIs B.2.28-1 B.2.28-1 and B.2.28-2 are acceptable acceptable because the applicant has amended amended the LRA to delete the Nickel-Alloy Nozzles Nickel-Alloy Nozzles Penetrations Program and the UFSAR and Penetrations UFSAR supplement for this AMP from the scope of license license renewal and has amended renewal amended the AMR items for the nickel-alloynickel-alloy Class 1 components components to directly refer to the applicant's aging management management commitments commitments for ASME ASME Code Class 1 nickel-alloy nickel-alloy components components and pressure pressure retaining retaining welds. Therefore, the staff's concerns described described in RAIs RAls B.2.28-1 and RAI 2.28-2 2.28-2 are resolved.

With respect to the acceptability of these commitments, the staff finds the provisions of LRA Commitments No. 15 for Unit 1 and No. 17 for Unit 2 acceptable Commitments because they conform to the acceptable because the commitment commitment criteria recommendations discussed in the Staff Evaluation Section of this recommendations discussed this evaluation.

evaluation. The staff also verified verified that LRA Table A.4-1 indicates that Commitment Commitment No. 15 for for implementation by January Unit 1 is scheduled for implementation January 29,2016, 29, 2016, and that Commitment Commitment No. 17 for Unit 22 is scheduled for implementation implementation by May 27,2027. 27, 2027. The staff finds these implementation implementation dates acceptable for aging management dates acceptable management during the period period of extended extended operation because the operation because the operating licenses operating licenses for Units 1 and 2 will expire on January January 29, 2016 and May 27,2027, 29,2016 27, 2027, respectively.

Thus, the staff finds that the applicant's revised aging management basis for the ASME aging management ASME Code Class 1 nickel-alloy components acceptable nickel-alloy components because: (a) the relevant acceptable because: relevant AMRs for thesethese nickel-alloy components appropriately nickel-alloy components appropriately reflect and credit the applicant applicant Water Chemistry Program, ASME Code Section XI InserviceInservice Inspection, Inspection, Subsections Subsections IWB, IWC and IWD Program; Program; (b) the (b) the applicable AMRs have been amended applicable amended to delete references to Nickel-Alloy Nozzles and Nickel-Alloy Nozzles Penetrations Program Program and instead instead to point directly to the applicant applicant commitments for nickel-alloy nickel-alloy components and pressure components pressure retaining welds provided in UFSAR UFSAR Supplement Supplement Table A.4-1 for for Unit 1 (Commitment (Commitment No.15) and UFSAR Supplement Table A.5-1 for Unit 2 (Commitment (Commitment No.

17); and (c) the change change in the AMRs makes the AMRs for these components AMRs makes components consistent consistent with the the AMRs for nickel-alloy nickel-alloy components described in the GALL Report Revision 1, Volume 2, Tables IV.A2, IV.C2, and IV.D1.IV.D1.

accepted the applicant's basis for deleting this AMP from the LRA, the staff Since the staff has accepted staff finds that there is no reason to perform a program program element- by- program program element evaluation of the Nickel-Alloy Nickel-Alloy Nozzles Penetrations Program that was originally Nozzles and Penetrations originally docketed docketed in the LRA.

Operating Experience.

Operating Experience. The staff noted that the industry experience identified identified in NRC Bulletins Bulletins applicable to the applicant's Nickel-Alloy 2003-02 and 2004-02 is applicable Nickel-Alloy Nozzles Penetrations Nozzles and Penetrations Program. The staffstaff considers considers this AMP to be an existing program because the applicant is existing program already implementing already implementing its current regulatory commitments for non-RV closure head penetration regulatory commitments penetration nozzle nickel-alloy nickel-alloy components, as confirmed in its responses to NRC Bulletin 2003-02, dated September 19, 2003, December 2, 2003, December 29, 2004, and May 24, 2005, and to NRC September NRC Bulletin 2004-01 dated July 27, 2004, December 27,2004, December 29,2004, 29, 2004, and May 19, 19, 2005.

In RAI B.2.28-3, Part A, dateddated June June 5, 2008, the staff requested that the applicant clarify staff requested whether whether NRC BulletinsBulletins 2003-02 2003-02 and 2004-01, 2004-01, the applicant's applicant's responses responses to these Bulletins, and any regulatory commitments made made in response to these Bulletins are within the scope of the the 3-165 3-165

applicant's applicant's Nickel-Alloy Nickel-Alloy Nozzles and Penetrations Program and the license renewal commitment(s) for this program program for Unit 1 or Unit 2.

The staff also determined determined as part of its review of the CLB that on February February 27, 2007, the the supplemental commitment on monitoring activities for nickel-alloy applicant provided a supplemental dissimilar nickel-alloy dissimilar metal welds used in the Unit 1 pressurizer pressurizer design, and that the NRC approved approved these actions in a Confirmatory Action Letter dated March 20, 2007.

In RAI B.2.28-3, Part B, dated June June 5, 2008, the staff requested that the applicant clarify whether its letter of February February 27,2007 27, 2007 and any commitments commitments or actions made in this letter, and and staff's basis for approval approval in the Confirmatory Action Letter of March 20, 2007, are within the the scope of the applicant's Nickel-Alloy Nickel-Alloy Nozzles Nozzles and Penetrations Penetrations Program Program and the applicable applicable license license renewal renewal commitment(s) commitment(s) for this program for Unit 1 or Unit 2.

In RAI B.2.28-3, Part C, dateddated June June 5, 2008, the staff requested that the applicant identify any applicant identify additional communications, and BVPS specific response and commitments additional NRC generic communications, commitments made made to these additional generic generic communications communications that are within the scope of the applicant's applicant's Nickel-Alloy Nozzles and Penetrations Nickel-Alloy Penetrations Program and the applicable license renewal commitments commitments for this program (i.e., Commitment Commitment No. 15 for Unit 1 and/or to Commitment Commitment No. 17 for Unit 2).

In its response response to RAI B.2.28-3, Parts A, B, and C, dated July 21, 21, 2008, the applicant applicant stated that the LRA Section B.2.28 was not intended to be a defined AMP with 10 10 elements. The applicant applicant Nickel-Alloy Nozzles clarified that, instead, the Nickel-Alloy Nozzles and Penetrations intended to Penetrations Program was intended to identify and establish the applicable commitment for nickel-alloy applicable commitment nickel-alloy components components other than those in the upper RV closure closure head, as recommended recommended in the GALL Report Tables IV.A2 (for PWR RV components), IV.C2IV.C2 (for PWR piping and pressurizer pressurizer components), and IV.D1 PWR IV.D1 (for PWR recirculating SG components). The applicant recirculating explained that Nickel-Alloy applicant explained Nickel-Alloy Nozzles Nozzles and Penetrations Program Penetrations Program was not intended to be an AMP per se, but instead instead was incorporated incorporated into into the LRA only to establish the commitment commitment wording wording for the LRA and to simplify identification identification and review of the relevant AMRs in the application.

application.

applicant explained that in order to resolve this issue, it has amended The applicant amended the LRA for BVPS to to Nickel-Alloy Nozzles delete the Nickel-Alloy Nozzles and Penetrations Penetrations Program and to revise UFSAR UFSAR Supplement Section A.1.28. The applicant applicant also stated that, in to order properly cross-reference cross-reference to thethe appropriate commitments, the relevantrelevant AMRs in LRA Tables 3.1.2-1 3.1.2-1 are amended amended to delete delete references to the Nickel-Alloy references Nickel-Alloy Nozzles Nozzles and Penetrations Penetrations Program, Program, and instead, include include references to the commitments references provided in UFSAR Supplement Tables A.4-1 for Unit 1 commitments provided (Commitment No. 15) and A.5-1 for Unit 2 (Commitment No.17). The staff confirmed that the the applicant has made the applicable applicable amendments amendments to the LRA.

Based on its review, the staff finds the applicant's applicant's response to RAI B.2.28-3, Parts A, B, and C acceptable acceptable because that applicant has amended the LRA to deletedelete the Nickel-Alloy Nickel-Alloy Nozzles and Penetrations Program and the AMR items for the nickel-alloy Penetrations nickel-alloy Class 1 components components to directly directly management commitments refer to the applicant's aging management commitments for these components. The staff staff also finds the applicant's applicant's response acceptable because response acceptable because the scope of the applicant's commitments commitments in LRA Tables Tables A.4-1 for Unit 1 (Commitment (Commitment No. 15) A.5-1 for Unit 2 (Commitment (Commitment No.17) includeinclude the applicant's:

applicant's: (a) past commitments in response to applicable NRC Orders, Bulletins Bulletins and GLs GLs on nickel-alloy component component cracking (as discussed discussed the paragraphs paragraphs below), (b) (b) future future 3-166 3-166

commitments commitments made to any NRC Orders, Bulletins Bulletins and GLs on nickel-alloy nickel-alloy component cracking cracking that may be issued in the future and/or (c) commitments commitments to staff-accepted staff-accepted industry guidelines on industry guidelines management of cracking management cracking in Class 1 nickel-alloy component component during the period of extended operation. Therefore, Therefore, the staffs concerns raised in RAI B.2.28-3, Parts A, B, and Care C are resolved.

The staff noted noted that the current generic communications current NRC generic communications that relate to aging management aging management of cracking in the nickel-alloy nickel-alloy components for Units 1 and 2 are NRC Order EA-03-009 Order EA-03-009 (February 11, 2003), as amended (February 11,2003), amended in First Revised NRC Order Order EA-03-009 (February (February 20, 2004),

20,2004),

applicable applicable to cracking cracking of nickel-alloy nickel-alloy base metal nozzles nozzles and pressure retaining welds in PWR PWR upper RV closure heads; NRC Bulletin Bulletin 2003-02 (August 21, 2003), applicable 21,2003), applicable cracking in PWR PWR instrumentation nozzles with nickel-alloy RV bottom mounted instrumentation nickel-alloy pressure retaining retaining welds; and NRC Bulletin 2004-01 (May 28, 2004), applicable (May 28,2004), applicable to cracking cracking in nickel-alloy nickel-alloy components components and pressure retaining welds in PWR pressurizers. documents are publicly available at the pressurizers. These documents the following NRC public web site web addresses:

http://www. nrc.qov/reactors/operatinq/ops-experience/vessel-head-http://www.nrc.gov/reactors/operating/ops-experience/vessel-head-degqradation/vessel-head-deq radation-files/order-rpv-inspections. pdf degradation/vessel-head-degradation-files/order-rpv-inspections.pdf http://adamswebsearch2.nrc.qov/idmws/doccontent.dll?library=PU ADAMS"PBN http://adamswebsearch2.nrc.gov/idmws/doccontent.dll?library=PU ADAMSAPBN TAD01&ID=042010213 TAD01&ID=042010213 http://www.nrc.qov/reading-rm/doc-collections/qen-http://www.nrc.gov/reading-rm/doc-collections/gen-comm/bulletins/2003/bl03002.pdf comm/bulletins/2003/bl03002.pdf http://adamswebsearch2.nrc.gov/idmws/doccontent.dll?library=PU ADAMSAPBN http://adamswebsearch2.nrc.govlidmws/doccontent.dll?library=PU ADAMS"PBN TAD01&ID=041530271 TAD01 &ID=041530271 The staff verified that the applicant's responses and commitments commitments in the CLB to the applicableapplicable NRC Orders, Bulletins, or GLs on nickel-alloy component cracking component cracking are publicly available at the available the following NRC public web site web addresses:

http://www.nrc~qov/reactors/operating/ops-experience/pressure-boundary-http://www.nrc:gov/reactors/operating/ops-experience/pressure-boundary-integqrity/upper-head-issues/order-ea-03-009.

integ ritY/u pper-head-issues/order-ea-03-009. htm html#reqion I#reg ion 1 http://www.nrc.,ov/reactors/operatincq/ops-experience/pressure-boundary-http://www.nrc.gov/reactors/operating/ops-experience/pressure-boundary-intecjrity/bottom-head-issues/bulletin-2003-02.html#region1 integrity/bottom-head-issues/bulletin-2003-02. htm I#region 1

.http://www.nrc.qov/reactors/operatinpqops-experience/pressure-boundary-http://www. nrc.gov/reactors/operating/ops-experience/pressure-boundary-inteqrity/pressurizer-issues/bulletin-2004-01 integrity/pressurizer-issues/bulletin-2004-01.html .html The staff also verified verified that the applicant's augmented activities applicant's augmented activities for its ASME ASME Code Class 1 nickel-alloy nickel-alloy components includes commitments commitments made in the applicant's responses responses to these these generic communications.

communications. Based on this review and verification, verification, the staff finds that the the applicant's responses responses to these generic communications communications provide provide clear evidence that the clear evidence the applicant has incorporated applicable BVPS-specific incorporated applicable BVPS-specific and generic industry-wide experience generic industry-wide experience to to address cracking cracking of the ASME Code Class 1 nickel-alloy components for Units 1 and 2, and has has placed appropriate placed appropriate regulatory regulatory commitments components as part commitments for these components part of its CLB.

3-167 3-167

Therefore, the staff concludes Therefore, concludes that the applicant has provided an acceptable acceptable basis for managing managing cracking of these components components becausebecause the applicant has incorporated incorporated its current regulatory commitments for these nickel-alloy nickel-alloy components into LRA Commitment No. 15 for Unit 1 and LRA Commitment Commitment No. 17 17 for Unit 2.

UFSAR Supplement. The applicant provided UFSAR provided the UFSAR supplement supplement for its Nickel-Alloy Nozzles Nickel-Alloy Nozzles Penetrations Program and Penetrations Program in LRA Section A.1.28. The staff confirms that UFSAR Supplement A.1.28 is no longer required for the Nickel-Alloy Nickel-Alloy Nozzles Nozzles and Penetrations Program because, in in its letter of July 21,2008, 21, 2008, the applicant amended amended the LRA to delete the Nickel-Alloy Nickel-Alloy Nozzles Nozzles and Penetrations Program and UFSAR Supplement Supplement A.1.28 for the Nickel-Alloy Nickel-Alloy Nozzles Nozzles and and Penetrations Program from the scope of the LRA. The staff also confirms Penetrations confirms that the applicant has has amended amended the AMR items for the nickel-alloynickel-alloy Class 1 components to directlydirectly refer to its aging management commitments, management commitments, described described in UFSAR UFSAR Supplement Supplement Tables A.4-1 for Unit 1 (Commitment No. 15)

(Commitment 15) and A.5-1 for Unit 2 (Commitment No.17). The staff finds that these these commitments commitments provide an acceptable acceptable basis for managing cracking managing cracking in the applicant's ASME applicant's ASME Code Class 1 nickel-alloy nickel-alloy components and pressure retaining welds because because placement placement of the the commitments on the LRA is consistent with the staff's aging management commitments management guidance guidance in SRP-LR Sections 3.1.2.2.15 and 3.1.2.2.17 3.1.2.2.17 and in the applicable applicable AMRs AMRs for these components in the the GALL Report, Revision 1, Volume Volume 2, Tables IV.A2, IV.C2, and IV.D1. IV.D1.

Conclusion.

Conclusion. Based on its review of the applicant's Nickel-AlloyNickel-Alloy Nozzles and Penetrations Penetrations Program, the staff concludes concludes that the applicant applicant has demonstrated demonstrated that effects effects of aging will be be adequately adequately managed so that the intended function(s) function(s) will be maintained maintained consistent with the CLB CLB for the period of extended extended operation, as required by 10 10 CFR 54.21 54.21(a)(3).

(a)(3). The staff also reviewed reviewed the FSAR supplement supplement and finds that, instead instead of including a UFSAR UFSAR supplement for the AMP, applicant has provided the applicant acceptable basis for amending provided an acceptable amending the LRA to delete delete this AMP and supplement for this AMP from the scope of the LRA, and instead, include applicable UFSAR supplement applicable commitments for these nickel-alloy nickel-alloy components, as described described UFSAR Supplement Tables A.4-1 UFSAR Supplement for Unit 1 (Commitment No. 15) 15) and A.5-1 for Unit 2 (Commitment (Commitment No.17). The staff concludes concludes this to be an acceptable acceptable alternative method of satisfying the UFSAR supplement supplement requirements requirements of 10 CFR 54.21(d).

3.0.3.3.4 Reactor Reactor Vessel Integrity Program Summary Summary of Technical Information in the Application.

Technical Information Application. In LRA Section Section B.2.35, the applicant applicant described the existing Reactor Vessel Integrity Program as a plant-specific program.

described The Reactor Vessel Integrity Program manages manages loss of fracture toughness due to neutron neutron2 embrittlement embrittlement in reactor materials exposed exposed toto a fluence exceeding neutron fluence a neutron 1.0E+17 n/cm exceeding 1.0E+17 n/cm 2 (E>1.0 MeV). The program program is based on 10 CFR Part 50, Appendix H, H, "Reactor Vessel Material Surveillance Surveillance Requirements," and ASTM E185-82, "Standard Practice for Conducting Conducting Surveillance Surveillance Tests for Light-Water Light-Water Cooled NuclearNuclear Power Reactor (incorporated by Reactor Vessels" (incorporated by reference into 10 10 CFR 50, Appendix Appendix H). The program periodically periodically removes capsules during the the course course of plant operating life to evaluate evaluate neutron embrittlement through embrittlement through surveillance capsule capsule testing and evaluation, fluence calculations, and monitoring of effective full-power years (EFPYs). Best-estimate values of RV accumulated accumulated neutron neutron fluence are determined determined by analytical models that satisfy satisfy the guidance guidance of Regulatory Regulatory Guide (RG) 1.190, "Calculational and Dosimetry (RG) 1.190, Determining Pressure Vessel Neutron Methods for Determining Neutron Fluence."

Fluence." The applicant applicant utilizes data from the program program to determine:

3-168 3-168

" pressure-temperature (P-T) limits, minimum temperature pressure-temperature temperature requirements, and end-of-lifeend-of-life Charpy upper-shelf energy in accordance accordance with 10 CFR Part 50, Appendix G, "Fracture "Fracture Toughness Requirements" Toughness

" end-of-life reference temperature end-of-life reference pressurized thermal temperature for pressurized thermal shock (RTPTS)

(RT PTS) values values inin accordance accordance with 10 10 CFR 50.61, 50.61, "Fracture Toughness Requirements Requirements for Protection Against Pressurized Pressurized Thermal Shock" The Reactor Vessel Integrity Integrity Program Program guides withdrawal and testing or storage of material specimen specimen capsules. All withdrawn capsules were tested and stored. Standby capsules capsules at Units 1 and 2, available for future testing, will be removed from the vessels when the neutron fluences fluences are approximately approximately equivalent equivalent to the projected projected vessel wall neutron fluence at 60 years of operation (corrected (corrected for lead and capacity factors). In addition, the Reactor Reactor Vessel Integrity Integrity Program implements implements flux reduction programsprograms as required by 10 CFR 50.61. 50.61.

Staff Evaluation. In LRA Section B.2.35, Amendment Amendment 1, dated February February 12, 2008, the applicant applicant described program for managing the effects described its program effects of aging on the fracture toughness properties for low-alloy steels in the RVs for Units Units 1 and 2. This AMP description description includes includes a discussion discussion of the the RV surveillance surveillance programs for Units 1 and 2. The applicant stated that its methods for monitoring monitoring the effects effects of neutron embrittlement embrittlement will comply with 10 CFR Part 50, Appendix Appendix HandH and ASTM E 185-82, "Standard Practice E 185-82, Practice for Conducting Surveillance Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Nuclear Reactor Vessels," which is incorporated incorporated by reference reference into 10 10 CFR Part 50, Appendix H.

AppendixH.

evaluates neutron This AMP evaluates neutron embrittlement embrittlement for all RV materials materials with projected neutron exposureexposure 17 2 greater than 10 1017 n/cm2 n/cm (E (E > 1.0 MeV) after after 60 years of operation. The AMP monitors changes in monitors changes the RV materials' materials' upper shelf energy (USE)

(USE) values and nil-ductility nil-ductility transition temperature temperature (RTNDT)

(RT NOT) values for the purpose of supporting the developmentdevelopment of P-T limit curves and pressurized pressurized thermal thermal shock assessments. USE USE and RT RTNDT NOT values are calculated calculated using RG 1.99, Revision 2, "Radiation Embrittlement Embrittlement of Reactor Reactor Vessel Materials."

Materials."

The calculation methodologies calculation methodologies in RG 1.99, Revision 2 prescribe the use of either chemistry data from the RG or credible plant-specific credible plant-specific surveillance capsule capsule data.

The staff reviewed the applicant's description of its RV Integrity applicant's description Integrity AMP for Units 1 and 2 to to determine determine whether whether the AMP is adequate for managing the effects effects of aging on the RVs. The staff staff confirmed that the applicant's confirmed applicant's description surveillance program for Units 1 and 2 in the description of the RV surveillance the Reactor Vessel Integrity Program Reactor Program is consistent with GALL GALL AMP XI.M31, XI.M31, "Reactor Vessel Surveillance." The applicant's Reactor Surveillance." Reactor Vessel Vessel Integrity Program description description includes aa discussion of specific specific aspects of the RV surveillance capsule withdrawal surveillance capsule withdrawal schedules for Units 1 and 2 for the period period of extended operation. Surveillance Capsules U, U, V, W, and Y were removed from the Unit 1 RV and tested. There is currently currently one surveillance capsulecapsule (Surveillance Capsule (Surveillance Capsule X) and three standby surveillance surveillance capsules (Surveillance Capsules T, Z, capsules (Surveillance and S)S) remaining in the Unit 1 RV. UFSAR UFSAR Table Table 4.5-3 for Unit 1 documents documents the withdrawal time withdrawal time for Surveillance Surveillance Capsule X as 25.9 EFPY, based on a projected projected capsule neutron fluence of 5.87 19 22 x 10 19 n/cm2 (E > 1.0 1.0 MeV), which is equivalent equivalent to the peak RV inner wall exposure exposure at 45 EFPY.

The estimated Surveillance The estimated Surveillance Capsule Capsule X withdrawal withdrawal date is 2013. The withdrawalwithdrawal and testing of Surveillance Surveillance Capsule Capsule X satisfies ASTM E E185-82 185-82 specifications specifications for the original 40-year 40-year license license 3-169 3-169

term. The three standby surveillance capsules will be exposed exposed to additional neutron flux, providing a source for future surveillance data that will be used to monitor neutron embrittlement embrittlement for the extended extended period of operation.

operation. The applicant applicant has removed removed and tested Surveillance Surveillance Capsules U, U, V, W, and X at Unit 2. No additional capsules are required to satisfy the ASTM E 185-82 185-82 specifications specifications for the original original 40-year license term. Two standby surveillance capsules capsules (Surveillance Capsules Y and Z) remain in the Unit 2 RV. The applicant stated that one of these (Surveillance these 19 capsules will be removed removed at a peak neutron fluence exposure of approximately fluence exposure approximately 8.48 x 10 1019 2

n/cm2 n/cm (E > 1.0 MeV), which corresponds corresponds to the peak RV inner wall exposure exposure at 72 EFPY. The The corresponding capsule withdrawal corresponding withdrawal time is 23.5 EFPY, and the projected projected withdrawal withdrawal date is 2014. The applicant applicant stated that the second capsule capsule will remain in the RV to provide neutron fluence monitoring and will be available available for future testing.

The staff found that the applicant's applicant's description description of the Reactor Vessel Integrity Program for Units 1 and 2 acceptable acceptable because because the surveillance program design, the capsule withdrawal surveillance program schedule, and the evaluation evaluation of test results are consistent with ASTM E185-82. As capsules are withdrawn from the RV, specimens specimens are stored for future reconstitution, reconstitution, ifif needed. The program manages the remaining standby capsules to achieve the withdrawal of at least one capsule manages capsule when the capsule neutron neutron fluence is greater than, but less than two times, the 60-year 60-year maximum RV neutron fluence. The remaining standby capsules maximum capsules will be managed managed for optimal neutron exposure neutron exposure and meaningful meaningful metallurgical metallurgical data, if if additional additional license renewals renewals are sought.

The program program manages manages the review and updating updating of 60-year neutronneutron fluence fluence projections to support the preparation preparation of new P-T limit curves and RT RTPTSPTS calculations for altered RV exposure RVexposure conditions.

The staff noted that the applicant applicant included a statement statement in the Reactor Vessel IntegrityIntegrity Program indicating indicating that the AMP requires all surveillance surveillance specimens removed from RVs for Units 1 and 2, both tested and untested, to remain in storage.

In RAI B.2.35-1, B.2.35-1, dated March March 21,21, 2008, the staff requested that the applicant applicant provide a formal commitment to implement this requirement.

Specifically, the staff requested the applicant applicant provide a commitment to store and maintain maintain standby surveillance surveillance capsules in a condition that would permit their future use through the end of the period period of extended extended operation.

In its response to RAI B.2.35-1, dated April 18, 2008, the applicant stated that itit has added RAI B.2.35-1, Commitment Commitment No. 27 to LRA Table Table A.4-1 (Unit (Unit 1) and Commitment No. 30 to LRA Table A.5-1 (Unit 2). Both commitments (Unit commitments read as follows:

As part of the Reactor Vessel Integrity Integrity Program, FENOC [the applicant]applicant] will store and maintain standby surveillance capsules standby surveillance capsules in a condition that would permit their their future use through the end of the period period of extended extended operation.

Based on its review, the staff finds the applicant's response to RAI B.2.35-1 B.2.35-1 acceptable because acceptable because the applicant applicant has added commitments to the LRA for Units 1 and 2 to store and maintain maintain standby surveillance surveillance capsules in a condition that would permit their future use through the end of the period of extended extended operation.

operation. The staff confirms that the applicant has added these 3-170 3-170

commitments to LRA Tables A.4-1 (Unit (Unit 1) and A.5-1 (Unit (Unit 2) as part of Amendment No.6 No. 6 to the the LRA. Therefore, Therefore, the staffs staff's concern concern described in RAI B.2.35-1 is resolved.

resolved.

In LRA B.2.35, the applicant also discussed discussed its Operating Experience Program element as part Operating Experience of its description of the Reactor Reactor Vessel Integrity Integrity Program.

Program. The applicant stated in its discussion of this program program element element that the AMP has provided materials data data and dosimetry dosimetry for monitoring monitoring of radiation embrittlement embrittlement since since plant startup. The staff has approved approved the use of this program for the current 40-year 40-year license license term. Surveillance Surveillance capsules have been been withdrawn during the current operating period, and the data from these surveillance surveillance capsules havehave been used to verify and project the embrittlement embrittlement behavior of RV beltline materials. Calculations Calculations have been been performed performed as required to project RTNDT project RT NDT for PTS and USE valuesvalues at the end of the period of extended operation. P-T limit curves assureassure reactor coolant system operation operation within required required safety margins, and are revised prior to exceeding exceeding specified RV neutron fluence limits. The applicant applicant discussed actions to manage the RV neutron fluence at the location location of the limiting material B6903-1) in the RV for Unit 1. Starting with RFO 11 (1995),

(Lower Shell Plate B6903-1) (1995), the applicant applicant management program to manage instituted a neutron flux management manage the effects effects of the neutron fluence on the RTRTPTS PTS value for the limiting RV material material at Unit 1. The applicant applicant also described enhancements made to the Reactor Vessel Integrity Program as a result of its self-assessment enhancements self-assessment of the program 2001. These program enhancements program in 2001. enhancements enabled the applicant to better better document and control technical document technical information used within the program and provides provides reasonable reasonable assurance assurance that the Reactor Vessel Integrity Program Program is effective. The staff confirmed that the the applicant's discussion applicant's discussion of the Operating Experience Program Operating Experience Program element satisfies the criteria criteria defined in the GALL Report defined Report and in SRP-LR SRP-LR Section A.1.2.3.10.

Section A.1.2.3.1 o. Therefore, the staff finds thisthis program element acceptable...

element acceptable description of the program and its response to RAI B.2.35, the staff determines Based on its description determines that the applicant's applicant's Reactor Integrity Program Reactor Vessel Integrity Program for Units 1 and 2 is acceptable acceptable because: (a) the proposed surveillance capsule withdrawal schedule proposed surveillance schedule provides provides reasonable reasonable assurance assurance that neutron-induced embrittlement neutron-induced embrittlement in low-alloy steel RV base metals and their associated associated welds will adequately monitored be adequately monitored during the extended period of operation; and (b) the applicant's applicant's RV surveillance surveillance program program for Units 1 and 2 complies with the requirements requirements of the 10 CFR Part 50, Appendix H.

UFSAR Supplement. The applicant applicant provided the UFSAR supplement supplement summary summary description description forfor the Reactor Reactor Vessel Integrity Integrity Program in LRA Section Section A.1.35. The staff reviewed this reviewed this Section and determined determined that the information in the supplement supplement is an adequate summary description program, as required by 10 CFR 54.21(d).

description of the program, 54.21(d).

Conclusion. Based on its review of the applicant's Conclusion. "Based applicant's Reactor Vessel Integrity Program, Program, the staffstaff finds that the program elements are consistent with GALL AMP XI.M31. XI.M31. The staff concludes that demonstrated that the effects of aging will be adequately the applicant has demonstrated adequately managed managed so that the the intended function(s) intended function( s) will be maintained maintained consistent with the CLB for the period of extended extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement supplement for this AMP and concludes that itit provides an adequateadequate summary summary description of the program, program, as required by 10 CFR 54.21(d).

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Monitoring Program (Unit 3.0.3.3.5 Settlement Monitoring (Unit 2)

Information in the Application. In LRA Section B.2.37, the applicant Summary of Technical Information applicant described described the Settlement Monitoring Program (Unit Settlement Monitoring (Unit 2 only) as an existing plant-specific plant-specific condition monitoring program for structures and piping that are within the scope of license monitoring program license renewal.

Staff Evaluation.

Evaluation. In accordance accordance with 10 CFR 54.21(a)(3),

54.21(a)(3), the staff reviewed reviewed the information in LRA Section Section B.2.37 on the applicant's Settlement Monitoring applicant's Settlement Program (Unit Monitoring Program (Unit 2 only) to ensure that the effects of aging, wi" will be adequately adequately managed so that the intended function(s) will be wi" be maintained maintained consistent consistent with the CLB for the period of extended extended operation. The staff reviewedreviewed the the Settlement Settlement Monitoring Monitoring Program (Unit (Unit 2 only) against against the AMP elements found in the SRP-LR Section Section A.1.2.3 and in SRP-LR Table A.1-1, A.1-1, focusing focusing on how the program manages manages aging effects through through the effective incorporation incorporation of 10 elements elements (i.e., "scope of the program,"

"preventive actions," "parameters monitored or inspected,"

"preventive actions," "parameters monitored or inspected," "detection "detection of aging effects,"

"monitoring and trending," "acceptance criteria,"

"monitoring and trending," "acceptance criteria," "corrective"corrective actions," "confirmation process,"

"administrative "administrative controls,"

controls," andand "operating experience").

The applicant applicant indicated that program elements (7) (7) "corrective actions," (8) "confirmation process," and (9) site-controlled QA program. The (9) "administrative controls" are parts of the site-controlled The staff's detailed detailed evaluation of the QA program is documented documented in SER Section 3.0.4. Evaluations Evaluations of the ten program elements follow.

Scope of the Program. The "scope of the program" program element criterion in SRP-LR SRP-LR Section A. 1.2.3.1 requires that the program scope A.1.2.3.1 scope include include the specific structures and addressed with this program.

components addressed The staff reviewed the applicant's applicant's program basis documents documents for this program element and found that the program is applicable applicable to the Unit Unit 2 valve pit (although there are two Unit 2 valve pits, only one is affected), safeguards building, and refueling water storage affected), safeguards storage tank (RWST)

(RWST) foundation.

In RAI 4.7.5-1, In 4.7.5-1, dated April 1, 1, 2008, the staff req requested provide the list of uested that the applicant provide structures structures that were initially within the scope of the Settlement Monitoring Monitoring Program Program (Unit 2 only) and the basis for which monitoring monitoring has been discontinued.

discontinued.

In its response response to RAI 4.7.5-1, 4.7.5-1, dated April 30, 2008, the applicant applicant stated a" all of Unit 2 Category I safety-related safety-related structures have been been determined to be "stable" with the exceptionexception of the RWST pad and shield wall, safeguards safeguards area building, and valve pit.

Based on its review, the staff finds the applicant's response to RAI4.7.5-1 RAI 4.7.5-1 acceptable because acceptable because the applicant has adequately described adequately described the list of structures structures that were initially within the scope of the Settlement Settlement Monitoring Monitoring Program (Unit 2 only) and the basis for which monitoring Program (Unit monitoring has been discontinued.

discontinued. Therefore, the staff's concernconcern described described in RAI 4.7.5-1 is resolved.

resolved.

The staff UFSAR Section 2.5.4.13 staff reviewed UFSAR 2.5.4.13 and notes that the applicant monitored monitored thethe settlement settlement of each UnitUnit 2 Category Category I structure during construction and wi" will continue monitoring throughout the life of the plant, until the settlement settlement for a particular particular structure structure has been 3-172 3-172

determined determined stable, as defined defined by the Settlement Settlement Monitoring Monitoring Program (Unit (Unit 2 only). For such structures, structures, the applicant will discontinue discontinue settlement settlement monitoring.

monitoring. The staff notes that the RWST safeguards area building, and valve pit have not yet maintained a "fixed" pad and shield wall, safeguards elevation and; therefore, continue to be monitored in accordance elevation accordance with the Settlement Monitoring Monitoring Program Program (Unit 2 only). The LRA identifies identifies which structures structures are managed managed by the program, program, which satisfies the criterion defined in SRP-LR SRP-LR Section Section A.1.2.3.1.

A.1.2.3.1. On this basis, the staff finds the the applicant's applicant's "scope of the program" element element acceptable.

Preventive Actions.

Preventive Actions. The "preventive actions" program element criterion in SRP-LR SRP-LR Section Section A.1.2.3.2 A.1.2.3.2 states that condition monitoring monitoring programs do not rely on preventive actions, and thus, preventive preventive actions need not be provided.

The staff finds this program element acceptable acceptable because because this is a condition monitoring program and there is no need for preventive actions. The staff confirms that the "preventive"preventive action" program element satisfies satisfies the criterion defined in SRP-LR Section A. A.1.2.3.2.

1.2.3.2. On this basis, the the staff finds the applicant's "preventive actions" element element acceptable.

Parameters Monitored Parameters Monitored or Inspected. The "parameters monitoredlinspected" monitored/inspected" program elementelement in SRP-LR Section A.1.2.3.3 A.1.2.3.3 can be summarized summarized as follows:

The parameters parameters to be monitored or inspected should be identified identified and linked to the degradation degradation intended function(

of the particular SC intended function(s).

s).

• " For condition monitoring programs, the parameter inspected should detect parameter monitored or inspected the presence presence and extent of aging effects.

"

• For performance monitoring monitoring programs, a link should be established established between degradation particular structure degradation of the particular structure or component component intended intended function(s) and the the parameter being monitored.

parameter monitored.

• " For prevention prevention and mitigation mitigation programs, the parameter parameter monitored should be the specific specific parameter controlled to achieve prevention or mitigation of aging effects.

parameter being controlled The staff reviewed the applicant's applicant's program basis documents documents for this program element and the the staff finds that the applicant has identified the elevations of buildings that are surveyed surveyed and and compared to previously recorded elevations. Any changes compared changes in elevations are evaluated with respect to previously previously established limits on changes changes in structure structure elevations.

The staff confirms confirms that the "parameters monitored monitored or inspected" program program element the element satisfies the criterion defined in SRP-LR SRP-LR Section Section A.1.2.3.3. On this basis, the staff finds this program program element acceptable.

Detection of Aging Effects. The "detection of aging aging effects" program element SRP-LR element in SRP-LR Section A.1.2.3.4 A.1.2.3.4 SRP-LR can be summarized summarized as follows:

• Provide information that links the parameters parameters to be monitored monitored or inspected to the agingaging effects being managed.

managed.

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• " Describe when, where, and how program data are collected Describe collected (i.e., all aspects of activities activities to collect data as part of the program).

• " Link the method or technique technique and frequency, ifif applicable, to plant-specific plant-specific or industry wide operating operating experience.

experience.

• " Provide the basis for the inspection Provide inspection population population and sample size when sampling is used to inspect aa group of SCs. The inspection populationpopulation should be based on such aspects such aspects of the SCs as aa similarity similarity of materials materials of construction, construction, fabrication, procurement, design, installation, installation, operating operating environment, environment, or aging aging effects.

The staff reviewed reviewed the applicant's programprogram basis documents documents for this program program element element and finds finds that the applicant used surveys surveys to measure measure structure settlement. If If the settlement structure settlement of a structure exceeds exceeds anticipated anticipated levels, the applicant is required to review the current analysis.

In RAI 4.7.5-2, dated April 1, 2008, 2008, the staff requested thatthat the applicant applicant provide a list of safety-related safety-related piping systems that are subject to differential differential structure settlement of the attached structures.

In its response to RAI 4.7.5-2, dated April 30, 2008, the applicant stated that there are no no safety-related safety-related piping piping systems monitored for differential differential settlement. If If the settlement of a structure structure exceeds exceeds anticipated anticipated levels, a review of the current analysisanalysis (as itit relates to the integrity integrity of the structure structure and the maintenance maintenance of settlement assumptions in the associated associated piping stress stress analyses) analyses) is required.

Based on its review, the staff finds the applicant's applicant's response to RAI 4.7.5-2 acceptable because 4.7.5-2 acceptable because the applicant has verified that there are no safety-related safety-related piping systems monitored for for differential differential settlement. Therefore, the staff's concern concern described described in RAI 4.7.5-2 is resolved.

The staff notes that in LRA Section 4.7.5, the applicant's applicant's Settlement Monitoring Monitoring Program Program ensures ensures that the current 40-year settlement assumptions in the Unit 2 pipe stress stress analyses are are maintained for the period of extended operation.

maintained operation. Sixty-year differential settlement projections projections are not provided since the TLMs TLAAs associated associated with the subject Unit 2 piping stress analyses have been dispositioned in accordance dispositioned accordance with 10 CFR 54.21(c)(1)(iii). The aging effects managed managed by by the program are identified identified and linked to the parameters parameters monitored, monitored, which satisfies the criterion criterion defined in SRP-LR Section Section A.1.2.3.4. On this basis, the staff finds the applicant'sapplicant's "detection of program acceptable.

aging effects" of the program acceptable.

Monitoring and Trending.

Monitoring Trending. The "monitoring and trending" program program element in SRP-LR SRP-LR Section A.1.2.3.5 summarized as follows:

A.1.2.3.5 can be summarized

"

• Monitoring Monitoring and trending trending activities should be described, described, and they should provideprovide predictability predictability of the extent of degradation degradation and thus effect timely corrective or mitigative mitigative actions.

• " This program element describesdescribes how the datadata collected are evaluated evaluated and may also include trending trending for a forward forward look. The parameter or indicator trended should be be described.

The staff reviewed reviewed the applicant's applicant's program basis documents for this program element element and finds finds that the program manages TLMs TLAAs established established to maintain component stress levels within the the 3-174 3-174

capabilities associated components. The staff also finds that the applicant's capabilities of the associated applicant's settlements settlements of structures incrementally to measure structures are trended incrementally measure and predict the extent of settling.

The staff confirms that the "monitoring and trending" program element satisfies satisfies the criterion criterion defined defined in SRP-LR Section Section A.1.2.3.5. On this basis, the staff finds this program element element acceptable.

Acceptance Acceptance Criteria. The "acceptance criteria" program element in SRP-LR Section A.1.2.3.6 A.1.2.3.6 can be summarized summarized as follows:

• " acceptance criteria of the program The acceptance program and its basis should be described. The The acceptance acceptance criteria, against which the need for corrective actions will be evaluated, evaluated, should ensure ensure that the SC intended intended function(s) are maintained maintained under all CLB CL6 design conditions during the period of extended operation.

conditions

• • The program program should include a methodology for analyzing analyzing the results against applicable applicable acceptance criteria.

acceptance

• " Qualitative inspections Qualitative inspections should be performed performed to the same predetermined predetermined criteria as as quantitative inspections by personnel in accordance quantitative inspections accordance with the ASME Code and through through approved approved site-specific programs.

The staff reviewed reviewed the applicant's applicant's program basis documents documents for this program element finds element and finds that each each monitored structure structure has an allowable allowable settlement settlement limit. And the applicant's applicant's Structure Structure Settlement Settlement Evaluation is a comparison of observed structure structure settlement settlement to that anticipated by by the original plant designer or that amount of settlement later determineddetermined to be acceptable acceptable by by more recent analyses. The program requires action action to be taken ifif there are discrepancies discrepancies measured and anticipated between measured anticipated settlements.

The staff confirms that the "acceptance "acceptance criteria" program element satisfies satisfies the criterion defined defined SRP-LR Section A.1.2.3.6. On this basis, the staff finds this program in SRP-LR program element acceptable.

acceptable.

Corrective Corrective Actions. The adequacy applicant's 10 CFR Part 50, Appendix 6 adequacy of the applicant's B Program, associated associated with this program element, is addressed addressed in SER Section 3.0.4.

The staff reviewed the other aspects of this program program to determine determine whether whether or not it satisfies thethe criteria defined in SRP-LR Section A.1.2.3.7.

A.1.2.3.7. The staff staff finds the requirements of 10 CFR Part 50, Appendix B, 6, acceptable acceptable to address corrective corrective actions. On this basis, the staff finds the the applicant's "corrective actions" element acceptable.

applicant's Confirmation Confirmation Process. The adequacy of the applicant's 10 CFR Part 50, Appendix Appendix 6 B Program, associated associated with this program program element, is addressed addressed in SER Section 3.0.4.

The staff reviewed reviewed the other aspects of this programprogram to determine determine whether or not it satisfies the the criteria defined defined in SRP-LR Section Section A.1.2.3.8.

A.1.2.3.B. The staff finds the requirements of 10 CFR Part 50, Appendix Appendix 6,B, acceptable acceptable to address a confirmation confirmation process. On this basis, the staff finds the the applicant's applicant's "confirmation process" element element acceptable.

Administrative Controls. The adequacyadequacy of the applicant's 10 10 CFR Part 50, Appendix Appendix 6 B Program, Program, associated with this program program element, is addressed addressed in SER Section 3.0.4.

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The staff reviewed reviewed the other aspects of this program element element to determine determine whether or not it satisfies the criteria criteria defined in SRP-LR Section A.1.2.3.9. The staff finds the requirements requirements of 10 CFR Part 50, Appendix B, acceptable acceptable to address administrative administrative controls. On this basis, the the staff finds the applicant's applicant's "administrative controls" element acceptable.

acceptable.

Operatinq Experience.

Operating Experience. The "operating experience" program element criteria in SRP-LR SRP-LR Section Section A.1.2.3.10 A.1.2.3.1 0 can be summarized summarized as follows:

• " experience should provide Operating experience provide objective evidence to support the conclusion objective evidence conclusion that the effects of aging will be managed managed adequately adequately so that the SC intended function(s) function(s) will be maintained maintained during the period of extended operation.

extended operation.

• " applicant may have to commit to providing operating The applicant operating experience experience in the future for new programs to confirm their effectiveness.

effectiveness.

The staff reviewed the applicant's applicant's program program basis documents documents for this program element.

In RAI 4.7.5-3, dated April 1 1,,2008, 2008, the staff requested that the applicant identify identify which structures were discontinued, structures discontinued, and the basis for discontinuing discontinuing this monitoring.

In its response to RAI 4.7.5-3, dated April 30, 2008, the applicant provided 30,2008, provided aa list of the the safety-related structures for Unit 2 with settlement safety-related settlement markers markers that were determined determined to be stablestable and for which monitoring was discontinued.

discontinued. Those structures include the auxiliaryauxiliary building, diesel generator generator building, emergency emergency outfall structure, decontamination building, structure, fuel and decontamination primary primary plant demineralized demineralized water tank pad and enclosure,enclosure, reactor containment building, reactor containment building, control room extension, service building, main steam and cable vault, and the intake intake structure. TheThe applicant applicant also stated that the Settlement MonitoringMonitoring Program is applicable applicable only to Unit 2. WithinWithin that program, settlement marker location is considered program, a settlement considered stable if,if, over aa reasonable time frame frame (2 to 3 years, or 730 to 1095 days), a trend can be established that shows the marker has has maintained a "fixed" elevation maintained elevation within a tolerance tolerance range of plus or minus 0.125 inch (plus (plus or or 1/8th inch).

minus 1/8th inch).

Based on its review, the staff finds the applicant's applicant's response to RAI 4.7.5-3 acceptable because 4.7.5-3 acceptable because the applicant applicant has verified that the program adequatelyadequately manages manages aging effects that are identified, identified, which which satisfies satisfies the criterion defined A. 1.2.3.10.

defined in SRP-LR Section A.1.2.3.1 O. Therefore, Therefore, the staffs concern described in RAI 4.7.5-3 4.7.5-3 is resolved.

The staff confirms that the applicant's applicant's "operating experience" program element satisfies the the criterion defined in SRP-LR SRP-LR Section A.1.2.3.10.

Section A.1.2.3.1 O. On this basis, the staff finds the applicant's applicant's "operating experience" effects effects of the program program acceptable.

acceptable.

UFSAR UFSAR Supplement. The applicant provided the UFSAR supplement for the Settlement UFSAR supplement Settlement Monitoring Monitoring Program Program in LRA Section A.1.37. The staff reviewed reviewed this Section and finds the the UFSAR supplement information UFSAR supplement information an adequate adequate summary summary description description of the program, as required required by 10 CFR 54.21(d).

Conclusion. Based on its review applicant's Settlement review of the applicant's Monitoring Program (Unit Settlement Monitoring (Unit 2 only),

concludes that the applicant has demonstrated the staff concludes demonstrated that effects effects of aging will be adequately adequately 3-176 3-176

managed so that the intended function(s) managed function(s) will be maintained maintained consistent with the CLB for the the period of extended extended operation, operation, as required required by 10 10 CFR 54.21(a)(3). The staff also reviewed reviewed the the UFSAR supplement for this AMP and concludes UFSAR concludes that itit provides provides an adequate adequate summary description of the program, as required description required by 10 10 CFR 54.21(d).

3.0.3.3.6 3.0.3.3.6 Selective Leaching of Materials Materials Inspection Inspection Program Technical Information Summary of Technical Information in the LRA. Section B.2.36 B.2.36 of LRA Appendix Appendix B described the the Leaching of Materials Selective Leaching Materials Program. By letter dated September September 5,2008, 5, 2008, the applicant applicant replaced the Selective Leaching Leaching Inspection Program with a plant-specific Inspection Program plant-specific Selective Selective Leaching of Materials Inspection Materials Inspection Program.

Program. The applicant determined during the review of operating applicant determined operating experience that buried gray cast iron fire protection experience protection piping has experienced experienced selective leaching.

The applicant stated that for this piping, there will be periodic inspections to insure that selective periodic inspections selective leaching is identified before a loss of component intended component intended function. The program will continue to to consist of a one-time visual inspection inspection and hardness examination of selected components that selected components that are susceptible susceptible to selective leaching. The applicant applicant stated that the program scope includes scope includes components and commodities (for example, piping, pump casings, valve bodies and heat exchanger components) made of copper alloys exchanger alloys with zinc content greater than 15%. 15%. Gray cast iron which is exposed to a raw water, treated water, air, condensation, or soil environment will be periodically periodically inspected. Should evidence of significant selective selective leaching leaching be revealed revealed by the the one-time inspection inspection or previous operating experience, the Corrective operating experience, Corrective Action Program will be be unacceptable inspection used for the unacceptable inspection findings. The resolution resolution will include include evaluation evaluation for expansion of the inspection inspection sample size, locations, and frequency.

Staff Evaluation. The staff reviewed the Selective Leaching Leaching of Material Inspection Program Material Inspection Program against the AMP elements elements found in the GALL GALL Report, in SRP-LR Section Section A.1.2.3, and in in SRP-Table A.

SRP-Table A.1-1, 1-1, focusing on how the program manages manages aging effects through the effective effective incorporation incorporation of 10 program program elements. The staff's evaluations of the "scope of program,"

monitored/inspected," "detecting of aging effects,"

"preventative actions," "parameters monitored/inspected,"

"monitoring and trending," "acceptance criteria,"criteria," and "operating experience," program elements program elements for this AMP are given given in the subsections subsections that follow. The staff reviewed the AMP's "corrective "corrective administrative controls," and "confirmation process" program actions," administrative program elements elements as part of its review of LRA AMP B.1.3, "Quality Assurance Program Program and and Administrative Controls." The staffs staffs evaluation of the "corrective actions," administrative administrative controls," and "confirmation process" program elements is given in SER Section 3.0.4.

program Scope of Program. LRA Section B.2.36 B.2.36 as supplemented supplemented by the letter dated September 25, 2008, states September states that the scope of the program will include include all components components and commodities identified identified in AMRs as susceptible susceptible to loss of material due to selective leaching. leaching. The The scope includes includes components components and commodities commodities (for example, example, piping, pump casings, valve bodies bodies and heat exchanger exchanger components) made made of gray cast iron and copper copper alloys with zinc content greater than 15 percent greater percent that are exposed to raw water, treated water, air, condensation, condensation, or soil.

The applicant applicant further states in the September 25, 2008 letter letter that a representative representative sample of susceptible to selective leaching components that are susceptible leaching will be selected selected for examination.

examination. For For components that are not part of the gray cast iron fire protection piping, the sample will be be selected selected using EPRI guidance guidance developed for an earlier earlier utility. The sample population for buried gray cast iron fire protection protection piping will be based on test equipment limitations, piping configuration, configuration, and plant operating operating experience.

experience.

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The staff reviewed the applicant's applicant's "scope of program" programprogram element against the criteria in A.1.2.3.1, which states that: '

SRP-LR Section A.1.2.3.1, necessary for license "The specific program necessary license renewal should be identified. The identified. The scope of the program include the specific structures program should include structures and components of which the program program manages manages the aging."

The staff noted that the program program specifies specifies that it manages loss of material in components made components made of cast iron or copper alloys alloys containing greater greater than 15%15% zinc as an alloying element. The staff staff found this to be acceptable because itit is consistent acceptable because consistent with the AMRs in Sections VII and VIII on the components components materials materials that may be susceptible to selective selective leaching.

leaching. The staff also noted that this program was designated designated for management of aluminum aluminum bronze components, which according according to the GALL Report, may also be susceptible to the phenomenon phenomenon of selecting leaching. The staff confirmed that the applicant's applicant's plant design does not include any in-scope, passive long-lived long-lived components components that are made of aluminumaluminum bronze bronze materials. Thus, based on this confirmation, the staff finds that the program program does not need to be credited for the the management of aluminum management aluminum bronze components components because the LRA does not include any aluminum bronze components bronze components that need need to be scoped and screened screened in for an aging management management review.

The staff confirmed confirmed that the "scope of program" program element satisfies the criterion defined defined in SRP-LR Section A.1.2.3.1.

A.1.2.3.1. The staff finds this program element acceptable.

acceptable.

Preventive Preventive Actions. LRA Section B.2.36 B.2.36 states as supplemented supplemented by the letter dated September 25, 2008, that the program is an evaluation and inspection program program with no preventive actions to to preclude or mitigate preclude mitigate aging effects.

The staff reviewed the applicant's "preventive actions" program element element against the criteria inin SRP-LR SRP-LR Section A.1.2.3.2-2 A.1.2.3.2-2 which states:

"For condition or performance performance monitoring programs, they do not rely on on preventive preventive actions actions and thus, this information need need not be provided."

The staff noted that this is a condition monitoring monitoring program that does not include any preventive preventive actions to preclude preclude or mitigate mitigate aging effects.

The staff confirmed confirmed that the "preventive actions" program element does not need to meet the the criterion defined defined in SRP-LR Section A.1.2.3.2 because because the Selective Selective Leaching Leaching of Materials Materials Inspection Inspection Program Program is aa condition monitoring program that does not include any preventative condition monitoring preventative oror mitigative controls.

mitigative Parameters Monitored Parameters Monitored or Inspected.

Inspected. LRA Section B.2.36 B.2.36 states as supplemented supplemented by the letter letter September 25, dated September 2008, that for buried gray cast iron fire protection piping, 25,2008, piping, the program will consist of periodic testing of a sample population population using methods methods capable capable of determining determining locations locations where coating degradation degradation has occurred and where selective selective leaching leaching could bebe occurring.

occurring. For the remaining remaining components within the scope of this program, visual inspections inspections combined with qualitative hardness hardness examinations examinations of internal surfaces will be performed.

performed. These These examinations will be used to determine determine ifif selective leaching has occurred occurred and the extent that any selective selective leaching leaching will affect the component's intended intended function.

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The staff reviewed the applicant's "parameters monitored/inspected" program element against monitored/inspected" program the criteria in SRP-LR Section A.1.2.3.3-2 which states:

"For aa condition condition monitoring program, the parameter parameter monitored monitored or inspected should detect the presence presence and extent of aging effects. Some examples are are measurements of wall thickness and detection measurements detection and sizing of cracks."

The staff noted that the intended function for components susceptible to selective leaching leaching is to pressure boundary. Selective serve as a pressure Selective leaching leaching is a process that can leach leach one or more more element or secondary element secondary phase phase from the microstructure microstructure of metallic metallic alloys (cast iron, copper copper alloys alloys containing greater than 15%

containing greater 15% zinc as an alloying elementelement and aluminum aluminum bronzes containing containing greater greater than 8% 8% aluminum as an alloying alloying element) that are susceptible mechanism.

susceptible to this aging mechanism.

This process can induce porosity porosity on the components components over time, which significantly significantly reduces thethe fracture toughness toughness of the component materials component materials and even lead to leakage because leakage because the porosity becomes interlinked and develops develops throughwall.

throughwall. The staff notednoted that the applicant's applicant's Selective Selective Leaching Inspection Program is credited credited to monitor monitor for loss of material as a result of selective selective leaching and will provide examinations and hardness tests to determine provide visual examinations determine ifif porosity induced by selective leaching has led to loss of material material in any of these components. Based on this review, the staff finds that the applicant's applicant's "parameters monitored/inspected" program program element satisfies the corresponding corresponding program element SRP-LR Section A.1.2.3.3 element criterion in SRP-LR A.1.2.3.3 because the applicant has identifiedidentified the aging effect that the programprogram monitors for and because because the applicant applicant has identified identified the parameters monitored that will be indicative of the aging effect of parameters monitored concern.

The staff confirmed confirmed that the "parameters "parameters monitored/inspected" program element satisfies the the criterion criterion defined defined in SRP-LR Section A.1.2.3.3.A. 1.2.3.3. The staff finds this program program element acceptable.

acceptable.

Detection Detection of Aging Aginq Effects. LRA SectionSection B.2.36 B.2.36 states as supplemented supplemented by the letter dated September 25, 2008, that for buried September buried- gray cast iron fire protection protection piping, the program will consist of periodic testing of a samplesample population population using capable of determining using methods capable determining locations of piping or where coating degradation has occurred coating degradation occurred and where selective selective leaching leaching could be be occurring. The applicant applicant stated that the testing will be performedperformed prior prior to entering the period of extended operation extended operation and periodically periodically after that. The applicant also stated that the frequency of testing will be established established during the initialinitial inspection, inspection, but will not exceed exceed 10 years.

For the remaining components within the scope of this program, remaining components inspections combined program, visual inspections with qualitative hardness examinations examinations of internal internal surfaces surfaces will be performed.

performed. These These examinations will be used to determine if examinations if selective leaching has occurred occurred and the extent that any selective leaching leaching will affect the component's component's intended intended function. The applicant applicant stated that that groups of components components with the same material-environment combination will be considered material-environment combination considered as a separate population population and each group of components will be treated treated separately. Each group of components components will be visually examined and the internal surfaces of these components will be internal surfaces be scrapped scrapped or chipped chipped to determine ifif selective selective leaching is occurring.

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The staff reviewed reviewed the applicant's applicant's "detection of aging aging effects" program program element element against the the criteria in SRP-LR Section A. 1.2.3.4 which states:

Section A.1.2.3.4 "Detection of aging effects should should occur beforebefore there is isaa loss of the structure structure and component intended function(s). The parameters parameters to be monitored or inspected should be appropriate inspected appropriate to ensure that the structure structure and component component intended intended function(s) will be adequately maintained adequately maintained for license renewal under all renewal CLB design conditions. This includes includes aspects such as method or technique technique (e.g.,

visual, visual, volumetric, surface surface inspection), frequency, sample sample size, data collection data collection and timing of new/one-time new/one-time inspections inspections to ensure timely detectiondetection of aging effects.

effects. Provide information that links the parametersparameters to be monitored monitored oror inspected to the aging effects being managed."

"Nuclear power plants are licensedlicensed based on redundancy, diversity, and defense-in-depth principles. A degraded or failed component defense-in-depth component reduces the the reliability of the system, challenges safety systems, and contributes contributes to plant risk.

Thus, the effects of aging on a structure or component component should be managed managed to ensure ensure its availability to perform its intended intended function(s) function(s) as designed designed when called upon. In this way, all system level intended including redundancy, intended function(s), including diversity, and defense-in-depth defense-in-depth consistent with the plant's CLB, would be be maintained for license renewal. A program based solely on detecting maintained detecting structure structure and component component failure failure should not be considered considered as an effective aging management program for license renewal."

management describes "when," "where," and "how" "This program element describes "how" program data data are collected (i.e., aspects of activities to collect data as part of the program)."

(Le., all aspects "The method or technique technique and frequency frequency may be linked to plant-specific plant-specific or or industry-wide industry-wide operating experience. Provide justification, including codes and justification, including referenced, that the technique standards referenced, technique and frequency frequency are are adequate to detect the aging aging effects before before aa loss of SC intended intended function.

function. A program program based solely solely on detecting detecting SC failures is not considered an effective management effective aging management program."

"When sampling is used to inspect a group group of SCs, provide the basis for the the inspection population inspection population and sample size. The inspection population inspection population should be be based based on such aspects aspects of the SCs as a similarity of materials of construction,construction, fabrication, procurement, design, installation, installation, operating environment, or aging effects. The sample size should be based based on such aspects of the SCs as the the specific aging effect, location, existing technical information, information, system and structure design, materials structure materials of construction, service environment, or previous previous failure history. The samples samples should be biased toward locations most susceptible susceptible to the specific aging effect of concern concern in the period of extended operation.

extended operation.

Provisions Provisions should also be included on expanding expanding the sample size when degradation is detected in the initial sample."

degradation The staff's staffs review found the one-time inspectioninspection of the components components that are not part of the fire fire appropriate to insure there will not be a loss of intended function because protection system is appropriate because the applicant does not yet have any operating experience that indicates that selective operating experience leaching selective leaching 3-180 3-180

has occurred occurred in these non-fire protection system components. Thus, for these non-fire protection non-fire protection protection system components, the staff found this to be acceptableacceptable in meeting the staff's recommendation recommendation SRP-LR Section A.1.2.3.4 because, although the one-time in SRP-LR inspection program that does not one-time inspection not sufficient to confirm that loss of re-inspection frequency, the inspection will be sufficient have a periodic re-inspection material due to selective selective leaching is not occurring occurring in the components components or else to prompt prompt the the applicant to take appropriate appropriate corrective actions under under the program's program's "corrective actions" programprogram element ifif it is confirmed that selective leaching is occurring in these components. Thus, the the staff finds that the one-time non-fire protection system one-time inspection for the non-fire components meets the system components the program does not rely on waiting for a A.1.2.3.4 because the program staff's criterion in SRP-LR Section A.1.2.3.4 component component failure to occur as an aging managementmanagement basis for the AMP.

noted that the frequency The staff also noted examinations for the fire protection frequency of the examinations components is protection components linked to Beaver linked Beaver Valley plant-specific because selective plant-specific operating experience because selective leaching leaching has been previously identified in the plant's fire protection piping. Thus, the staff noted that the periodic previously identified periodic inspections of the fire protection inspections components is appropriate protection piping components appropriate because the applicant has applicant has actually experienced actually experienced and detected detected selective leaching leaching specific fire protection protection piping components components in the past. The staff noted re-inspection frequency noted that the re-inspection frequency for these fire protection piping piping components will be based on a review of the operating components operating experience experience and past inspection results of these components, but not to exceed a re-inspection frequency of once every 10 years. The re-inspection frequency The staff also finds this to be acceptable acceptable because because the re-inspection frequency will be based on re-inspection frequency actual plant operating operating experience experience to preclude component failures, but will not be more than the preclude component the re-inspection frequency re-inspection O-year inspection frequency established frequency equivalent to the 110-year the established in the applicant's 10-Year Inservice Inservice Inspection Plan.

The staff noted that the program's selective leaching includes both visual examination leaching technique includes examination methods and qualitative hardness hardness tests of the material. The staff finds this to be appropriate appropriate because any porosity that is induced by selective leaching is a large-scale because large-scale effect that can be be noticed noticed by visual examinations examinations and because drop in the component because a drop component hardness hardness properties, as as hardness tests, may indirectly monitored for by the hardness monitored indirectly be indicative of a dropdrop in the fracture toughness in the component materials. Thus, the staff finds that the visual examinations component materials. examinations and components materials hardness tests of the components hardness materials are acceptable methods for identifying acceptable methods identifying selective selective leaching in cast iron and coppercopper alloys containing containing greater the 15% 15% zinc.

noted that the applicant has an appropriate The staff also noted appropriate sampling inspections and sampling basis for the inspections hardness tests because developed sampling because they are using an EPRI developed sampling plan that has been found acceptable acceptable by the staffstaff and because apply the results of its visual inspections because the applicant will apply inspections and hardness and commodity group basis for evaluating same-kind hardness tests as a commodity same-kind components that are scheduled for inspection and hardness not scheduled hardness testing under (i.e., as a commodity under this program (i.e.,

group basis for evaluating the uninspected/untested group components that are made uninspected/untested components made of the same same material and are subject to the same environmental conditions as the components that have material have been inspected and been inspected acceptable because and tested). The staff also finds this to be acceptable because the applicant applicant experience in establishing the frequencies operating experience takes into account previous relevant operating frequencies and sample sizes of the program's sample program's visual inspections inspections and hardness tests.

based on this review, the staff finds that the applicant has met the staff's criterion in Thus, based SRP-LR SRP-LR Section A.1.2.3.4 because inspection and testing because the applicant has defined the inspection implemented in accordance frequencies and sample sizes that will be implemented techniques, frequencies accordance with thisthis AMP. The staff confirmed that the "detection of aging effects" program element element satisfies thethe 3-181

criterion defined in the GALL GALL Report and in SRP-LR SRP-LR Section A.1.2.3.4 and that this program element element is acceptable.

acceptable.

Monitoring and Trending.

Monitoring Trending. LRA Section Section B.2.36 states as supplemented supplemented by the letter dated September September 25, 2008, that monitoring and trending does not apply to the components other than the fire protection because it is aa one-time inspection.

protection piping because inspection. For the buried fire protection piping, the results of the initial test will be used to determine determine the frequency frequency for the period of extended operation. The period between inspections wiWnot extended will'not exceed exceed 10 years. The results of the the tests will be documented documented and retained in a retrievable retrievable form.

The staff reviewed the applicant's "monitoring and trending" program program element against against the criteria criteria in SRP-LR Section Section A.1.2.3.5 which states:

"Monitoring and trending activities activities should be described, described, and they should provideprovide predictability of the extent of degradation predictability degradation and thus effect effect timely corrective corrective or meditative actions. Plant-specific meditative Plant-specific and/or industry-wide industry-wide operating experience experience may considered in evaluating the appropriateness be considered appropriateness of the techniquetechnique and frequency."

The staff review finds that for components other than the buried fire protection protection piping, there will not be any monitoring monitoring and trending because because it is a one-time inspection.

inspection. For the buried fire fire protection piping,.the protection piping" the staff review finds this program element element acceptable acceptable because the applicant applicant will conduct conduct periodic inspections inspections based on consideration consideration of the plant-specific plant-specific operating operating experience. The inspection results will be monitored experience. monitored and trended to reestablish the frequency frequency of examinations examinations of the fire protection system piping. Thus, based on this review, the staff finds that for the fire protection system components, the applicant has met the staff's recommendation recommendation in SRP-LR SRP-LR Section A.1.2.3.5 because because the program will trend the inspection inspection results for the cast ironiron components components and copper with greater greater than 15%

15% zinc components that are within the scope of the the protection system.

fire protection Thus, based on this review, the staff confirmed that, for the fire protection protection system components, the "monitoring and trending" program element satisfies the criterion defined defined in SRP-LR SRP-LR Section A.1.2.3.5 and that the program element is acceptable. acceptable. Based Based on this review, the staff staff finds that the program does not need to satisfy the criterion in SRP-LR SRP-LR Section A.1.2.3:5 A.1.2.3.5 for the the non-fire non-fire protection system components components because the program program calls for a one-time inspection inspection of the components.

components.

Acceptance Acceptance Criteria. LRA Section B.2.36 states as supplemented supplemented by the letter dated dated September September 25, 2008, that any indications of degradation degradation by selective selective leaching leaching will be addressed addressed using the the corrective action program.

The staff reviewed the applicant's applicant's "acceptance criteria" programprogram element against the criteria criteria inin SRP-LR Section A.

SRP-LR Section A.1.2.3.51.2.3.5 which states:

"Qualitative inspections inspections should be performed to some predetermined criteria as some predetermined as quantitative inspections by personnel in accordance accordance with ASME Codeand through approved approved site specific programs."

The staff review finds that the applicant's acceptance criteria program element is acceptable The staff review finds that the applicant's acceptance criteria program element is acceptable because because any degradation degradation that is detected detected as a result of the program's program's visual examinations examinations or 3-182

indirectly observed as a result of the program's hardness tests will be evaluated using the the corrective action program.

The staff confirmed that the "acceptance criteria" program element satisfies the criterion defined defined in the GALL Report and in SRP-LR Section A.1.2.3.6. The staff finds this program element acceptable.

Operatingq Experience. The staff also reviewed operating experience Operating experience and selected condition applicant's technical staff to confirm that the plant-specific operating reports and interviewed the applicant's operating experience did not reveal any degradation degradation not bounded by industry experience. In the the application, the applicant stated that there is no operating experience for the effectivenesseffectiveness of the program because itit is a new program.

The applicant stated that during the review of operating experience, experience, the applicant identified applicant identified observation, protection piping. As a result of this observation, selective leaching for buried gray cast iron fire protection the applicant stated that they will conduct periodic inspections of the buried gray cast iron fire protection protection piping. In 2001, auto-started, and water was 2001, the applicant stated that the fire pump auto-started, was observed coming from the ground due to the selective leaching of the buried gray cast iron fire fire protection piping. A failure analysis was conducted and the presence of selective leaching leaching waswas bituminous attributed to the failure of the bituminous verified. The applicant stated that the failure was attributed coating on the piping. The piping was replaced using a material that is not susceptible susceptible to selective leaching.

confirmed that the "operating experience" program element satisfies the criterion The staff confirmed criterion Report and in SRP-LR Section defined in the GALL Report defined A.1.2.3.10.

Section A.1.2.3.1 O. The staff finds this program program element acceptable element because the applicant has demonstrated acceptable because appropriate plant demonstrated that it takes appropriate account in establishing experience into account operating experience establishing the program elements for this AMP.

program elements Supplement. In LRA Section UFSAR Supplement.

UFSAR Section A.1.36, the applicant applicant provided the UFSAR UFSAR Supplement for for Materials Inspection Program. The staff reviewed Leaching of Materials the Selective Leaching reviewed this UFSAR Supplement for adequacy. The staff found that, although the UFSAR Supplement UFSAR Supplement Supplement was differentdifferent from the staff's recommended,UFSAR supplement for these type of AMPs recommended .UFSAR supplement AMPs in SRP-LR Table 3.3-applicant's UFSAR Supplement 2, the applicant's description for the AMP was adequate because itit Supplement description components that the program monitors, the inspection summary of the components provided a summary inspection and hardness hardness techniques that techniques that the program program will implement to monitor monitor for selective leaching leaching of the components, and the corrective and taken if selective leaching corrective actions that will be taken detected in the components.

leaching is detected staff also noted that the applicant's The staff Supplement for the Selective Leaching applicant's UFSAR Supplement Leaching of Materials Inspection Materials includes LRA Commitment No. 19 in UFSAR Supplement Program includes Inspection Program Supplement Commitment No. 21 in UFSAR Supplement Table A4-1 for Unit 1 and LRA Commitment Supplement Table A5-1 for for applicant committed noted that in these commitments the applicant Unit 1. The staff noted committed to implementing implementing the the Selective Leaching Selective Materials Inspection Leaching of Materials Inspection Program 29, 2016 for Unit 1 and Program by July 29,2016 and by May 27, 2027 for Unit 2. 2. The staff finds finds this to be be an an appropriate commitment for this AMP because appropriate LRA commitment because applicant's Selective the applicant's Leaching of Materials Selective Leaching Inspection Program Materials Inspection Program is designated as aa new is designated application that has yet program for the application program implemented for license yet to be implemented renewal and because, license renewal under under these implementation of the one-time commitments, the implementation these commitments, one-time inspections that is inspections that credited under is credited under program for the units will be implemented this program extended operation.

entering the period of extended implemented prior to entering operation.

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Based on this review, the staff finds that the applicant's applicant's UFSAR UFSAR supplement supplement for the Selective Selective Leaching of Materials Leaching Materials Inspection Inspection Program provides an adequate adequate summary summary description the description of the program, as required by 10 CFR 54.21(d) program, 54.21(d) because the applicant has provided details provided sufficient details on how the program program will be implemented implemented in the summarysummary description and because because the UFSAR UFSAR Supplement includes appropriate Supplement includes appropriate commitments to implement this new program program during the the period period of extended extended operation.

Conclusion.

Conclusion. The staff finds the applicant's SelectiveSelective Leaching Leaching of Materials Inspection Program is acceptable because the staff has confirmed that the program elements acceptable because elements for the AMP are in in conformance conformance with the staff's program element element criteria that are defined in SRP-LR SRP-LR Section A.1.2.3.

On the basis of its technical review of the applicant's applicant's Selective Leaching Inspection Program as as discussed above, the staff concludes concludes that the applicant has demonstrateddemonstrated that the effects effects of aging will be adequately adequately managed so that the intended intended functions will be maintained consistent consistent with the CLB for the period of extended operation,operation, as required by 10 CFR 54.21(a)(3). staff 54.21 (a)(3). The staff also reviewed UFSAR supplement reviewed the UFSAR supplement for this AMP and finds that itit provides an adequate adequate summary description description of the program, as requiredrequired by 10 CFR 54.21(d).

3.0.3.3.7 Boral Surveillance Program Boral Surveillance Summary of Technical Information in the Application. In Amendment Technical Information Amendment 34, dated January 19,2009, January 19, 2009, the applicant made a revision of the LRA to include LRA Section A.1.43, Boral Surveillance Boral Surveillance Program Program (Unit (Unit 1 Only). In this section of the LRA the applicant provided provided the the following program program description:

description:

Boral Surveillance Program is an existing plant-specific The Boral plant-specific condition condition monitoring program monitoring program for which there is no comparable NUREGO1 comparable NUREG01801 801 aging aging management management program. The program program manages manages the neutron absorbing function of the BVPS Unit 1 High DensityDensity Spent Fuel StorageStorage racks by the removal and

-testing of sample Boral Boral neutron absorber absorber coupons. Coupon analysis is performed performed by a vendor, and recommendations recommendations based on the analysis are provided to FENOC.

The purpose of the program is to characterize characterize certain properties properties of the Boral Boral inin the storage racks to assure assure its capability to fulfill its intended function, and to to assure assure that assumptions made made in the Fuel Pool criticality analysis remain valid.

Because the test coupons are located and configured configured to ensure exposure to higher-than average higher-than average levels of gamma radiation, data gathered by the program represent accelerated accelerated use, and there there is reasonable assurance that degradation reasonable assurance degradation detected and corrective will be detected corrective actions taken prior to a loss of intended function.

Staff Evaluation. The staff reviewed Boral Surveillance reviewed the Boral Surveillance Program Program in LRA Section Section B.2.43 (in Amendment 34) against the AMP elements found in the SRP-LR Section A.1.2.3, and in Amendment in SRP-LR SRP-LR Table A.1-1,A.1-1, focusing on how the program manages manages aging effectseffects through the effective effective incorporation incorporation of 10 elements. Specifically, the staff reviewed the following seven (7) program program elements of the applicant's program:

program: (1) "scope of the program," (2) "preventive actions," (3) (3)

"parameters monitored "parameters monitored oror inspected,"

inspected," (4)(4) "detection "detection of aging effects," (5) "monitoring and of aging (6)" acceptance trending," (6)" acceptance criteria," and (10) (10) "operating experience."

3-184 3-184

In LRA Section B.2.43, the applicant provided the following elements: elements: (7)

(7) corrective corrective actions, (8) confirmation process, and (9) administrative controls controls common to all AMPs. The applicant applicant indicated indicated that program elements elements (7) "corrective actions," (8) (8) "confirmation process," and (9) (9)

"administrative controls" are parts of the site-controlled "administrative controls" are parts of the site-controlled QA program.

program. The staff's evaluation of the QA program program is in SER Section 3.0.4. Evaluation of the remaining seven elements elements follows:

Scope of the Program.

Program. LRA Section B.2.43 states that, "The scope of the program program consists of the Boral Boral neutron neutron absorbing absorbing material material in the High Density Spent Fuel Storage Storage Racks at BVPS BVPS program applies only to BVPS Unit 1, because the BVPS Unit 2 Spent Fuel Storage Unit 1. The program Storage Racks do not use BoralBoral as a neutron absorber."

The staff confirms that the "scope of the program" program program element element satisfies satisfies the guidance guidance in in SRP-LR Section A.1.2.3.1, A.1.2.3.1, since the staff confirmed Boral was only used in BVPS Unit 1 confirmed that Boral spent fuel pool and BVPS Unit 2 uses Boraflex. Therefore, Therefore, the staff finds this program program element element acceptable.

Preventive Preventive Actions. LRA Section B.2.43 states that, "The program is a condition monitoring monitoring program program that does not contain preventive preventive actions."

The staff confirms that the "preventive actions" program program element satisfies satisfies the guidance guidance in in SRP-LR SRP-LR Section Section A.1.2.3.2 since BVPS Unit 1 has a condition monitoring monitoring program.

program. Therefore, the staff finds this program element acceptable.

acceptable.

Parameters Monitored Parameters Monitored or Inspected.

Inspected. LRALRA Section B.2.43 states that, "The program monitors chan~es changes in physical properties physical properties of the BoralBoral by performing measurements on representative performing measurements representative Boral coupons. The coupons simulate as nearly nearly as possible possible the actual in-service in-service geometry, physical mounting, materials, and flow conditions of the Boral Boral panels in the storage racks. The The coupons are removed removed in accordance accordance with a prescribed prescribed schedule. Upon removal, each coupon is .

.inspected inspected and tested to determine determine changes in physical properties of the Boral physical properties Boral in the spent fuel fuel measurements performed pool. The measurements performed are:

• " Visual Observation Observation and Photography Photography

• • Neutron Neutron Attenuation Attenuation

• • Dimensional Measurements Measurements (length, width, and thickness) thickness)

• • Weight and Specific Gravity Specific Gravity program provides for additional, optional The program measurement parameters optional measurement parameters and actions, including including radiography, destructive destructive wet chemical analysis, re-insertion re-insertion of tested coupons, and in-service in-service Boral panels themselves. These inspection of the Boral These additional additional actions actions provide options for confirming or further investigating further investigating results of coupon analysis"

• The staff confirms confirms that the "parameters monitored monitored or inspected" program program element element satisfies the the guidance guidance in SRP-LR Section Section A.1.2.3.3. The staff considers this program acceptable program element acceptable experience has shown that Boral because experience Boral degradation degradation in the SFP environment environment occurs slowly slowly and can be detected in the early stages stages by the methods proposed. The measurements measurements of neutron attenuation, neutron attenuation, physical distortion, and and weight change change would detect coupon degradation degradation that would precede precede a loss of functionality functionality in the Boral Boral panels (neutron absorption absorption and fuel 3-185 3-185

assembly spacing).

spacing). Moreover, unacceptable unacceptable coupon results would initiate an engineering engineering evaluation and, ifif considered necessary, direct testing of the storage storage racks (i.e. blackness (Le. blackness testing).

Detection of Aging Aqing Effects. LRA Section B.2.43 states states that "The program was approved approved by the the NRC in the "Safety Evaluation by the Office Office of Nuclear Nuclear Reactor Reactor Regulation Regulation Related Related to Amendment No. 178 to Facility Amendment Facility Operating License No. DPR - 66". Detection of aging Operating License aging effects effects occurs through through monitoring changes in physical properties monitoring changes Boral coupons. When the properties of the Boral the program program was initiated, a total of 20 test coupons were installed in the Unit I I fuel pool, with 10 coupons installed in installed each each of 2 coupon coupon trees. Coupons are removed removed for analysis according to a prescribed prescribed schedule. The schedule schedule is such that coupons will be removed through the period of extended extended operation.

After removal, removal, three length measurements and three width measurements length measurements measurements are taken and compared to corresponding corresponding pre-irradiation pre-irradiation measurements.

measurements. Five thickness measurements measurements are taken and compared compared to corresponding corresponding pre-irradiation pre-irradiation measurements.

measurements. The coupons are examined examined visually for signs of degradation, including including edge and comer defects, discoloration, discoloration, and surface pitting.

The coupons coupons are then dried carefully in three stages stages to avoid expansion expansion of the water which has has been absorbed and subsequent bulging of the coupon.

Neutron attenuation attenuation measurements measurements are made relative relative to a standard standard sample. Weight and specific specific measurements are also taken."

gravity measurements The staff confirms that the "detection of aging effects" program element satisfies the guidance guidance in in SRP-LR Section A. 1.2.3.4 since the staff considers the program to collect data from Section A.1.2.3.4 from representative coupon samples to assess for stability and integrity of Boral representative Boral to be acceptable for for detection detection of aging effects. Therefore, Therefore, the staff finds this program element element acceptable.

Monitoring and Trending.

Monitoring Trending. LRA SectionSection B.2.43 B.2.43 states that "The"The evaluation of the coupons coupons provides information on the radiological radiological effects, thermal effects, and chemical chemical effects of the the spent fuel pool environment on the Boral Boral panels. ForFor the first several refueling cycles after after installation, the coupon trees are surrounded by discharged installation, discharged fuel assemblies assemblies having a high high specific power prior to shutdown. This fuel storage configuration intended to accelerate configuration is intended aging' accelerate aging' of the test coupons. Over the duration duration of the coupon testing program, the coupons coupons will have have accumulated more radiation dose than the expected accumulated lifetime dose for normal storage cells.

expected lifetime Because Because the test coupon coupon data gathered gathered by the program program represents represents accelerated accelerated use, there is reasonable reasonable assurance that degradation degradation will be detected detected and corrective corrective actions taken prior to aa loss of intended intended function of the Boral Boral panels panels themselves."

The staff confirms confirms that the "monitoring and trending" program program element element satisfies the guidanceguidance in in SRP-LR SRP-LR Section A.1.2.3.5.

A.1.2.3.5. The staff finds this program element acceptable acceptable because the the applicant applicant monitors monitors and trends parameters parameters that would indicate degradation prior to a loss of indicate degradation intended intended function of the Boral Boral panels.

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Acceptance Criteria. LRA Section B.2.43 states that "The most significant Acceptance significant measurements measurements taken are thickness thickness (to monitor for swelling) swelling) and neutron neutron attenuation attenuation (to confirm concentration of confirm the concentration Boron-10 Boron-1 0 in the Boral).

Boral). Acceptance Acceptance criteria for these measurements measurements are as follows:

• A decrease of no more than 5% 5% in Boron-10 Boron-1 0 content as determined neutron determined by neutron attenuation.

attenuation.

• increase in thickness An increase thickness at any point should not exceed 10% 10% of the initial thickness at that point.

Changes Changes in excess of either of these two criteria require investigation investigation and engineering engineering evaluation evaluation to identify identify whether further testing or corrective corrective actions may be necessary.

The remaining measurement parameters serve measurement parameters serve a supporting role and should be be examined for early indications of the potential examined potential onset of Boral degradation that would suggest a Boral degradation need need for further attention. These These include:

" Visual or photographic evidence of unusual surface pitting, corrosion or edge

• Visual or photographic evidence of unusual surface pitting, corrosion or edge deterioration deterioration

• • Unaccountable Unaccountable weight excess of the measurement weight loss in excess measurement accuracy accuracy

• • The existence existence of areas of reduced boron density should an optional neutron radiograph be taken" The staff confirms that the "acceptance criteria" program program element element satisfies the guidance guidance in SRP-LR Section A.1.2.3.6 A.1.2.3.6 since BVPS Unit 1 provided specific values for the acceptance acceptance criteria which would provide reasonable reasonable assurance assurance that corrective actions actions could be taken before before loss of functionality functionality would occur. The staff finds this program elementelement acceptable.

acceptable.

Operatincq Operating Experience. LRA Section B.2.34 states that The "The program administers the removal and testing of sample Boral Boral neutron neutron absorber coupons. Coupon analysis analysis is performed by a recommendations based on the analysis vendor, and recommendations analysis are provided to FENOC. The results of Boral coupon analysis Boral analysis are recorded in inspection inspection reports. Recommended Recommended items for evaluation evaluation from the reports have been documented in the BVPS Corrective Action Program.

been documented Program.

To date, the most recent program inspection inspection report was issued in 2007. Two coupons were were removed from the BVPS Unit 1 Spent removed Spent Fuel Pool in June 2007 and shipped to Northeast Technology Corp (NETCO)

Technology (NETCO) for testing. The results of these tests are indicative indicative of satisfactory material performance. However, both coupons had numerous numerous blisters in the Boral Boral cladding.

cladding.

The previous previous inspection inspection report, issued in 2002, identified a few small blisters on the coupons.

Prior to that, no blisters were noted on the coupons. Because the blisters displace water from the flux trap of the Region I racks, they could potentially potentially challenge dimensional assumptions dimensional assumptions made in the fuel pool criticality analysis. FENOC performed FENOC performed an evaluation evaluation of the blisters through through the Corrective Action Program.

Program. FENOC will monitor monitor future surveillance coupons for extent and surveillance progression of corrosion corrosion and blister blister growth. consistent with recommendations growth. This action is consistent recommendations from NETCO and EPRI Report 1013721, 1013721, "Handbook of Neutron Neutron Absorber Materials for Spent Nuclear Fuel Transportation Nuclear Transportation and Storage Applications."

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Although the results of the coupon analysis warranted warranted further evaluation, evaluation, the neutron structural integrity of the coupons was determined attenuation and structural determined to be unaffected. The unaffected. The operating experience experience for the program provides evidence evidence that continued surveillance surveillance of the the coupons will effectively effectively manage aging aging effects effects such that there is no loss of intended intended function."

The staff confirms that the "operating experience" program element element satisfies the guidance in SRP-LR SRP-LR Section A.1.2.3.1 A. 1.2.3.10, 0, since the operating operating experience supports supports the conclusion conclusion that thethe Boral Surveillance Boral Surveillance Program will be able to effectivelyeffectively manage manage the loss of neutron-absorbing neutron-absorbing capacity and degradation degradation of Borale.

Boral. The staff finds this program element element acceptable.

UFSAR Supplement. In LRA LRA Section A.1.43, the applicant provided provided the most recent UFSAR UFSAR Supplement Supplement for the Boral Surveillance Boral Surveillance Program (Unit 1 Only), which was provided provided as an amendment amendment of the LRA in the letter of January January 19, 2009. The staff reviewed reviewed this UFSAR UFSAR Supplement for adequacy. The staff found that the summary summary description Boral description of the Boral Surveillance Program Surveillance Program would provide provide adequate assurance that the assumptions made in the adequate assurance the Fuel Pool criticality criticality analysis analysis would remain valid for the period of extended extended operation. The The program would have coupons coupons removed and analyzed by a vendor, who would make make recommendations based recommendations based on the analysis. These test coupons are exposed exposed to higher-than-higher-than-average average levels of gamma radiation and any data from these coupons coupons would represent represent accelerated accelerated exposure. The staff finds the summary summary acceptable since there adequate there is adequate assurance assurance that degradation degradation will be detected detected and corrective corrective actions taken prior to the loss of intended function. Therefore, Therefore, the staff concludes concludes that the UFSARUFSAR supplement supplement for this AMPAMP adequate summary provides an adequate summary description description of the program, as required required by 1010 CFR 54.21(d).

54.21 (d).

Conclusion. On the basis of its technical review of the applicant's applicant's Boral Boral Surveillance Surveillance Program, the staff concludes concludes that the applicant has demonstrated demonstrated that effects of aging aging will be adequately managed managed so that the intended function(s) function( s) will be maintained consistent consistent with the CLB for the the period of extended extended operation, operation, as required required by 10 CFR 54.21 54.21(a)(3).

(a)(3). The staff also reviewed the the UFSAR supplement for this AMP and concludes UFSAR concludes that itit provides provides an adequate adequate summary description of the program, as required description required by 10 CFR 54.21 54.21(d).

(d).

3.0.4 QA Program Attributes Integral Integral to Aging Management Management ProgramsPrograms In LRA Sections Sections A.1, A.1, "Summary Description of Aging Management Management Programs" and B.1.3, "Quality Assurance Assurance Program and Administrative Administrative Controls," the applicant describeddescribed the elements elements of corrective corrective action, confirmation confirmation process, and administrative administrative controls controls applied to the AMPs for both safety-related safety-related and nonsafety-related nonsafety-related components. The BVPS Quality Assurance Assurance (QA)

program, program, described described in Unit 1 UFSAR Appendix A, and Unit 2 UFSAR, Chapter 17, implements implements the requirements of 10 CFR Part 50, Appendix B. The Corrective Corrective Action Program Program applies applies corrective actions, confirmation, corrective confirmation, and administrative administrative controls regardless of componentcomponent safety classification. Specifically, LRA Section B.1.3 states that the QA program implements implements thethe requirements requirements of 10 CFR Part 50, Appendix B. LRA Section Section B.2, "Aging Management Management Programs,"

summarizes the AMPs.

summarizes 3.0.4.1 Summary of Technical Technical Information Information in the Application Application Sections A.1, A.1, "Summary Description of Aging Management Management Programs," and B.1.3, "Quality Assurance Assurance Program and Administrative Controls," of the license renewal application (LRA), (LRA),

described the elements of corrective action, action, confirmation confirmation process, and administrative controls administrative controls 3-188 3-188

that are applied to the aging management management programs (AMPs) for both safety-related safety-related (SR) and nonsafety-related nonsafety-related components. The BVPS quality assurance assurance program (QAP), which which includes the the elements of corrective elements confirmation process, and administrative corrective action, confirmation administrative controls, is to the QA attributes regardless of the safety classification of the components. Specifically, in Section A.1 attributes and Section B.1.3 the applicant applicant stated implements the requirements stated that the QA Program implements requirements of 10 CFR 50, Appendix B, and is consistent with NUREG-1801, NUREG-1801, "Generic Aging Lessons Learned Learned (GALL)

(GALL) Report."

3.0.4.2 Staff Evaluation Evaluation Pursuant to 10 CFR 54.21 54.21(a)(3),

(a)(3), an applicant is required required to demonstrate demonstrate that the effects of aging aging on SCs subject to an AMR will be adequately adequately managed managed so that their intended functionsfunctions will be maintained maintained consistent with the CLB for the period of extended operation. NUREG-1800, NUREG-1 800, Branch Technical RLSB-1, "Aging Management Technical Position RLSB-1, Management Review - Generic," describes describes ten attributes of an acceptable acceptable AMP. Three of these ten attributes associated with the QA attributes are associated administrative controls. Table activities of corrective action, confirmation process, and administrative Table A. 1-1, A.1-1, "Elements of an Aging Management Management Program Program for license license Renewal," of Branch Technical Position RLSB-1 provides the following description of these quality quality attributes:

" Attribute No. 7 - Corrective Actions, including root cause determination and prevention cause determination prevention of recurrence, recurrence, should be timely;

" Attribute No.8 No. 8 - Confirmation Confirmation Process, which should ensure that preventive actions are adequate adequate and that appropriate corrective appropriate corrective actions actions have been completed and are effective; effective; and,

• Attribute No.

No.9 9 - Administrative Controls, which should provide a formal review and approval process.

approval NUREG-1800, Branch NUREG-1800, Branch Technical Technical Position IQMB-1IQMB-1 noted that those aspects aspects of the AMP that affect quality quality of safety-related safety-related SSCs are subjectsubject to the QA requirements requirements of Appendix B to 10 CFR Part 50. Additionally, for nonsafety-related nonsafety-related SCs subject to an AMR, the applicant's applicant's existing Appendix Appendix B to 10 CFR Part 50 QA program program may be used to address the elements elements of corrective corrective action, confirmation confirmation process, and administrative administrative control. Branch Technical Technical Position IQMB-1 IQMB-1 provides the following guidance guidance with regard to the QA attributes attributes of AMPs:

"Safety-related "Safety-related SCs are subject to Appendix requirements Appendix B to 10 CFR Part 50 requirements which which are adequate adequate to address all qualityquality related related aspects aspects of an AMP consistent consistent with with the CLB of the facility for the period of extended extended operation. nonsafety-related operation. For nonsafety-related SCs that are subject to an AMR for license license renewal, an applicant has an option to to expand expand the scope of its Appendix B to 10 CFR Part 50 program to include these SCs to address corrective action, confirmation process, and administrative administrative control for aging management management during the period of extended extended operation. In this case, the the applicant should document document such aa commitment commitment in the Final Safety Analysis Report supplement accordance with 10 supplement in accordance 10 CFR 54.21(d)."

The NRC staff reviewed reviewed the applicant's applicant'S aging management management programs (AMPs) described described in in Appendix Appendix A, "Updated Final Safety Analysis Report Supplement," and Appendix Appendix B, B, "Aging Management Programs and Activities,"

Management Activities," of the LRA, and the associated implementing implementing 3-189 3-189

documents.

documents. The purpose of this review The purpose review was was to ensure ensure that the quality assurance that the assurance attributes attributes (corrective action, confirmation (corrective action, process, and confirmation process, and administrative controls) were administrative controls) were consistent consistent with with the the staff's staff's guidance described in NUREG-1800, guidance described NUREG-1800, Section Assurance for Aging Section A.2, "Quality Assurance Aging Programs (Branch Management Programs Management Technical Position (Branch Technical IQMB-1 )." Based on the NRC staff's Position IQMB-1)." staff's evaluation, evaluation, the descriptions descriptions of the AMPs and and their associated quality attributes provided associated quality attributes provided in in Appendix A, Section Appendix Section A.1, A.1, and Appendix Appendix B, Section Section B.1.3, of the LRA are consistent are consistent with the the staff's staff's position regarding quality assurance position regarding aging management.

assurance for aging management.

3.0.4.3 Conclusion Conclusion NRC staff's evaluation, the descriptions the basis of the NRC On the applicability of the descriptions and applicability the plant-specific plant-specific associated quality AMPs and their associated AMPs quality attributes attributes provided provided in in Appendix Appendix A, Section A.1,A.1, and and Appendix B, Appendix B, Section Section B.1.3 B.1.3 ofof the the LRA, LRA, were were determined determined to be consistent with the staff's position consistent with regarding QA for aging management. The staff concludes that the QA attributes regarding (corrective attributes (corrective administrative control) confirmation process, and administrative action, confirmation control) ofof the applicant's applicant's AMPs are consistent with 10 CFR 54.21 with 54.21 (a)(3) 3.1 Aging Management 3.1 Management of Reactor Reactor Vessel, Reactor Reactor Vessel Vessel Internals, Internals, and Reactor Reactor Coolant System Coolant documents the staff's review This Section of the SER documents review of the applicant's AMR results for the the applicant's the reactor vessel, reactor vessel internals, reactor components and component internals, and RCS components groups of:

component groups

• reactor vessel

• internals reactor vessel internals

• RCS RCS Technical Information in the Application 3.1.1 Summary of Technical LRA Section 3.1 provides AMR results for the reactor vessel, reactor provides AMR reactor vessel internals, and RCS RCS components and component component groups. LRA Table 3.1.1, 3.1.1, "Summary of Aging Management Management Evaluations in Chapter IV IV of NUREG-1 NUREG-1801 801 for the Reactor Vessel, Reactor Vessel Internals, and Reactor Coolant System," is a summary summary comparison of the applicant's AMRs with those those evaluated in the GALL Report for the reactor vessel, reactor vessel internals, and RCS components and component component groups.

applicant's AMRs evaluated and incorporated The applicant's plant-specific and industry incorporated applicable plant-specific operating operating experience determination of AERMs.

experience in the determination The plant-specific included condition reports and discussions with appropriate plant-specific evaluation included appropriate site personnel to identify AERMs. The applicant's review of industry operating experience included a operating experience review of the GALL Report and operating experience experience issues identified since the issuance of the the GALL Report.

3.1.2 Staff Evaluation The staff reviewed LRA Section 3.1 to determine whether the applicant provided sufficient sufficient demonstrate that the effects of aging for the reactor vessel, reactor vessel information to demonstrate internals, and RCS components within the scope of license license renewal and subject to an AMR, will 3-190

be adequately adequately managed so that the intended intended function(s) maintained consistent function(s) will be maintained consistent with the the CLB for the period of extended extended operation, operation, as required by 10 10 CFR 54.21(a)(3).

54.21(a)(3).

The staff conducted an on onsite site audit of AMRs to ensure the applicant's applicant's claim that certain AMRs AMRs were consistent consistent with the GALL Report. The staff did not repeat repeat its review of matters oJ the matters described in the GALL Report; described Report; however, the staff did verify verify that the material presented in the material presented the applicable and that the applicant identified LRA was applicable identified the appropriate appropriate GALL Report AMRs. The The staffs evaluations evaluations of the AMPs are documented documented in SER Section 3.0.3. Details of the staffs staff's audit evaluation documented in SER Section 3.1.2.1.

evaluation are ,documented 3.1.2.1.

In the onsite audit, the staff also selected AMRs consistent consistent with the GALL Report and for which further evaluation evaluation is recommended. The staff confirmed confirmed that the applicant's applicant's further evaluations evaluations were consist~nt consistent with the 'SRP-LR SRP-LR Section Section 3.1.2.2 acceptance acceptance criteria. The staffs audit evaluations are documented documented in SER Section 3.1.2.2.

" "

The staff also conducteda conducted.a technical review of the remaining remaining AMRs AMRs not consistent consistent with or not addressed ,in in the GALL GALL Report. The technical technical review evaluated evaluated whether all plausible whether plausible aging effects have been identified and whether the aging effects effects listed were appropriate appropriate for the the material-environment combinations specified.

material-environment combinations specified. The staffs-evaluations documented in SER staffs'evaluations are documented SER Section 3.1.2.3.

For SSCs whichwhich the applicant claimed were not claimed 'Here not applicable applicable or required no aging management, the staff reviewed the AMR line items and the the" th~ plant's operating experience experience to verify the verify the applicant's applicant's claims.

Table 3.1-1 summarizes evaluation of components, aging effects or mechanisms, summarizes the staffs evaluation mechanisms, and AMPs listed in LRA Section 3.1 and addressed addressed in the GALL GALL Report.

Evaluation for Reactor Vessel, Reactor Table 3.1-1 Staff Evaluation Reactor Vessel Internals, and Reactor"" Reactor Coolant System System Components Components in the GALL Report Component Group Aging Effect/ AMP In GALL .Further AMP In LRA Staff Evaluation (GALL Report Mechanism Report Evaluation Supplements, Item No.) 'In'ALL' or

- rReport Amendments Steel'pressure Steel 'pressure Cumulative Cumulative TLAA, evaluated evaluated in Yes Yes' Not applicable Not applicable Not applicable applicable vessel vessel support skirt fatigue damage accordance accordance with to BVPS (See SER SER and and attachment attachment 10 CFR 54.21(c) Section 3.1.2.2.1) 3.1.2.2.1) welds welds (3.1.1-1)

(3.1.1-1) o 3-191

Component Component Group. Gr~~p Aging Aging Effect/

EffectJ ',AMP AMP in GAlt, ',: ,ti='~rth~r;,

In GALL. AMP In LRA, Furthr ,AMPlnLRA" , Staff Staff Evaluation Evaluation

• • • \~~~i~~.{,~0if~(!~~(~ .;~;.";;~~#f~;t~ ~f'l }t~~~1'1'.f7k;:"*}j'.**.,

(IGALL Repo  ; "Mechanism ",Reprt Ealuation Suplemen,.ts, Item No.), In GALL or

___,;_-;Report Amendments Steel; stainless steel;steel; Cumulative Cumulative TLAA, TLAA, evaluated evaluated in Yes Not applicable applicable Not Not applicable applicable to steel with with nickel-alloy nickel-alloy fatigue damage accordance fatigue damage accordance with PWRs (SeeSER (See,SER or stainless steelsteel 10 10 CFR CFR 54.21(c) 54.21(c) and and Section Section 3.1.2.2.1) 3.1.2.2.1) cladding; nickel~alloy cladding; nickel-alloy environmental environmental effects effects reactor reactor vessel are to'be tO,be addressed addressed components:

components: flanges;flanges; for Class 1 nozzles; nozzles; components components penetrations; penetrations; safe ends; ends; thermal sleeves; vessel

, shellsheads shells, ~headsand and welds welds (3.1.1~2)

(3.1.1-2) ._

Steel; stainless Steel; stainless steel; Cumulative Cumula~ive TLAA, evaluated evaluated in in Yes Not applicable applicable applicable to Not applicable steel with nickel-alloy ni,c~el-alloy fatigue damage damage accordance accordance with with, " PWRs PWRs(See (See SER or stainless stainless steel ' 10'CFR 54.21(c).and 10'CFR 54.21(c).and Section.3.1.2.2.1)

Section ,3.1.2:2.1) cladding; nickel-alloy claddin!:J; environmental effects environmental effects reactor coolant reactor coolant are to be-addressed are be*addressed pressure boundary pressure for Class 1 piping, piping components components components, and' and .'

elements, piping elementS.

exposed to reactor coolant (3.1.1-3)

(3.1.1-3) __ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ ,__ _ _ _ _ _ _

Steel pump and Cumulative Cumulative TLAA, evaluated evaluated in in Yes Not applicable Not applicable applicable to valve closure bolting fatigue damage accordance accordance with PWRs (See SER (3.1.1-4) ,1010 CFR 54.21(c) 54.21(c) Section 3.1.2.271) 3.1,2.2,1) check Code limits for

, allowable cycles cycles (less than tha,n

,7000 cycles) of

'. lOOQ range.

thermal stress range,

, thermal Stainless StainlesS steel ;and and Cumulative evaluated in TLAA, evaluated in Y'es Yes TLAA Fatigue is a TLAA nickel-alloy reactor ,fatigue nickel-alloy fatigue damage accordance with accordance (See SER intemals \

vessel internals 10 CFR 54.21 54.21(c)

(c) 3.1.2.2.1)

Section 3.1.2.2.1) components' (3.!1.5)

(3.1.1~5)

__ _ __ _ _ _ ___._ . _ ___... _ __ _ __ _

';'

." " ".- r. ,',

nickel-alloy*tubes .

nickel-alloY,tubes Cumulative ' TlAA, TLAA, evaluated in in Yes TLAA Fatigue is a TLAA fatigue and sleeves sleeves i" a in a fatigue damage damage accordance with.

accordance with " (See SER

(~ee reactor coolant and 10 CFR 54.21(c) Section 3.1.2.2.1) 3.1.2.2.1) secondary feedwater/steam feedwater/steam environment environment (3;1.1-6)

(3.1.1-6) 3-192

'COn1pone~tGr~up Component Group * ',AglngE~~AMP Aging Effect/ AMP in In GALL GALL., FlJrther, ',AMPlnL~:'

",' ,', Further AMP in LRA, ,<'Sblffi:,-:a, lua;t"lon, Staff Evaluation (GALL Repot Mechanism

(t3A[LR~P?~t,:,.;:,'Mechll'nlsm';,

Item No.) I-ALo i,

Supplements, AReport nEvaluation

',Repo/t" "', ,i:¥aluiltjo~" '~,~~,:,,:r,p,I:, nt~j:,i ,'" "

,,~~,ry'No:r{r',',i,;,<' & " " , ; iIW;~~~"At11,ell,~,ments\,< Report Amendments ,,",','

Steel Steel and and stainless stainless Cumulative Cumulative TLAA, evaluated in TLAA, evaluated in Yes TLAA TLAA Fatigue is aa TLAA Fatigue steel reactor steel reactor coolant coolant fatigue fatigue damage damage accordance accordance with with (See SERSER pressure pressure boundary boundary 10 10 CFR CFR 54.21(c) 54.21(c) Section Section 3.1.2.2.1) 3.1.2.2.1) closure closure bolting, bolting, head head closure closure studs, studs, support support skirts skirts andand attachment attachment welds,welds, pressurizer presSurizer relief relief tank components, tcinkcomponents, steam steam, generator generator components, components, piping piping and and components compon~nts external -surfaces eJdemalsurfaces and and bolting bOiting ,

(3.1.1-7)

(3.1.1-7) L Steel; Steel; stainless stainless steel; steel; Cumulative Cumulative TLAA, TLAA, evaluated evaluated in in Yes Yes TLAA TLAA Fatigue is Fatigue is aaTLAA, TLAA and and nickel-alloy nickel-alloy fatigue damage

'fatigue damage accordance accordance with with (See (See SERSER reactor reactor coolant coolant 10 10 CFR CFR 54.21(c) 54.21(c) and and Section Section 3.1.2.2.1) 3.1.2.2.1) pressure pressure boundary boundary environmental environmental effects effects piping, piping; piping piping are are toto bebe addressed addressed components, c9mponents, piping pipifl9 for for Class Class 11 elements; elements; flanges; flanges; components components nozzles nozzles and and safe safe ends; pressurizer ends; pressurizer Vessel

'v,ess~1 shell shell heads heads and welds; and welds; heaterheater sheaths sheaths and and sleeves, sleeves; penetrations; pel1etration~; and and thermal thermal,sleeves sleeves (3.1.1-8) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

(3.1,1-8)

Steel; St~el; stainless stainless steel;

,steel; Cumulative Cumulative TLAA, TLAA, evaluated evaluated inin Yes Yes TLAA TLAA Fatigue Fatigue isis aa TLAATLAA steel with nickel-alloy steel with nickel-alloy fatiguefatigue damage damage accordance accordance with with (See (See SER SER '

or or stainless stainless steel steel 10 CFR 54.21 (c) and 10CFR54.21(c) and Section Section 3.1.2.2.1) 3.1.2.2.1) cladding; cfadding; nickel-alloy nickel-alloy environmental environmental effects effects reactor reactor vessel veSsel ' 'are are toto bebe addressed addressed components:

components: flanges;

'flanges; for for Class Class I1 nozzles; nozzles; components components penetrations; penetrations; pressure presSurehousings; hOusings; safe safe ends; ends;thermal thermal sleeves; sleeves; vessel vessel '

shells, shells,heads headsand and welds welds (3.1.1-9) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

(3.1.1-9)

\,

3-193 3-193

Component Group Aging'Effect/ AMP.In GALL Further AMP In LRA, Staff Evaluation (GALL Report Mechanism Report Evaluation Supplements,'

Item N4o.) In GALL or

___________________ ___________ Report Amendments Steel; stainless steel; Cumulative Cumulative evaluat~d in TLAA, evaluated Yes TLAA TLAA Fatigue is a TLAA steel with nickel-alloy nickel-alloy fatigue damage accordance accordance with (See SER or stainless stainless steel 10 CFR 54.2154.21(c)

(c) and Section 3.1.2.2.1)

Section 3.1.2.2.1) cladding; hickel~alloy nickel-alloy  ; environmental effects environmental effects steam generator generator are to be addressed addressed components components for Class 1 ..

(flanges; components components penetrations; nozzles; safe ends, nozzles; lower heads heads and and welds)

(3.1.1-10) ....

Steel top head head Loss of material material Water Water Chemistry Chemistry and and Yes applicable Not applicable applicable to Not applicable enclosure (without enclosure due to general, One-Time One-Time Inspection PWRs (See SER cladding) top head pitting and Section Section 3.1.2.2.2) 3:1.2.2.2) nozzles (vent, top crevice crevice head spray or RCle, RCIC, corrosion and spare) exposed to reactor t6 coolant reactor coolant*

(3.1.1-11)

(3.1.1-11)

__ _ _ __ _ _ __ _ _ _

Steel steam steam Loss of material material Water Chemistry Chemistry and Yes applicable Not applicable applicable to Not applicable g~neratorshell generator shell due toto general, general, One-Time Inspection BVPS (See SER assembly expo~ed exposed to pi~rig pitting and SectiOn 3.1.2.2.2.1)

Section'3.1 :2,2.2.1) secondary secondary feedwater feedwater crevice crevice and-steam and-steam corrosion (3.1 .1,12)

(3;1.H2)

. . .. ._ _ __ _ _ __ __ _ _ __ _ _

Steel and stainless stainless Loss of material LosS material Water Chemistry Watbr Chemistry and Yes Not applicable Not applicable Not applicable applicable to steel isolation due to general general Inspection One-Time Inspection PWRs (See SER condenser Condenser (st~el (steel only), Section Section 3.1.2.2.2) 3.1.2.2.2) components exposed pitting and components exposed pitting and to reactor reactor coolant . crevice crevice

(-31.1-13)

'. (:!,1.1-13) corrosion cQrtosion

..

Stainless steel, Stainless' Loss of Loss* of material material Water Chemistry and Yes Not applicable applicable Not applicable to nickel-alloy,pand nickel-alloy, "and due to pitting One-Time Inspection One-Time Inspection PWRs (See SER steel with nickel-alloy nickel-alloy. and crevice crevice Section 3.1.2.2.2)

Section or stainless steel corrosion clad.~il'1g cladding reaCtor reactor ves~elflariges; vessel flanges, .

nozzles, '!

penetrations, safe

penetrations, ends, vessel sh~ils, shells, heads and welds and welds (3.1.1-14) 3-194 3-194

'Co*m*pnent Group Ai0ng IEtkLt .lAMP inGALL Further AMP InLRA". Staff Evaluation (GALL, Re6rt s*chanism Report Evaluation Supplements,

.~ltm~o.;~.In GALL 'or;

_________ _______ _________ Report Amendhients.

,

Stainless steel; steel steel Loss of material Water Chemistry Chemistry and Yes Not applicable Not applicable to to nickel-alloy or with nlckel-alioyor due to pitting Inspection One-Time Inspection PWRs (See SER stainless steel and crevice Section 3.1.2.2.2) 3.1.2.2.2) cladding; cladding; and nickel-nickel- corrosion corrosion alloy reactor coo!ant coolant pressure bound~ry pressure boundary components components exposed to reactor coolant reactor coolant (3.1.,!-15)

(3.. 1.1,-15) .

_________ ___________ ______ _________ __________

. " . j Steel steam*

Steel steam' Loss of material material Inservice Inservice Yes ASME ASME Consistent Consistent withwith the generator upper and generator due to general, Inspection (IWB,'

general" Inspection (IWB, Code Code Section XI Xl GALL GALL Report Report (See lower shell and pitting and IWC, IWC, and IWD),IWD). and Inservice SER

. transition cone crevice Water Chemistry Watei' Chemistry Inspection, Inspection, Section Section 3.1.2.2.2.4) 3.1.2.2.2.4) exposed exposed to corrosion and; and, for Subsection Subsection IWB,IWB, secondary feedwater secondary feedwater Westinghouse Westinghouse IWC, and IWD IWC,and IWD and steam Model Model 4,4 4.4 and for Class 2 (3.1.1-16) 51 S/G, if general components components and pitting corrosion corrosion (B.2.2)

(B.2.2) and and of the shell is known Water Chemistry to exist, additional (B.2.42)

(B.2.42) inspection Inspection procedures procedures are to be be developed.

deve!()ped. ._ _

Steel (with or or.without Loss of fracture TLAA, evaluated in' . Yes TLAA,9valuated TLAA TlAA Loss of tracture fracture stainless steel toughness tough l1ess due accordance accordance with toughness isa is a cladding) cladding) reactor neutron to neutron 1.0 CFR 50, . tLAA (See SER TLAA vessel belt!ine bettline shell, irradiation Appendix G, G, and 3.1.2.2.3 Section 3.1.2.2.3 nozzles, and welds embrittlement embrittlement. RG 1.99. The item (1>>

(1)) .

(3.1.1-17) '.

(3.1.1-17) applicant may applicant choose to chpose demonstrate that the demonstrate the materials materials of the the nbzzles nozzles are not controlling for the

~

Tw. evaluations.

evaluations, Steel (with or Without without Loss of fracture . Reactor offracture Reaetor Vessel Yes Reactor Vessel Consistent with the Reactor the stainl~sssteel.

stainless steel toughness Surveillance tOlJghneSs due Surveillance Integrity (B.2.35) GALL Report Report (See cladding),reactor claddingtreactor' to nelJtr'On neutron SER SER' vessel Deltiine' b'eltlineshell, shell, irradiation Section .3.1.2.i3 3.1.2.223 nozzles, and Welds;'weids;- embrittlement (2))

item (2>>

safetY safety injection*

injection. ., .

nozzles no.zzles'*

(3.1.1-18)

(3: 1.1::1'8) ... __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _

Stainless steel and Cracking Cracking due to A plant-specific plant-specific aging Yes Not applicable applicable Not applicable to nickel-alloy top' nlqkel-alloy top head management stress corrosion management . PWRs (See SER enclosure vessel cracking and program is to be 3.1.2.2.4)

Section 3;1.2.2.4) leak detection flange leakdeteetion intergranular intergranular evaluated.

evaluated.

line stress corrosion corrosion (3.1.1-19) 1craqking cracking I 3-195 3-195

Com~ponenht Group, AigEfc .MP In' ALL'- Furte ANP'ILR ttaff Evaluatio

'(GALL-Report' -Mechnm Reork~n

,vii~l,

,Spp I2tem' No) . . In GALL o

__________________

___________ Rport Arrendmomnts Stainless steel Cracking due Cracking due to Inservice Inservice Yes applicable Not applicable Not applicable to isolation condenser stress stress corrosion Inspection (IWB, Inspection (IWB, PWRs (See SER components exposed exposed cracking cracking and IWC, and IWD),

IWC, 3.1.2.2.4)

Section 3.1.2.2.4) to reactor coolant coolant' intergranular Water Chemistry, (3.1.1-20) streSs corrosion stress and plant-specific arid plant-specific

. cracking clC.icking verification program verification program Reactor vessel shell . Crack growth Reactor growth TLAA Yes TLAA Crack Crack growth due due fabricated of SA50S-SA508- due tq to cyclic to cyclic loading is Cl 2 forgings clad CI loading aa TLAA TLAA (See SER with stainlesS With stainless steel . Section 3.1.2.2.5) using a~ high-heat-input welding Input welding process process (3.1 .721~2.1) p(3.1-21)

Stainless steel steel and Loss of fracture FSAR supplement supplement Yes *PWR Vessel

,PWRVessel Consistent Consistent with the nickel-alloy reactor nickel-alloy toughness due commitmentrto due commitmenho Intemals Intemals GALL Report (See vessel internals intemals , to neutron , (1) participate participate in , Program Program SER components exposed components exposed irradiation irradiation industry RVI aging Commitment Commitment Section 3.1.2.2.6) to reactor reactor cO,olant coolant embrittlement, em~rittlement, programs - (B.2.33) neutron flux and neutroriflux void swelling swelling (2) implement implement (3.1.1-22) applicable results (3) submit for NRC approval:>

approval > 24 24 .

, morith'sbefore months:b~fore the the extended period an extend6d RVI inspection, inspection plan industry, based on .industry' recommendation.

recommendation.

Stainless

~tainless steel steel, , Cracking Cracking due due to A plsn't-specific A, plant-specific aging aging Yes Water Chemistry Consistent with the the reactorvessel ' stress corrosion stresS corrosion' management management (B.2.42) and (B;2.42) GALL Report (S)ee GALL ReP9rt (~ee closure,head closureehead flange cracking program is to be One Olle Time SER SER, .

" leak detection Ihw line evaluated. '

evaiUated. Inspection Inspection Section Section 3.1.2.2.7.1) 3.1.2.2.7.1)

I and ,bottom~mounted arid bottom-mounted (B.2.30) instrument guide Instrument guid~

tubes, tubes (3.1.1-23)

(3~1.1-23)

__ _ _ _ __ _ _ _ _ __ _ _*_ _ _ _ _ .

., .

__ _ _ _ __ _ .__

_ _ _

. - ..

Class 1 cast , Cracking Cracking due due to Water Chemistry Yes Water Chemistry Chemistry Consistent with the the austenitic stainless austeritic stress corrosion .' and;'forCASS and fJor CASS (B.2.42)

(B.2.42) and GALL Report (See (See steel plplrig, st8,el piping, piping' piping cracking components that do

, domponehts ASME' ASME SER components, and cOmponents, , no(me~t not imeet the S~on,)(1 SectionXl Section 3.1.2.2.7.2)

'Section 3.1.2.2.7.2) -

piping elements eiemerits '. , N~REG"0313 NUREG-0313 In~ivice' In"rvice '.

exposed to to reactor guidelines, a plant-guld~lines,a 'lhspectlon, Inspction, coolant "

cooiant ' specific ~MP AMP Subs8ctionlWB, Subsiecion IWB, (3.1.1-24))

('3.1.1-24 - IWC, IWC,arid and IWD IWD '

(8.2.2)

(~.2.?)

Stainless steel jet Cracking due to A plant-specific plant-specific aging Yes Not appllca~le applicable applicable to Not applicable to pump sensing line cyclic loading management

, management PWRs (See (S~eSER SER

(~.1.1-25)

(3..1-25) program is to be program Section 3.1.2.2.8)

Section 3.1 ;2.2.8) evaluated. "

3-196

component Group Aging Effect/ AMP-In GALL Further AMP In LRA, .Staff Evalt,latlon Evaluation.

_(GALL Repirt ,: Mechanism, Repot Evaluation Supplements, ',,".

- .

hem o.)In' GLL' o

__________ R.,AM Amndmnents,,

Steel and stainless Cracking due to Inservice Inservice Yes Not applicable applicable Not applicable to to steel isolation cyclic loading Inspection (IWB, Inspection (IWB, PWRs (SeeSER (See SER condenser condenser IWC, and IWC, andlWD) and IWD) and Section 3.1.2.2.8)

Section 3.1.2.2.8) components exposed components exposed plant-specific plant-specific to reactor coolant coolant verification program verification program (3.1.1-26)

Stainless StainleSs steel and Loss of preload FSAR supplement Yes PWR Vessel Consistent with the the reactor nickel-alloy reactor due due to stress commitment commitment to Internals Intemals GALL Report (See vessel vessel internals internals relaxation relaxation (1)

(1 )' participate in (B.2.33)

(B.2;33) SER screws, bolts, tie scr:ews, industry RVI aging ind!Jstr'y Commitments Commitments Section ~.1.2.2.9) 3.1.2.2.9) rods, and hold-down hold-down programs prOgrams springs (2) implement (2) implement (3.1.1-27)

(3.1.1-27) applicable results (3) (3) submit for NRCNRC approval > 24 approval> 24 months before the the extended period period an RVI inspection inspection plan based on industry recommendation.

reCommendation.

Steel steam steam Loss of material plant~specific aging Yes material A plant-specific Yes Not applicable applicable Not applicable applicable to generator feedwater feedwater due to erosion erosion management management BVPS BVPS (See SER impingement p!ate impingement plate program is to be program Section Section 3.1.2.2.10) and.support and support exposed exposed evaluated.

evaluated. I tq* seCo'ndary to secondary .~

. feedWater feedwater * '.

(3.1,.1 ~28)

(3.1.1-28)

Stahiless steelste~m Stainless steel steam Cracking due to A plant-specific plant-specific aging Yes Not applicable Not applicable applicable to dryers exposed to tp flow~induced flow-induced management management PWRs (See SER PwRs reactor cOolant coolant vibration vibration program is to be Section 3.1.2.2.11)

Section 3.1.2.2.11)

(3.1.1-29)

(3.1.1-29) } evaluated.

evaluated.

! 3-197 3-197

. .

COITIPon~nt Group Gro~pAglng'Effect( .AMPlri,(:;ALLFur:th~r

.'

Component Aging'Effectl. AMP:in GALL Further AMP. In

, AMP LRA, In LRA, Staff Staff Evaluation Evaluation .

,(~ALLRepoi;t~

(GALL Rep6Ort . . Mechanism Mechanism .. , Report Report .Evaluation Evaluation . supplements, Supplements,

.' .ltein ItemNo.) N.o.,.* . " GALL In GALL in or" .' .' '.

or

;' .', ," "',,:,.,,:;, .,;: :-:'.,:.< . ; ' 0 ) '.* : . ..~.* ,::, ..:.,:,:'

_____________________

.* ~;, <.:'~'. ;.'; '.<' ' ...:;;' , ... ".

___________

~'~.~11, . ,: ..Amrendments

< Rport, ~~.~'t'ents ~.

Stainless Stainless steel Cracking due to Water Cracking Water Chemistry Chemistry and and Yes "i~ter Chemistry Water Chemistry Consistent with Consistent with the the reactor reactor vessel stress corrosion corrosion FSAR FSAR supplement supplement (B.2.42)

(B.2.42) and GALL Report Report (See internals internals components components cracking, cracking, commitment to commitment PWR PW~ Vessel SER (e.g., Upper Upper internals internals irradiation-irradiation- (1) participate participate in in Internals Section Section 3.1.2.2.12) 3.1.2.2.12) assembly, assembly, RCCA RCCA assisted stress assisted stress industry RVI aging aging Program Program guide guide tube tube corrosion programs programs (B.2.33)

(B.2.33) assemblies, cracking cracking (2) implement implement Commitments Commitments Baffle/former Bafflelformer applicable results applicable results a~sembly,Lower assembly, Lower (3) submit (3) submit for NRC NRC internal internal assembly, approval > 24 approval> 24 shroud assemblies, months months before before the the Plenum cover and PleriumcQver and extended period an extended plenum cylinder, . RVI inspection inspection plan

. Upper grid assembly, assembly, . based on <?n industry Control rod guide recommendation.

recommendation.

tube (CRGT) tube assembly, Core support shield shield assembly, Core barrel assembly, assembly, Lower grid assembly, assembly, Flow distributor distributor assembly, Thermal shield, Instrumentation Instrumentation support structures)

(3.1.1-30)

~----~------~~-------r----~--~~-r-------+----------~----------~I Njckel~alloy and.

-- Nickel-alloy and steel Cracking due to Cracking Inservice Inservice Yes Water Water Chemistry Consistent with the Consistent the with nickel-alloy nickel-alloy primary water primary Inspection Inspection (IWB, (IWBI- (B.2.42) and GALL Report (See cladding piping" c.ladding piping, stress corrosion stress' corrosion IWC, IWC, arid and IWO) IWD) and and ASME ASME* SER SER' -

piping component, cracking cracking Chemistry and Water Chemist.y Section XlXI Section 3.1.2~2.13)

Section 3.1.2.2.13) piping elements, piping. elements, .FSAR IFSAR supplement Inservice lriservice penetrations, commitment'to commitmentto . Inspection, Inspection, hOZzles~

nozzles, safe ends, implement applicable implement applicable Subsection IWB,IWB, welds (other and welds plant commitments to IWC, and IWO IWD than reactor vessel (1) NRC Orders, (B.2.2) pressurizer head); pressurizer Bulletins, and Bulletins, heater sti~aths, sheaths, Generic Letters Letters sleeves,, diaphr~gm sleeves" diaphragm associated with Nickel-Alloy plate, manways and nickel-alloys and Nickel-Alloy Nozzles and nickel-alloys flanges; core support (2) staff-accepted NoZzles and (2)

.'. Penetrations pads/core pads/cOre guide'lugs (3.1.1-3i) guide;lugs industry guidelines.

. industrY Program Program (3.1.1-31 ) PrOgram (B.2.28)

(B.2.28)

Commitment.

Commitment Steel steam

$teel Wail thinning A plant-specific A plant-specific aging Yes One-Time Consistent with the the generator feedwater gen~rator due to flow- management management Inspection GALL Report (See inlet ring and and accelerated accelerated program is is to be be (B.2.30)

(B.2.30) SER supports supports corrosion evaluated. 3.1.2.2.14)

Section 3.1.2,2.14)

(3.1.1-32)

(3.1.1-32) I_

3-198

CbComponent Group Aging EfficlJ AMPIn GALL TWFuther* :AMP In LRA,_.I Staff Evaluation (GA`LL Rteport:.' Mechanilsm Repor Eauto Sple nts, ItmN.)I ALL or J

-,~~~~~i _____ por Amndments Stainless Stainless steel and Changes in Changes in FSAR supplement Yes PWR Vessel PWRVessel Consistent with the the nickel-alloy reactor nickel-alloy dimensions due commitment commitme'rit to Internals Intemals GALL' Report GALL Report (See vessel internals to void swelling (1) participate participate in in Program SER components industry indu~try RVI aging (B.2.33) Section 3.1 .2.2.15) 3.1.2.2.15)

(3.1.1-33)

(3.1.1"33) programs-programs: Commitment Commitment (2)

(2) implement implement applicable results applicable 'results (3) submit for NRC (3)submitfor NRC approval > 24 approval> 24 before the months t>efore

, extended period peiiod an

~RVrinspection

!RVI inspection plan based on 'indllstry based industry recommendation.

recorl'lm.endation.

-'1 , -'

Stainless Stainl~ss steel'and steel and Cracking due Cracking Inservice due to Inservice Yes Water Chemistry Consistent Consistent with the, the nickel-alloy reactor nickel~alloy reactor stress corrosion Inspectioh(IWB.

inspection(IWB, (B.2.42) and (6.2.42) GALL GALL Report (See control rod drive drive cracking 'and cracki",g and IWC, IWC. and IWO) IWD) and ASME SER SER head penetration head penetration primarywater primary water WaterChemistry Water Chemistry and \ Sec'ti6n Settion XI Xl Section Section 3.1.2.2.16.

3.1.2.2.16.

pressure housings pressure stress corrosion for nickel-alloy.

nickel-alloy, Inservice 1) 1)

(3.1.1-34) cracking comply With with Section, Section.

applicable NRC ap'plicable N~C Subsections Subsections Orders and provide a Orders IWB, IWC.

IWB. IWC, and commitment commitment in in the IWD (B.2.2)

IWP FSAR supplement to FSARsjJpplement impleme~tapplicable implement applicable (1)) Bulletins' (1 Bulletins"and Nickel-Ally Letters and GenericLetters Generic and Nozzles and Nickel-Alloy (2) staff-accepted Pentans Nozzles and (2) staff-accepted industry guidelines. Penetrations Prneram

, ihdustryguidelines. Program Program (B.2.28),

(B.2.28)

Commitment with stainless Cracking Steel With Cracking due to Inservice

-Inservice" Yes Not'applicable Not' applicable Not applicable applicable to steel or nickel-alloy nickel-alloy stress corrosion corrosion In8~ctibn Insoection (IWB.(IWB BVPS (See SER claddingprdmary siqecracking clac!ding'primar:y side cracking and IWC, IWCiand and 1\\,0)

IWD) and Sections 3.1.2; 3.1.2A.1 1.1 components; steam c()mponents; steam primary primarY water Water Chemistry and and 3.1.2.2.16.1) 3.1.2.2.16.1) generator upper and stress corrosion

\ generatoruppejo'imd _fhrDickel~alloy.

for nickel-alloy, lower heads, heCids. ' - cracking cracking "omply

,;omply"With,with' ' '

tubesheets and tube- applicable NRC iilppli¢8ble sh.eet weldsI to-tube sheet Orde rs and provide a' Orders'arid, (3.1.1-35) , " comrriitm~nt:lri commitmentin the the FSAR-supplement to FSARsuppiement implement applicable impiement,applicable (1) BU-iIEW~s (1) Bulletins ,andand GenericLetters and Generic:Letters

_____________ __________

(2)

'(2) $~ff~a~pted staffy- cepted industryguidelines. ______ _______

industry guidelines.

3-199 3-199

/

Component Group', AgingEffect AMP in GALL Further :AMP In LIRA, Staff Evaluation (GALL.Rep .tMechialnism Reor EalatonSuplmets OitM No) w ALL~ o Nickel-alloy, Cracking due to Water Chemistry and Yes Water Water Chemistry Consistent with the Consistent the stainless steel stress corrosion One-Time Inspection Inspection (B.2.42) and GALL GALL Report Report (See pressurizer spray cracking cracking and and, and, for nickel-alloy One-Time One-Time SER SER head primary primary water welded spray heads, Inspection Inspection Section 3.1.2.2.16.

Section 3.1.2.2.16.

(3.1.1-36) stress stress corrosion comply with (B.2.30) 2) 2)

cracking cracking ,applicable applicable NRC provide aa Orders and provide commitment in In the the FSAR supplement FSAR. supplement to implement applicable ilJlplement applicable

~.ulletins and (1) Bulletins (1)

Letters and Generic LetterS staff~accepted (2) staff-accepted in'du~try industry .guidelines.

guidelines.

Stainless Stainless steel and Cracking due totei Water-Chemistry and Water and Yes Water Chemistry Consistent with the the nickel-alloy nickel:alloy reactor stress corrosion FSAR supplement 8uppl'ement (B.2.42)

(B.2.42) GALL Report (See vessel intemals internals cracking, commitment to conunltmentto SER SER '.

components componer'lts primary water primary paiticipate In (1) partiCipate PWRVessel PWR Vessel Section 3.1.2.2.17) 3.1.2.2.17)

(eg., Upper intemals (e,g.,.Upper stress corrosion industry RVI aging industry RVI aging Intemals Internals assembly, RCCA asserribly,RCCA cracking, programs prog'rams* (B.2.33) guide tube irradiation-irrad!ation- (2) implement Commitment Commitment assemblies, Lo.wer Lower assisted stress applicable applicable results results Internal 'assembly, Interrial corrosion (3) submit for (3)sutimit NRC forNRG CEA CEA shroud cracking approval >>24 24 .

assemblies, Core months before the before the shroud assembly, extended extended period an an Core support shield RVI :inspection inspection plan

.*. assembly; assembly, Core . based based on industry barrel assembly, assembly; recommendation.

recommendation.

Lower grid assembly,

. Flowdlstrlbutor Flow distributor assembly) asserr.ib,ly)

(3.1.1-37.)

(3;1:1-3n St~I'(with Steel.(with or without Cracking Cracking due to BWR Control Rod No Not applicable Not Not applicable to stainiesissteel.

stainiess steel cyclic loading Drive Retum Drive Return Line PWRs PWRs cladding) Control cladding) control rod Nozzle Nozzle return line drive retum line nozzles exposed nozzles exposed to reactor coolant',

reactdr coolant" (3.1.1-38).. . . .

(3.1.t-3lJ)

Steel'(with Steel (with or without Cracking Cracking due to BWR Feedwater Feedwater No Not applicable Not applicable to stainless steel stainlesi;o cyclic cyclic loading loading Nozzle PWRs PWRs cl~dding)'

cladding) f~dwater feedwater exposed to nozzles exposed nozzles reactor coolant reactor (3.1.1-39)

(3.1: 1-39) 3-200 3-200

Component Group Aging Effect/ AMP In GALL Further AMP in LRA, Staff Evaluation (GALL Report Mechanism Report Evaluation *Suppleents, Item No.) In GALL or Report Amendments.

Stainless steel and Cracking due to BWR Penetrations Penetrations No Not applicable Not applicable to nickel-alloy nickel-alloy stress stress corrosion and Water Chemistry PWRs PWRs penetrations for cracking, cracking, control rod drive stub Intergranular Intergranular tubes stress corrosion instrumentation, jet instrumentation, cracking, cracking, cycliccyclic pump loading instrumentation, instrumentation, standby standby liquid liquid control, flux monitor, control,flux'monitor, drainline and drain line exposed'to exposed to reactor coolant coolant

((3:.1."

1.140,)

1 0)

. '

Stainless StainleSs steel and Cracking due to BWR Stress No Not applicable Not app~icable applicable to nickel-all'oy piping, nickel-alloy stress corrosion Corrosion Corrosion Cracking Cracking PWRs PWRs piping. components, piping cracking and and Water Chemistry and piping elements piping elements intergranular intergranular greater gi'eaterthan than or equal.

equal stress corrosion to 44 NPS; nozzle,

,,!PS; nozzle cracking cracking safe ends and associated a'Ssociat'ed welds welds

(~~1,.1:4 ~y .' ,

Stainless steel and Cracking Cracking due to BWR Vessel ID ID-

.. No Not applicable applicable Not applicable applicable to

. niCkel~~IIQY nickel-alloy ve~~el vessel stress 90rrosion corrosion Attachment Attachment Welds PWRs PWRs

, shell attachmenet

'attachmel:it weilds exposed to"t" shei ' cracking and' and and Water Chemistry W~lds exposed. to intergranular inte,.granular reactor coolant '. stress corrosion (3:1.142)'

(3.1.1-42): cracking cracking .

Stai';le~

Stainless steel st~elfuel fuel Cracking due to Cracking to .BWR BWR Vessel .. No Not applicable applicable Not applicable applicable to slip~rtsandc6~tr:ol suppo0rtsand cohnctrol ,stresS stress corrosion Intemalsand internals and Water PWRs PWRs .

rod drivelassemblies d;;veiasserriblies .grackingcracking and and'Chemistry Chemistry

~~nir;Olr6(fdl'ive control rod'driVe lntergranular

'intergriuiular .

housing exposed

., tiQusing exposed to stressstress corrosion reactor cOolant coolant .... craclking crackil19 .

, (3:1.1 (3.1.1-43) :43) " .', _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

StainlesSsteelandCra¢k't!g~ue Stainless steel and Cracking due to BWRVessel BWR.Vessel No Not applicable applicable Not applicable NQt applicable to

'nickei~alloy nickel-alloy cQre core 'stresS~coitosion stress corrosion Internals Internals and Water PWRs PWRs shroud c0ore plate, shroud;ec,replate, cracking`,_

craCking," Chemistry core plat~

core. bolt~, : .

p!ate bolts,, intergrinular intergr'anular support structure, suPPprt* structure, top Stress.bcorrosion stress. qorrosion guide, core spra*"

gUide,cOrespray<' c~cklng, cracking,.

Iines,spargefS;j~t lines, spargers, jet irTC!.dia.tion~

irradiation-

, pump assemblies; assemblies; assisted stress control rod'drive

'control rod'drive, corrosion ....

housing, nuCiecilrnuclear cracking hOUSing, cracking instrumentation instrumentation' guldetubes guide tubes .

(3.1.1-44)

{3.1.1-44) ..... __

3-201

(

"

Component Group , Aging Effect/.. EffectJ AMP In GALL '. Further' Further AMP In (RA,

AMP LRA, Staff Evaluation Evaluatlt,n (GALL Report (GALL Mechanism Mechanism. " Report '" , , E~!lllJiltlol1c Evaluation Supplements, Supplements, or ',' ~ ' I",'

,;"<,.,;;;:~:;. ,,;) :;~;'>:!'; . . . :~';Vi};;;[" ,.!,~':

'." '

i"' Item No.)

Item, No:>: , , In GALL

',lrfGAL:L , ,;,.or"

"- , , ~ ,

'"

'~

.\:.

"i- Ie, LA

"'1 ~~:;. _________ ___________ ,.:;.'; :';~R~p~~::'\

Report . Amendments,

'At11en'dmen&",

,. v ~ .' 0." ~ A< ",r";£a;>-, I~i:ii;!\r;;:;:,'..',<

[<

.,'

.}).),;

Steel piping, piping Wall thinning Flow-Accelerated Flow-Accelerated No Not applicable applicable Not applicable applicable to components, and due due to flow- Corrosion PWRs PWRs piping piping elementselements accelerated exposed exposed to reactor corrosion corrosion coolant coolant (3.1.1-45)

(3.1.1-45)

,

Nickel-alloy core Nickel-alloy Cracking due to Inservice Inservice No Not applicable Not applicable-to applicable to shroud and core stress corrosion Inspection Inspection (IWB, (IWB, PWRs PWRs plate access hole cracking, IWC, IWC, and IWD), and (mechanical cover (mechanical intergranular intergranular Water Chemistry

(

covers) stress corrosion (3.1.1-46)

(3.1.1c46) cracking, irradiation-irradiation-assisted stress corrosion cracking Stainless steel and Loss of material Inservice No Not applicable Not applicable applicable to nickel-alloy reactor nickel-alloy due to pitting Inspection Inspection (IWB, (IWB, PWRs PWRs vessel vessel intemalsinternals and, and crevice crevice IWC, and IWD), and exposed to reactor corrosion Water Chemistry coolant  ;

(3.1.1-47)

Steel and stainless stainless Cracking due to Inservice No Not applicable applicable Not applica~le applicable to steel Class 1 piping, piping, stress corrosion corrosion Inspection (IWB, (IWB, PWRs PWRs fittings and branch branch cracking, cracking, IWC, and IWD),

IWC,and connections <:< NPS 4 intergranular intergranular Water chemistry, and exposed to reactor stress corrosion corrosion One-Time One-Time Inspection coolant cracking (for of ASME ASME (3.1.1-48)

(3;1.1-48) stainless steel Code Class 1 Small- Small-only), and bore Piping Piping thermal and mechanical  ; "

loading _

Nickel-alloy core Nickel-alloy Cracking due to C..;aking Inservice Inservice No Not applicable applicable applicable to Not applicable shroud ,and and core stress corrosion corrosion Inspection (IWB, (IWB, " PWRs PWRs plate access access hole cracking, cracking, IWC, and IWD),

cover (welded intergranular intergranular Water Chemistry, covers) stress corrosion corrosion and, for BWRswith aa (3.1.1-49) cracking, crevice crevice in the access acceSs irradiation-ilT(ldlatlon- hole covers, assisted stress augmented augmented corrosion inspection using UT UT cracking or other demonstrated demonstrated acCeptable acceptable inspection of the access hole cover welds welds 3-202

'Compoh~ntGrQup Component Group , ,g 'A.ln'EffectI Aging ,ýEffectl

~l"" '. AMP In GALL Further AMP In LRA, Staff Evaluation

..

~~ ;';.!~~;h~~£\rr.*;*;,

(GALL Report Item No.)

Mechanism

-;;MechanlsrTr:.

,'~~:"'~;"

"

. . ,'" ',,' " / ,}t:(::' ,.;

Report Evaluation InGALL Supplemenits,

'or

_________ _______ _________ Report Amendments High-strength low High-strength Cracking due to Reactor Reactor HeadHead No Not applicable applicable Not applicable to alloy steel top head head stress corrosion Closure Closure Studs PWRs PWRs closure studs and cracking cracking and exposed to air nuts exposed intergranular intergranular with reactor reactor coolant stress corrosion leakage' leakage . '. cracking cracking (3.1.1-50)

(3.1.. 1"50)

Cast austenitic austenitic ; LOSs~f Loss of fracture fr~cture ThermalAging Thermal Aging and No Not applicable applicable Not applicable to steel jet stainless steeljet toughness due Neutron Neutron Irradiation Irradiation PWRs PWRs pump assembly assembly lothermal to thermal aging Embrittlement of I;mbrittlement castings; orificed orificed fuel and neutron neutron . CASS CASS support

. suppqrt. irradiation

. (3.1.1~51)

(3.1.1-51) embrittlement embnttlement Steel and and stainless stainless . Cracking due.to due to Bolting Integrity No Not applicable applicable applicable to Not applicable s~eel.reactor coolant steei.reactor coc>lant . stress corrosion corrosion BVPS (See SER preSsure b()undar'y pressure boundary cracking, loss of cracking, Section 3.1.2.1.1) 3.1.2.1.1) pump and - material due to (RCPB) pumpand**

(RCPB) valve closure bolting, weEir, wear, loss of manway manway and I:mdhoklingholding preload due due to boiting, flange bolting, .' thermal thermal effects, bolting, and closil~ closure gasket creep, bolting in High",high- and salf- self-pressure <!Ild preSsure andhigh- .hig~ loosening looSening tel')1perature sys!~lTls temperature systeqms (3.1.1-:52)';"

(3. 1.1 -52) _ _ _ _ _ _ _________ _ _ _ _

,", / . - .<,',,' ".:': ::".

S.teel piping, piping Steel piping, Loss of material material Closed-Cycle No applicable Not applicable Not applicable to c()mponent~,

comrponents, and' and due to general, Cooling Water. Water. BVPS (See SERSER piping elementsr elements. pitting and System Section 3.1.2.1.1 Section 3.1.2.1.1))

exposed to closed

.e)(j:>osed Closed crevice crevice cycle cooling water 9ycle cooling water corrosion COlTPsion (3.1.1~~3) .

(3.1.1-53) _ ._ _-

Copper alloy ailoy piping, Loss of material Closed-Cycle No No applicable Not applicable Not applicable to components, due to'pittingi piping eompohEmt's; piping' to'pitting;, Cooling Water BVPS (See SERSER and piping .elements crevice, and and System 3.1.2.1.1))

Section 3.1.2.1.1 t()closecj'; galvanic exposed to'closed"' galvanic cycle cooling water Water corrosion (3.1.1-54) 1....* 1 1 3-203

Corrip()~entGr'aUp"~lngEff8clt; Component Group Aging Effect/ ,"~i;;~.~ AMP In ri411 ****;,;'j:tlrther*~

i...GALL Further t*,:AMp:lri;L~.

AMP In LJRA, .:Sti.ffEv~luation Staff Evaluation

~~!iii~i~ f!~~l~ i;?(i,~;r~f1Il~~~ ~1llf~ ~t~4l~~I;,;j/ 'h,.;,;**,*;i\;.

(GALL Report Mechanism Report Evaluation Supplements, Item No.)d In*n GALL or

_________ _______ __________ Report Amendments Cast austenitic Cast austenitic Loss of fracture Inservice Inservice No ASME Consistent with the Consistent stainless steel stainless toughness due Inspection toughness Inspection (IWB,(IWB, Section XI Section GALL Report pump Class 11 pump Class thermal aging to thermal aging IWC, IWC, and and IWD). 'Inservice Inservice and valve casings, and casings, valve embrittlement embrittlement Thermal aging Thermal aging Inspection, Inspection, bonnets bodies and bonnets bodies susceptibility susceptibility Subsection IWB, Subsection IWB, exposed to reactor exposed reactor screening is not screening not IWC, and IWC, IWD and IWD coolant>

coolant 250°C

> 250°C necessary, inservice necessary, inservice" (B.2.2)

(B.2.2)

(> 482°F)

(> 482°F) inspection inspection (3.1.1-55)

(31.1-55) requirements are requirements sufficient for sufficient m~i:lCiging' these managing agiJ'lg effects. ASME ag!ng ASME

" Code CaseN-481 Case N-481 pr:ovides an also provides an alternative for pump alternative pump casings:

casings.

Copper alloy Loss of of material Selective Leaching material Selective Leaching ofof No Not applicable applicable Not applicable to

> 15% piping, 15% Zn piping, due to selective Materials due Materials . BVPS (See SERSER piping components, leaching leaching Section Section 3.1.2.1.1) 3.1.2.1.1) and piping.elements and piping.elements closeg exposed to closed cycle cooling water cycle (3.1.1-56)

(3.1.1-56) - .. ,.-

. .

Cast Cast austenitic Loss of fracture Thermal Aging Aging No Thermal Aging Aging Consistent with the Consistent the stainless.

stainles's steel toughness due Embrittlement of Embrittlement GALL Report Embrittlement of GALL Class 1 piping, piping to thermal aging CASS .. Cast Austenitic Austenitic component, and embrittlement embrittlement Stainless Stainless Steel piping elements and piping-elements (B.2.41)

(B.2.41) control rod drive' drive pressure housings housings exposed to to reactor coolant> 250°C coolant > 250'C

(>482°F)

(> 482°F)

(3.1.1-57) f\

coolant Steel reactor cOolant material Boric Acid Corrosion No Loss of material Boric Acid Consistent with pressure boundary boundary, due to boric acid Corrosion Corrosion GALL Report external' external surfaces surfaces corrosion (B.2.7) exposed to air Withwith borated water water leakage leakage (3:1.~-58)

(3.1.1-58) 1 3-204

ýCompfonent;Gr'oup Aging, Efect AMP In GALL- Furthe AMP InILRA, Stf Evaluation (ALRepor Mehnsm Rport Evaluaitioni Supplements item No.) }.In GALL or,.

________ _________ Reoort Amendments, Steel steam Steel steam Wall thinning Wall Flow-Accelerated Flow-Accelerated No Not applicable Not applicable to generator steam generator due to flow- Corrosion BVPS (See SER nozzle and noZzle and safesafe end, end, accelerated accelerated 3.1.2.1.1)

Section 3.J .2.1.1) feedwater nozzle and feedwater and corrosion safe end, AFW nozzles and nozZles and safe ehds exposed to

~econdary secondary .

feedwater/steam feedwaterlsteam (3.1.1-Z59)

(3: 1.1;59) * ....

Stainless steel StainleSs steel flux flux, LossLoss ofof materi~'

material Flux Thimble Tube Flux' No No Consistent with the' Flux Thimble 'yonsistent the thimble tubes tubes (with(with. or due to wear Inspection Tube Inspection Inspection GALL Report without chrome ' (B.2.19) plating) .

(31.-60) ,

(~.1.H>O) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Stainless steel, Stainless steel, steel steel Cracking due to Inservice /'.

Inservlce No ASME the.

Consistent with the, preSsuri~erintegral pressurizer integral cyclic loading Inspection (IWB,(IWB, Section XIX1 GALL Report support exposed support exposed to to IWC, and IWO) IWD) Inservice Inservice air with metal ,., Inspection, Inspection, temperature up temperature up to to Subsections Subsections 288C'(5So"F) 2!38°C' (550°F) IWB, IWC, and IWB,IWC, (3,1.1-61 t (3.1.1.-61) .... __ _ _IWD.(B.2;2) IWg'(B.22)

Stainless steel, steel StainleSs ste,el Cracking due to Inservice Inservice No Not applicable Not applicable applicable to with stainless steel

'.YithstainleSssteel cyclic loading Cyclic loading Inspection (IWB, Inspection (IWB, BVPS (See SER cladding reactor cladding reactor' IWC, and IWO)

IWC; IWD) Section,3.1.2.1.1) )

Section,3.1.2.1.1 coolant sy~teni system Cold cold leg, I~,hothot leg6,surge leg, surge line, lil)e,~ndspray and-spray line line piping and piping and fittings fittings exposed to reactor exPbsedto coolant .

'(~J,:

1(3.1.1-ý62) 1-:?2).. .' _ _ _ _ _ _ _ _ _ _ _ _ _ _

I '

Steel r9~ctbrvessel Steel reactor vessel Loss Loss ofof material material Inservice Inservice., . No No ASME ASME Consistent with Consistent with the the flange, stainless flange, stainiless *- due,to due to wear Inspection (IWB, Inspection (I¥VB, Section XI GALL Report GALL 'Report steel/and: ni6kel~alloy' steer and, nickel-alloy IWC, and IWC, and IWD)

IWO) Inservice reactor vessel vessel ' Inspection, Inspection, Ihterri~i~~xposed internals eXposed to, to, Subsections Subsections reactor coolant '

reactor IWB, IWC, and IWB, IWe, (e.g., upp~'rand (e.g., upper and IWD IWb (B.2.2)

(B.2.2) lower iritemals:

internals.'

assembly, CEA assembiYi CEA shroud ,~s~emlJly, s~roud assembly, core support barrel, cbresupport upper grid

'upper assebrlly, gridasSerribly, core 'shlel~

support shield core $UPport assembly, assembly, lower grid grid assembly) .

(3.1.1-63)

(3.1.1-63) 3-205 3-205

Component Group A4glng Component Effect!

Aging Effectl AMP.InIGALL AMP In GALL FUrer . AMP Further' AMPin In LRA, LRA; St~ff Evaluation Staff Evaluation

, .(G~~L::~e~~H:>1 (GALL ýeport' ~echanl~m' Mechanisme Rep-ort,-i ;i' .E:-,~r~iI~l~n, v" ,Report, Evaluait ion "s~ppi~!"e~tS,:

Spple~mnts, -' ., <, .

Item No.)

'i'."'~'~,~~:;~~*!~"~:{,r" I':':', D':~;;i':>

In GALL or

' ,';< ' < , : i :,*,!,~:£~L.~"<!~~~~~i~~,:': " ,\

Stainless steel steel and Cracking due to Inservice Inservice No ASME Consistent with the Consistent the steel with stainless stress corrosion Inspection (IWB, Inspection (IWB, Section XIXI GALL Report steel or nickel-alloy nickel-alloy cracking, fwc, and IWD) and IWC, Inservice Inservice cladding pressurizerL primary water cladding pressurizec Water Chemistry Inspection, components stress corrosion corrosion Subsections SubseCtions (3.1.1-64) -, cracking IWB, IWC, and IWa, IWD (B.?2)

I'yVD (B.2.2) and Water Water Chemistry Chemistry (B.2.42)"

(B.2.42) .

Nickel-alloy reactor Nickel-alloy Cracking due to Inservice No ASME Consistent Consistent with the the vessel upper head vessl3lupperhead primary water water Inspection (J\iVB, h1spection (IWB, Section Xl section XI GALL Report and control control rod drive drive stress corrosion and IWD) and corrosion IWC, andlWD) Inservice Inservice penetration nozzles, nozzles, cracking Water Chemistry and Inspection, Il1s'pection, instrument tubes,

, instrumerittubes, Nlckel~Alloy Nickel-Alloy Subsections Subsections head vent pipe (top venfpipe(top Nozzles Penetration Nozzles IWB, IWC, and IWB, head), and welds Weld~d to the Upper Welded IWD (8.2,2),

IWD' (B.2.2),

(3.1.1-65)

(3.f1-65) Reactor Vessel ' Water Chemistry Chemistry Closure Heads'of Closure Heads 'of (B.2.42), and Pressurized Water Nickel-Alloy Nickel-Alloy Reactors Penetration Penetration Nozzles Welded NoZzles

,Upper to the ,UpPEilr Reactor Vessel Reactor ClosurireHead Ci08ur8'Head >.'

(B.2.29)

(B.2.29)

Steel steam Loss of material In Inservice service No Not applicable*

applicable - Not

-NotApplicable Applicabie to generator secondary generator secondary due to erosion Inspection (IWB, Inspection (IWB, BVPS (See SER manways'and manwaysand IWC, and IWD)fcir IWD) for Section Section 3.1.2.1.1) 3.1.2.1.1) handholds ..

, handholds Class 2 cQmponents components (cover only) exposed to air with leaking leaking secondary-side secondarY-side waterwater

. and/or steam (3.1.1 66)

(3.1;1t66) _

Steel with stainless Cracking Cracking due to Inservice Inservice No Not applicable applicable Not Applicable to steel or nickel-alloy nickel-alloy cyclic loading Inspection (IWB, Inspectiqn (IWB, BVPS (See SER cladding; or stainless IWC, and IWD), and IWC, Section 3.1,.2.1.1) 3.1:2.1.1) steel pressurjzer steel' pressurizer Water Chemistry .

components exposed exposed to reactor to' reactor' coolant (3.1.1-67):

(3.1.1-67>' 1 3-206 3-206

Component, Group Aging Effect/ AMP In GALL. Further A 1MPIn LRA, Staff Evaluation (GALL Report' ýMechanlsm Report Evaluation Sup*lements, '

4tem No.) iný GALL or-

___________ ___________________ Report Amendments Stainless steel, steel Cracking due to Inservice Inservice No ASMVE ASME Consistent with the with stainless steel stress corrosion (IWB, Inspection (IWB, Section Xl XI GALL Report Report cladding Class 1 cracking IWC, and IWD), and Inservice Inservice piping, fittings, pump Water Chemistry Inspection, casings, valve Subsections Subsections bodies, nozzles, safe IWB, IWC, and IWB, ends, manways, IWD (B.2.2) and flanges, CRD Water Water Chemistry housing; housing; pressurizer (B.2.42)

(8.2.42) heater heater sheaths, sleeves, diaphragm plate; pressurizer plate; pressurizer relief tank components, reactorreactor coolant system cold cold

leg, leg, hot leg, surge surge line, and spray lineline piping and fittings fittings (3.1.1-68)

(3.1.1-68)

Stainless Stainless steel, Cracking Inservice Cracking due to Inservice No ASME the Consistent with the nickel-alloy nickel-alloy safety stress corrosion Inspection Inspection (IWB, (IWB, Xl Section XI GALL Report injection injection nozzles, nozzles, cracking, IWC, and IWD), and IWC, Inservice Inservice safe ends, and primary water Water Chemistry Chemistry Inspection, associated associated welds stress corrosion Subsections Subsections and buttering buttering cracking IWB, IWC, and IWB,"IWC, and exposed to reactor IWD (B.2~2)

IWO (B.2.2) and and coolant Water Chemistry (3.1.1-69) (B.2.42)

(B.2.42)

Stainless steel; steel Cracking due to Inservice Inservice No ASME Consistent with the the with stainless steel stress corrosion Inspection (IWB, corrosion Inspection (IWB, Section Xl Section XI GALL Report cladding Class 1 cracking, IWC, and IWD),

IWC, Inservice Inservice piping, fittings and piping, thermal and Water chemistry, and Inspection, connections branch cOnnections mechanical mechanical One-Time Inspection Subsections Subsections exposed to

<< NPS 4 exposed loading loading of ASME AS ME IWB, IWC, andand reactor coolant Code Class 1 Small-Small- IWD (B.2.2), ..

(3.1.1-70)

(3.1.1~70) bore Piping Water Chemistry (B.2.42), and (B.2.42),

One-Time One-:TIme Inspection of ASME ASME Code Class 1 Small Bore

__Piping (B.2.31))

fllping(B.2.31 High-strength low High-strength Cracking due to Reactor Head Cracking No" Reactor Head

~ead Consistent with the the alloy steel closure stress corrosion Closure Studs Closure Closure Studs GALL Report head, stud assembly head cracking; loss of cracking; (B.2.34)

(B.2.34) exposed to air with material due to to reactor coolant wear leakage leakage (3.1A1-71))

(3.1,1-71 3-207

Component Component Gro!-,p' Group 'Aging Aging Effecti EffectJ AMP In GALL' GALL Further*-AMP

,Further AMP"InIn LRA, Staff Evaluation Staff Evaluation

.(GALL (GALL Report Report. Mechanism

-Methanism~,p6rt Report Evaluation Supplements,"

Evaluation Supplements,

"'" .:::',,',; '>/ ;'t~0;;;:-.";;': . . ;,~£;:p~~~,/ ;,l~~~[~entfS'J

" 'lte;n Item No.)No.) ,', .in GALL or'

',<>,i,!*,:;v

_______.'_._:_,

" , ___________ _..________r.__ Report Amendments" ,.i Nickel-alloy steam Cracking due to Steam Generator Generator No Steam Consistent with thethe generator tubes and generator OD stress 00 Tube Integrity Integrity and and Generator Generator Tube GALL Report sleeves exposed to corrosion Water Water Chemistry Chemistry Integrity (B.2.38) secondary cracking and and arid Water feedwater/steam feedwater/steam intergranular intergranular Chemistry (3.1.1-72) attack, loss of (B.2.42)

(B.2.42) mateial due to material to frettingand fretting and wear wear Nickel-alloy steam Nickel-alloy Cracking due to Steam Generator Generator No Steam Consistent with thethe generator tubes, generator primary water Tube Integrity Integrity and Generator Tube GALL Report repair sleeves, and stress corrosion corrosion Water Chemistry Integrity (B.2.38) tube plugs exposed cracking and Water Water to reactor coolant, coolant ' Chemistry (3.1.1~73)

(3.1.1-73) (B.2.42) ,

Chrome plated steel, steel, Cracking due to to. Steam Generator No Steam Consistent with thethe stainless steel, " stress corrosion corrosion Integrity and Tube Integrity Generator Tube Tube GALL Report nickel-alloy steam nickel-alloy cracking, loss of Water Chemistry Integrity (B.2.38) generator generator anti- material due to and Water Water vibration bars crevice..

crevice, Chemistry

,exposed exposed to corrosion and, and (B.2.42) secondary secondary' fretting feedwater/steam feedwaterlsteam (311;1-74)

(~: ;1-74) _ ..- .=

Nickel-alloy once-Nickel-alloy Denting due due to Generator Steam Generator No Not applicable applicable Not Not applicable to through through steam corrosion corro~ion of Tube Integrity and Integrity and' BVPS (See SER (SeeSER generator tubes carbon steel carnon Water Chemistry Section 3.1.2.1.1 3.1.2.1.1))

exposed to tube support secondary secondary . plate plate feedwater/steam feedwaterlsteam (3.1.1-75)

Steel steam

,Steel Loss of material Steam Generator Generator No Steam Consistent with the Consistent the generator tube generator due to erosion, Tube Integrity and GeneratorTube GALL GeneratorTube GALL Report support plate, tube general, pitting, Water ChemistryChemistry Integrity (B.2.38)

Integrity bundle wrapper and crevice and Water Water exposed to ' - corrosion, Chemistry secondary lig'ament ligament (B.2.42) feedwat~rlsteam feedwater/steam cracking due to cracking (3.1.1-76) "

(3.1.1-,76) corrosion ' _

Nickel-alloy steam Nickel-alloy Loss of material Steam Generator Generator No Not applicable Not applicable Not applicable applicable to generator tubes and gerierator due totowastage wastage Tube Integrity and BVPS (See SER sleeves exposed to andpitting and, pitting Water Chemistry Section 3.1.2.1.1)

Section 3.1.2.1.1) phosphate chemistry corrosion h,

in secondary feedwater/steam (3.1.1-77) 1 1 _

3-208 3-208

ComponentGroup Ag***ingEetl AMPin GALL Further AMPin LRA, Sta6ff EvaluatIon.

(GALL Report Me~chnism Report Evaluation Supplements,.

I2tem NO.)_ in GALL o

.. .. Report Amiendments'

$teel Steel steam Wall thinning Steam Generator Generator No Not applicable Not applicable applicable to generator tube generator due to flow- Tube Integrity Integrity and BVPS (See SER 9VPS support lattice bars accelerated Water Chemistry 3.1.2.1.1)

Section 3.1.2.1.1) exposed to corrosion corrosion secondary feedwater/steam feedwaterlsteam (3.1.1-78)

(3:1.1-78) _.

Nickel-alloy steam Nickel-alloy Denting due to to. Steam Steam Generator Generator No Steam Ste,am Consistent with the the generato generatoritubes tubes corrosion of of*' Tube Integrity; Water Generator Tube GALL Report exposed exposed to steel tube Chemistry and, for Integrity (B.2.38)

(9.2.38) secondary secondary support plate plants that could, could Water and Water feedwater/steam feedwaterlsteam experience denting expeMerice, denting Chemistry (3.1.1~79)

(3.1.1-79) upperSupport at the upper' support (B.2.42)

(9.2.42) plates, evaluate plates;e.valu,ite potential for rapidly p()tenticilforrapidly propagating cracks cracks and then develop develop and take corrective take' corrective actions consistent consistent with NRC Bulletin 9uiletin 88-02.

Cast austenitic austenitic' , Loss of fracture Thermal Aging and Thermal No Thermal Aging Consistent Consistent with the the stainless steel staililess toughness toughness due Neutron Irradiation Neutron Irradiation and. Neutron and Neutron GALL Report ' '

reactorvessel reactor vessel to thermal aging.

aging, Embrittlement Ernbrittlement of Irradiation internals (e.g., upper and neutron internals (e'.g., CASS . Embrittlementof Embiittlement of internals intemall> assembly, irradiation ' Cast Austenitic lower internal. .

lower internal embrittlement Stainless Stainless Steel assembly, assembly,CEA CEA ' (B.2.40)

(9.2.40),

, shrOud assemblies, shroud assernblies, control

, cQntrol rodrod gýuide guide tube assembly, assembiy,' corecore support support shield shield assembly, aSsembly,lower lower grid grid assem~ly),

assembly)?

(3.).f~O)

(3.1.1 -80) , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Nickel~aiio'y~r,nickel-Cracking Nickel-alloy or nickel- Cracking due to Water chemis~ry Chemistry No Water Chemistry Chemistry Consistent Consistent with the the alloycla~

alloy.clad stElan; steam primary water (B.2.42)

(9.2.42) GALL GALL Report generator, divider, generator. stress corrosion aivider'" ,stress expqs~dt6 plate exposed t0 ' cracking cracking reactor coolant reactor

(~.J 1.:81)' "

Stainless'steel

, Stainless steel steam Cracking due to Water Chemistry Chemistry No Not applicable applicable Not applicable applicable to generatorpi:l~ary generator pdmary , stress corrosion streSs corrosion BVPS 9VP$ (See 5ER SER side divider plate

,side'divider plat~ cracking Section 3.1.2.1.1)

SeCtion 3.1.2.1.1) exposed to exposed to' reactor reactor coolant '

(3.1.1-82).

($.1 :1-82) _ ,, __ _

3-209 3-209

. "... ~

CrpnnGroup..ý!Ag iingEetl AMP In GALL Furthe~r AMP&In,LRA-, Staff EvaIluat:Ion (GALL Reportzl Me~chainism Report Evaluation Supplemeftnts, Item NO.) In GALL -~~or,

.. ., . ._ _ "_ _ "...._.._ __ . . ."".. .. . i"Report ndme 1W :  :-"

Stainless steel; steel steel lossLoss of material material Water Chemistry Chemistry No Water Chemistry Chemistry Consistent with the the nickel-alloy or 'due with nickel-alloy due to pitting (B.2.42) GALL Report GAll Report stainless steel , and crevice crevice cladding; and nickel- corrosion cladding; alloy reactor vessel intemals and reactor internals coolant pressure boundary ,

components exposed exposed to reactor coolant t'o coolant (3.U:.s3)

(3. 1.1-ý83) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

~icl<:el~alloy Nickel-alloy steam Cracking due to Water Chemistry and No Not applicable Not applicable to t6 g~rierator generator stress corrosion One-Time Inspection corrosion One-Time Inspection BVPS (See SER components such such as, cracking or Inservice

'or Inservice Section 3.1.2.1.1) 3.1.2.1.1) secondary side Inspection Inspection (IWB, (IWB, nozzles nozzles' IWC, IWC, and IWO).

IWD).

(vent, drain, aQd and instrumentation) instrumentation) exposed to secondary feedwater/steam (3.1.1-84)

(3.1.'1'-84)

• .1-1. L

": '

Nickel-a4lloy pipi~g, Nickel-alloy piping, None None None

None' No None None Consistent Consistent with the the components, piping cOmponents, GALL Report and piping' piping elementselements expo~e~to exposed to air~ air

• Indoor unc6ntroiled Indoor uncontrolled (external)

(extemal)

(3. 1.185)

(3.1 .. 1:.a5), ' --

St~inless,st~el Sta'inlesslsteel None None No None None, Consistent with thethe piping,.i>ipi~g'

'piping pip!ng GALL Report GAll campone,tits, compone.ts, 'and and piping elements elements expose6d to air --

expo,sed ir6door uncontrolled indoor uncontrolled (External); "aii"with (Exter:nal); airiwith borate~,water borated water '

leal<:ag~;concrete; leakage; concrete; gas . :,,-~, :'

ga~

, (3;1.1,.s6)

Steelpip!ng, Steel: piping, piping pipirig None None No applicable Not applicable Not applicable applicable to components and components. and, BVPS (See SER piping elements in pipjng Section 3.1.2.1.1) 3.1.2.1.1) concrete (3.1.1-8; (3; 1.1 :.at)'

6 , ) ,A The staff's review of the reactor vessel, reactor reactor vessel internals, and RCS. compon~nt groups Res component groups followed any one of several anyone several approckhes. approaches. One approach, documented in apprbach, documentedinSER Sec.:tion 3.1.2.1, SER Section 3.1.2.1, reviewed AMR results reviewed results for components that the the applicant indicatedindicated are consistent with with the GALL 3-210 3-210

Report and require no further evaluation. documented in SER evaluation. Another approach, documented Section 3.1.2.2, reviewed AMR Section AMR results for components components that the applicant applicant indicated indicated are consistent with the GALL Report consistent Report and for which which further evaluation evaluation is recommended.

recommended. A third approach, documented documented in SER Section 3.1.2.3, reviewed AMR AMR results for components components that thethe applicant indicated are not consistent addressed in, the GALL consistent with, or not addressed GALL Report. The staff's review of AMPs credited to manage manage or monitor aging effects of the reactor vessel, reactor vessel internals, and RCS components is documented documented in SER Section Section 3.0.3.

3.1.2.1 AMR 3.1.2.1 AMR Results Results Consistent Consistentwith the GALL GALL Report Report LRA Section 3.1.2.1, 3.1.2.1, the applicant applicant identifies identifies the materials, environments, AERMs, and the the following programs that manage manage aging effects effects for the reactor vessel, reactor reactor vessel internals, and RCS components:

• • ASME Section Section XI Inservice Inservice Inspection, Subsections Subsections IWB, IWC, and IWD Program

• Bolting Integrity Integrity Program

• Boric Acid Corrosion Program

• Closed-Cycle Closed-Cycle Cooling Water System Program

• Monitoring Program External Surfaces Monitoring

• Flux Thimble Tube Inspection Program

• Nickel-Alloy Nozzles Nozzles and Penetrations Program

• Nickel-Alloy Penetration Nozzles Welded to the Upper Upper Reactor Reactor Vessel Closure Heads Heads Program

• One-Time Inspection Inspection Program

• One-Time Inspection of ASME Code One-Time Code Class 1 Small Bore Piping Program

• PWR Vessel Vessel Internals Program Internals Program

• Reactor Head Closure Studs ProgramProgram

• Reactor Vessel Integrity Integrity Program

• Generator Tube Integrity Program Steam Generator

• Thermal Thermal Aging and Neutron Irradiation Irradiation Embritllement Embrittlement of Cast Austenitic Stainless Steel (CASS) Program

• Thermal Aging Embrittlement Stainless Steel (CASS) Program Embrittlement of Cast Austenitic Stainless Program

• • Water Water Chemistry Chemistry Program LRA Tables 3.1.2-1 summarizes AMRs for the reactor vessel, reactor vessel 3.1.2-1 through 3.1.2-3 summarizes vessel internals, and RCS components and indicates AMRs claimed consistent with the GALL claimed to be consistent Report.

For component groups evaluated in the GALL GALL Report for which the applicant applicant claimed consistency consistency with the report and for which it does not recommend recommend further evaluation, the staff's further evaluation, audit and and review determined determined whether whether the plant-specific plant-specific components components of these GALL Report component component groups were bounded by the GALL Report evaluation. evaluation.

3-211 3-211

The applicant noted The applicant noted forfor each each AMRAMR line line item item howhow the the information information in in the the tables tables alignsaligns withwith the the information in the GALL Report. The staff audited those AMRs information in the GALL Report. The staff audited those AMRs with notes A through EE indicating with notes A through indicating how how thethe AMR AMR is is consistent consistent with with the the GALL GALL Report.

Report.

Note Note AA indicates indicates that that the the AMRAMR lineline item item is is consistent consistent with with thethe GALL GALL ReportReport for for component, component, material, environment, and aging effect. In addition, material, environment, and aging effect. In addition, the AMP is consistent with the the AMP is consistent with the GALL GALL ReportReport AMP, The staff audited these line items to verify consistency AMP, The staff audited these line items to verify consistency with the GALL Report and validity with the GALL Report and validity of of the the AMR AMR for for the the site-specific site-specific conditions.

conditions.

Note Note BB indicates indicates that that the the AMRAMR lineline item item is is consistent consistent with with thethe GALL GALL ReportReport for for component, component, material, environment, and material, environment, and aging effect. aging effect. In In addition, addition, the the AMPAMP takes takes somesome exceptions exceptions to to the the GALL GALL Report Report AMP. AMP. The The staffstaff audited audited these these line line items items to to verify verify consistency consistency with with the the GALL GALL Report Report and and verified verified that that thethe identified identified exceptions exceptions to to the the GALL GALL Report Report AMPs AMPs have have been been reviewed reviewed and accepted. The staff also determined whether the and accepted. The staff also determined whether the applicant's AMP was consistent with applicant's AMP was consistent with the the GALL GALL Report Report AMP AMP and and whether whether the the AMRAMR was was valid valid for for thethe site-specific site-specific conditions.

conditions.

Note Note C C indicates indicates that that the the component component for for the the AMR AMR line line item, item, although although different different from,from, is is consistent consistent with with the the GALL GALL ReportReport for for material, material, environment, environment, and and aging aging effect.

effect. In In addition, addition, the the AMPAMP is is consistent with the GALL Report AMP. This note indicates consistent with the GALL Report AMP. This note indicates that the applicant was unable to that the applicant was unable to find find aa listing of some system components in the GALL Report; listing of some system components in the GALL Report; however, the applicant identified in however, the applicant identified in the the GALL GALL Report Report aa different different component component with with thethe same same material, material, environment, environment, aging aging effect, effect, and and AMP AMP as as the the component component under under review.

review. The The staff staff audited audited these these line line items items to to verify verify consistency consistency with the GALL Report. The staff also determined with the GALL Report. The staff also determined whether the AMR line item of whether the AMR line item of the the different different component component was was applicable applicable to to the the component component under under review review and and whether whether the the AMR AMR was was valid valid for for the the site-specific site-specific conditions.

conditions.

Note Note D 0 indicates indicates that that the the component component for for the the AMR AMR line line item, item, although although different different from, from, is is consistent consistent with the GALL Report for material, environment, and aging with the GALL Report for material, environment, and aging effect. In addition, the AMP takes effect. In addition, the AMP takes some some exceptions exceptions to to the the GALL GALL Report Report AMP. AMP. The The staff staff audited audited these these lineline items items to verifyverify consistency consistency with with the the GALL GALL Report.

Report. The The staff staff verified verified whether whether the the AMR AMR line line item item of of the different different component component was was applicable applicable to to the the component component under under review review and and whether whether the the identified identified exceptions exceptions to to the the GALL GALL ReportReport AMPs AMPs have have beenbeen reviewed reviewed and and accepted.

accepted. The The staffstaff also also determined determined whetherwhether the the applicant's applicant's AMP AMP was was consistent consistent with with the the GALL GALL Report Report AMP AMP and and whether the AMR was whether the AMR was valid*for valid for the site-specific conditions.

site-specific conditions.

Note Note EE indicates indicates that that the the AMRAMR line line item item is is consistent consistent with with the the GALL GALL Report Report for for material, material, environment, and aging effect, but credits a different environment, and aging effect, but credits a different AMP. The staff audited these AMP. The staff audited these lineline items items to to verify consistency with the GALL Report. The staff also verify consistency with the GALL Report. The staff also determined whether the credited determined whether the credited AMP AMP would would manage manage the the aging aging effect effect consistently consistently with with the the GALL GALL ReportReport AMP AMP and and whether whether the the AMR AMR was was valid valid forfor the the site-specific site-specific conditions.

conditions.

The The staff staff audited audited and and reviewed reviewed the the information information in in the the LRA.

LRA. The The staff staff did did notnot repeat repeat its its review review of of the matters described in the GALL Report; however, the matters described in the GALL Report; however, the staff did verify the staff did verify that the the material presented presented in in the the LRA LRA was was applicable applicable and and thatthat the the applicant applicant identified identified the the appropriate appropriate GALL GALL Report AMRs.

Report AMRs.

The The staff staff reviewed reviewed the the LRALRA to to confirm confirm that that thethe applicant:

applicant: (a) (a) provided provided aa brief brief description description of of the the system, system, components, components, materials,materials, and and environments; environments; (b) (b) stated stated that that the the applicable applicable aging aging effects effects were were reviewed reviewed and and evaluated evaluated in in the the GALL GALL Report; Report; and and (c) (c) identified identified thosethose agingaging effects effects forfor the the 3-212 3-212

reactor vessel, reactor reactor vessel internals, and RCS components that are subject to an AMR. On On the basis of its audit and review, the staff determines determines that, for AMRs not requiring further evaluation, as identified in LRA Table 3.1.1, 3.1.1, the applicant's applicant's references to the GALL Report are are acceptable and no further acceptable further staff review is required, with the exception of the following AMRs that the applicant had identified identified were consistent with the AMRs of the GALL Report and for which the staff felt were in need of additional additional clarification and assessment. The staff's evaluations evaluations of these AMRs are providing providing in the subsection subsection that follows follows 3.1.2.1.1 AMR Results Identified Identified as Not Applicable Applicable In LRA Table 3.1.1, 3.1.1, items 12, 35, 66, 75, and 84, the applicant states that the corresponding corresponding AMR result line in the GALL Report is not applicable because BVPS does applicable because does not have once-through steam generators. The staff reviewedreviewed the documentation applicant's documentation supporting the applicant's AMR evaluation and confirmed the applicant's claim that BVPS has no once-through once-through steam generators. BVPS steam generators are recirculating, recirculating, as described described in UFSAR 4.2.2.4 UFSAR Sections 4.2.2.4 for Unit 1 and 5.4.2.4 for Unit 2. Therefore, Therefore, the staff agrees agrees with the applicant's applicant's determination determination that the corresponding corresponding AMR result line in the GALL Report Report is not applicable applicable to BVPS.

In LRA Table 3.1.1, 3.1.1, item 28, the applicant states that the corresponding corresponding AMR result line in thethe GALL Report is not applicable applicable because BVPS does not have impingement plates. The staff staff reviewed the documentation documentation supporting the applicant's applicant's AMR evaluation evaluation and confirmed thethe applicant's applicant's claim that BVPS does not have impingementimpingement plates. Therefore, Therefore, the staff agrees agrees with the applicant's determination that the corresponding applicant's determination corresponding AMR result line in the GALL Report is not applicable to BVPS.

applicable In LRA LRA Table 3.1.1, item 52, the applicant states that the corresponding Table 3.1.1, corresponding AMR result line in thethe GALL Report is not applicable because in BVPS (1) the associated associated bolting is not subject to prolonged or frequent frequent wetting, (2) the materials materials A325 or A490 common bolts common to high strength bolts are not found in any Reactor Vessel, Vessel Internals, Internals, or Reactor Reactor Coolant System mechanical closure bolting, and (3) (3) BVPS does does not use molybdenum molybdenum or disulfate disulfate thread lubricants. The staff staff reviewed the documentation supporting the applicant's documentation supporting applicant's AMR evaluation evaluation and confirmed thethe applicant's claims for the bolting bolting and bolting environmental conditions. Therefore, the staff staff agrees with the applicant's determination determination that the corresponding corresponding AMR AMR result line in the GALL Report is not applicable to BVPS.

In LRA Table 3.1.1, 3.1.1, item 53, the applicant applicant states that the corresponding AMR result line in the the applicable because GALL Report is not applicable because BVPS does does not have steel components components of the Class 1 Reactor Vessel, Vessel Internals, or Reactor Coolant System exposed to closed cycle Reactor cooling cycle cooling water. The staff reviewed reviewed the documentation documentation supporting the applicant's AMR applicant's AMR evaluation and evaluation confirmed the applicant's claim that BVPS does not have steel components of the Class 1 Reactor Vessel, Vessel Internals, or Reactor Reactor Reactor Coolant System exposed to closed cycle cooling cooling water. Therefore, the staff agrees agrees with the applicant's determination determination that the corresponding corresponding AMR result line in the GALL Report is not applicableapplicable to BVPS.

In LRA Table 3.1.1, items 54 and 56, the applicant states that the corresponding Table 3.1.1, corresponding AMR result line line in the GALL Report is not applicable applicable because because BVPS does does not have copper alloy components components in the Class 1 Reactor Reactor Vessel, Vessel Internals, or Reactor Reactor Coolant System. The staff reviewed reviewed the documentation documentation supporting supporting the applicant's AMR evaluation and confirmed the applicant's applicant's claim that BVPS does not have have copper copper alloy components components in the Class 1 Reactor Vessel, Vessel 3-213 3-213

Internals, or Reactor Coolant System. Therefore, Internals, Therefore, the staff agrees with the applicant's applicant's determination determination that the corresponding AMR result line in the GALL applicable to GALL Report is not applicable BVPS.

In LRA Table 3.1.1, 3.1.1, item 59, the applicant applicant states that the corresponding corresponding AMR result line in the the GALL applicable because GALL Report is not applicable because BVPS addresses generator addresses loss of material for steam generator components exposed to secondarysecondary feedwater feedwater steam in items items 3.1.1-16, 3.1.1-32, 3.1.1-32, and 3.1.1-76.

The staff reviewed the documentation documentation supporting the applicant's AMR evaluation evaluation in items items 3.1.1-3.1.1-16, 3.1.1-32, and 3.1.1-76, and no BVPS AMR line items roll up to this item. Therefore, the staff 16,3.1.1-32, staff agrees with the applicant's applicant's determination determination that the corresponding corresponding AMR result line in the GALL Report applicable to BVPS.

Report is not applicable In LRA Table 3.1.1, 3.1.1, item 62, the applicant states that the corresponding AMR result line in the the GALL GALL Report is not applicable applicable because because no BVPS AMR AMR line items roll up to this item.

item. The staff staff reviewed reviewed the documentation documentation supporting the applicant's AMR evaluation and confirmed AMR evaluation confirmed thethe applicant's applicant's claim that cracking of stainless stainless steel components exposed to reactor reactor coolant is addressed addressed in the evaluation evaluation of fatigue or SCC in other line items. Therefore, the staff agreesagrees with the applicant's determination determination that the corresponding corresponding AMR result line in the GALL Report is applicable to BVPS.

not applicable In LRA Table Table 3.1.1, 3.1.1, item 67, the applicant states that the corresponding AMR result line in the the GALL Report Report is not applicable applicable because no BVPS AMR line items roll up to this item. staff item. The staff reviewed the documentation documentation supporting the applicant's AMR AMR evaluation evaluation and confirmed confirmed thethe applicant's claim that cracking cracking of stainless steel or nickel components components or cladding cladding exposed exposed to to reactor coolant coolant is addressed addressed in the evaluation of fatigue or SCC in other line items. Therefore, the staff agrees agrees with the applicant's applicant's determination determination that the corresponding corresponding AMR result line in the the applicable to BVPS.

GALL Report is not applicable In LRA Table 3.1.1, 3.1.1, items 77, the applicant states that the corresponding corresponding AMR result line in the the GALL Report is not applicable applicable because because BVPS does not use phosphatephosphate chemistry. The staffstaff reviewed the documentation documentation supporting the applicant's applicant's AMR evaluation evaluation and confirmed confirmed thethe applicant's applicant's claim that BVPS does not use phosphate chemistry. Therefore, Therefore, the staff agrees agrees with the applicant's determination determination that the corresponding corresponding AMR result line in the GALL Report Report is not applicable applicable to BVPS.

In LRA Table 3.1.1, 3.1.1, items 78, the applicant states that the corresponding corresponding AMR result line in the the applicable because GALL Report is not applicable because BVPS steam steam generators have tube support plates support plates instead instead of lattice lattice bars.

The staff reviewed the documentation documentation supporting the applicant's AMR evaluation evaluation and confirmed the applicant's claim that BVPS steam generators have have tube support plates instead of lattice lattice bars. Therefore, the staff agrees agrees with the applicant's determination that the corresponding applicant's determination corresponding AMR AMR result line in the GALL Report Report is not applicable applicable to BVPS.

In LRA Table 3.1.1, 3.1.1, items 82, the applicant states that the corresponding corresponding AMR result line in the the GALL GALL Report is not applicable applicable because the BVPS steam generator generator primary side divider plate is fabricated fabricated from nickel-alloy nickel-alloy and not stainless steel. The staff reviewed the documentation documentation supporting supporting the applicant's applicant's AMR evaluation evaluation and confirmed confirmed the applicant's applicant's claim that BVPS steam generator generator primary side divider plate is fabricated from nickel-alloy. Therefore, the staff agrees agrees 3-214 3-214

with the applicant's determination that the corresponding applicant's determination corresponding AMR result line in the GALL Report is not applicable to BVPS.

In LRA Table 3.1.1, 3.1.1, items 87, the applicant states that the corresponding corresponding AMR result line in the the GALL Report GALL Report is not applicable because components within the scope because BVPS has no components scope of license license renewal in concrete concrete in the Reactor Reactor Vessel, Internals, or Reactor Coolant Coolant Systems. The staff staff reviewed reviewed the documentation documentation supporting the applicant's applicant's AMR evaluation and confirmed confirmed the the applicant's claim that BVPS has no components withinthe applicant's within the scope of license license renewal in concrete concrete in the Reactor Vessel, Internals, or Reactor Coolant Coolant Systems. Therefore, the staff agrees with the applicant's determination determination that the corresponding corresponding AMR result line in the GALL Report is not applicable to BVPS.

applicable 3.1.2.1.2 Aging Management Management of Loss of Fracture Toughness Toughness due to Thermal Aging in CASS CASS Reactor Reactor Vessel Internal (RVI) (RVI) Components Components In the applicant's applicant's letter of July 21, 2008, the applicant amended July 21, amended its AMRs in LRA Table 3.1.2-2 3.1.2-2 that pertain to the management management of loss of fracture toughness due to thermal aging embrittlement embrittlement and neutron irradiation embrittlement neutron irradiation embrittlement of its cast austenitic stainless steel (CASS) reactor reactor vessel internal (RVI)

(RVI) components. In this amendment amendment of the LRA, the applicant applicant changed is basis for for managing loss of fracture managing fracture toughness due to thermal embrittlement in the CASS RVI thermal aging embrittlement components from AMP B.2.40, "Thermal Aging and Neutron Irradiation Irradiation Embrittlement Embrittlement of Cast Austenitic Austenitic Stainless Stainless Steel (CASS) Program," to the applicant's managing the applicant's commitments for managing the aging aging effects attributed attributed to RVI components, components, as provided in Commitment No. 18 of UFSAR UFSAR Supplement Table A.4-1 for Unit 1 and Commitment No. 20 of UFSAR Supplement UFSAR Supplement Table A.5-1 for Unit 2.

The corresponding corresponding AMRs in the GALL Report that relate to these AMR items are AMR item 80 80 in Table Table 1 of the GALL Report, RevisionRevision 1, Volume 1 (GALL(GALL1)1) and AMR items IV.B2-21 and IV. B2-37 in Table IV.B2-37 Table IV.B2 of the GALLGALL Report, Revision Revision 1, Volume 2 (GALL2),

(GALL2), as applicable applicable to management of loss of fracture toughness due to thermal aging embrittlement the management embrittlement in CASS CASS Westinghouse-designed RVI upper Westinghouse-designed upper support support columns columns and lower support castings and lower lower support plate columns. These GALL1 GALL 1 and GALL2 AMR items identify that the environment that environment can induce induce loss of fracture fracture toughness toughness of these CASS components components as a result of thermal aging embrittlement and neutron irradiation embrittlement irradiation embrittlement embrittlement is the borated reactor coolantcoolant at an elevated elevated temperature in excess of 250°C (i.e.,

temperature (i.e., >482°F), and as exposed exposed to an integrated integrated neutron fluxflux (i.e., neutron (i.e., neutron fluence).

In these AMRs, the staff recommends that a program program corresponding corresponding to GALL AMP XI.M13, XI.M13, "Thermal Aging and Neutron Irradiation Embrittlement Irradiation Embrittlement of Cast Austenitic StainlessStainless Steel (CASS)" be credited for aging management management of loss of fracture toughness toughness in these CASS CASS components.

The staff noted noted that the applicant's applicant's amendment amendment of these stated AMRs in LRA Table 3.1.2-2 changed the aging management management basis in the AMRs AMRs from being consistent consistent with GALL GALL AMR items items IV.B2-21 IV.B2-21 and IV.B2-37 IV.B2-37 to being consistent consistent with the recommendations recommendations in these GALL AMR GALL AMR itemsitems except for the fact that the commitments commitments in Commitment No. 18 of UFSAR Supplement Supplement Commitment No. 20 of UFSAR Supplement Table A.4-1 for Unit 1 and Commitment Supplement Table A.5-1 for Unit 2 are now beingbeing credited credited as the basis basis for aging management management in lieu of an AMP corresponding corresponding to 3-215 3-215

GALL GALL AMP XI.M1 XI.M13, 3, "Thermal Aging and Neutron Irradiation Irradiation Embrittlement Embrittlement of Cast Austenitic Austenitic Stainless Stainless Steel (CASS)."

In the 2005 update of the SRP-LRSRP-LR and the GALL GALL Report, the NRC NRC took a recommended recommended position that aging management management of PWR PWR vessel internals needs to be done done on a consistent basis among among licensed licensed PWRs in the U.S. to account account for the fact that not all of the PWR RVI components are ASME Code Class and to account for the fact that additional additional aging management measures management necessary for some of the non-ASME measures may be necessary non-ASME Code Class PWR PWR RVI RVI components. Hence, Hence, the staff updated updated its aging management management basis in the AMRs for PWR PWR RVI components in the GALL components GALL Report through the following recommendedrecommended commitment commitment that was was recommended to be adopted recommended UFSAR Supplements adopted in the UFSAR Supplements for PWR LRAs:

"(1)

"( 1) participate in the industry programs for investigating investigating and managing managing agingaging effects effects on reactor internals; internals; (2) evaluate and implement implement the results of the industry programs as applicable to the reactor internals; internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended extended operation, operation, submit an inspection inspection plan for reactor internals internals to the NRC for review and approval."

Thus, for current Westinghouse-designed Westinghouse-designed PWR LRAs pending staff approval approval (including that for for BVPS Units 1 and 2), the staffs staffs AMR basis for managing managing the aging effects attributed to Westinghouse-designed Westinghouse-designed (as well as to Babcock Babcock and Wilcox-designed Wilcox-designed and Combustion Engineering-designed)

Engineering-designed) PWR RVI components components were amended to state:

"The AMP column column was changed to delete referencereference to XI.M16 (AMP M16 was was also deleted deleted from the GALLGALL report) and instead require a commitmentcommitment in the the FSAR Supplement to apply industry industry programs programs to be developed developed in the future for proper management management of reactor internals. Also, added to the further evaluation evaluation column the requirement requirement for the licensee licensee commitment to be confirmed."

The staff noted that the commitment that is recommendedrecommended by the staff includes a provision for PWR applicants applicants to submit an inspection inspection plan for their RVI components that is based on the the augmented inspection industry's augmented recommendations for PWR RVI components to the inspection program recommendations the NRC for review and approvalapproval at least two years prior to entering the period of extended operation. The staff verified that the applicant operation. applicant includes the applicable applicable commitment commitment for the RVI components components in Commitment Commitment No. 18 of LRA UFSAR Supplement Supplement Table A.4-1 A.4-1 for BVPS Unit 1 and in Commitment Commitment No. 20 of LRA UFSAR Supplement Supplement Table A.5-1 for BVPS Unit 2.

The staff also noted that the applicant's amended amended basis to credit the commitments commitments for managingmanaging the aging effects for the BVPS RVI components components (including the management management loss of fracture fracture toughness toughness in the CASS RVI componentscomponents as a result of thermal aging embrittlement embrittlement and neutron irradiation embrittlement) conformance with the staffs recommended embrittlement) is in conformance recommended commitment for RVI components as given components given in the applicable applicable AMRs of GALL2 Table Table IV.B2. As aa result of this review and the bases stated above, the staff finds that the applicant's amended and alternate basis for applicant's amended managing loss of fracture toughness managing toughness in the CASS RVI components as a result of thermal aging aging embrittlement, and neutron neutron irradiation embrittlement is embrittlement acceptableacceptable because it is in conformance conformance with staffs recommendation in GALL2 that a commitment commitment be placed on the LRA to manage manage thethe aging effects that are applicable applicable to the BVPS RVI components.

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Conclusion.

Conclusion. The staff evaluated evaluated the applicant's claim of consistency consistency with the GALL Report. The The staff also reviewed information information pertaining to the applicant's applicant's consideration of recent operating operating experience and proposals experience proposals for managing managing aging effects. On the basis of its review, the staff staff concludes that the AMRAMR results, which the applicant applicant claimed to be consistent with the GALL Report, are indeed indeed consistent consistent with its AMRs. Therefore, the staff concludes concludes that the applicant demonstrated that the effects of aging has demonstrated aging for these components will be adequately adequately managed so that their intended intended function(s) will be maintained maintained consistent with the CLB during the period of required by 10 CFR 54.21(a)(3).

extended operation, as required 54.21 (a)(3).

3.1.2.2 AMR AMR Results Consistent Consistent with the GALL GALL Report Report for for Which Further FurtherEvaluation Evaluation is Recommended Recommended In LRA Section 3.1.2.2, 3.1.2.2, the applicant further evaluates evaluates aging aging management, as recommended recommended by by the GALL Report, for the reactor reactor vessel, reactor reactor vessel internals, and RCS components and provides information concerning how it will manage manage the following aging effects:

• cumulative cumulative fatigue damage damage

" loss of material material due to general, general, pitting, and crevice corrosion ,

" loss of fracture toughness due to neutron neutron irradiation embrittlement irradiation embrittlement

• cracking cracking due to stress corrosion corrosion cracking (SCC) and intergranular intergranular stress corrosion corrosion cracking cracking (IGSCC)

• crack growth due to cyclic loading loading

• loss of fracture toughness due irradiation embrittlement due to neutron irradiation embrittlement and void swelling swelling

• cracking due to SCC

• cracking due to cyclic loading loading

• loss of preload due to stress relaxation relaxation

• loss of material due to erosion

• cracking due to flow-induced flow-induced vibration vibration

• cracking due to SCC and irradiation-assisted (IASCC) irradiation-assisted SCC (IASCC)

• cracking due due to primary water SCC

• wall thinning due to flow-accelerated flow-accelerated corrosion corrosion

• changes in dimensions changes dimensions due to void swelling swelling

• cracking due to SCC and primary water SCC

• cracking due due to SCC, primary primary water irradiation-assisted SCC water SCC, and irradiation-assisted

• QA for aging management management of nonsafety-related nonsafety-related components components For component groups groups evaluated in the GALL Report, for which the applicant claimed consistency with the report and for which the report recommends conSistency recommends further evaluation, staff evaluation, the staff audited and reviewed the applicant's applicant's evaluation evaluation to determine whether itit adequately adequately addressed the issues further evaluated. applicant's further evaluations evaluated. In addition, the staff reviewed the applicant's evaluations 3-217 3-217

against against the the criteria contained contained in SRP-LR SRP-LR Section Section 3.1.2.2.The 3.1.2.2.The staffs staff's review review of the the applicant's applicant's further evaluation further evaluation follows.

follows.

3.1.2.2.1 3.1.2.2.1 Cumulative Cumulative Fatigue DamageDamage LRA Section Section 3.1.2.2.1 3.1.2.2.1 states that fatigue fatigue is a TLAA, as defined defined in 10 CFRCFR 54.3. Applicants Applicants must evaluate evaluate TLAAs in accordance with in accordance with 10 10 CFR CFR 54.21 (c)(1).

54.21(c)(1).

In LRA LRA Table Table 3.1.1, 3.1.1, item 1, the the applicant applicant states states that thethe AMR AMR result line line in the GALL Report Report is not used used because because BVPS has has a Westinghouse Westinghouse reactor reactor vessel and and does not havehave aa pressure pressure vessel support vessel support skirt.

The reviewed the documentation The staff reviewed documentation supporting the applicant's applicant's AMR evaluation evaluation and confirmed confirmed that BVPS BVPS does does not have have a pressure pressure vessel support support skirt. On the basis basis that BVPS does does not have a pressure pressure vessel support skirt, the staff agreesagrees with the applicant's applicant's determination determination that thethe AMR AMR result lineline in the GALL Report Report is not applicable applicable to BVPS.

In LRA LRA Table Table 3.1.1, 3.1.1, items 2, 3, and 4, the applicant applicant states that the AMR result lines are not applicable.

The staff reviewed reviewed the corresponding corresponding AMR AMR result lines in the SRP-LR SRP-LR and noted that they apply apply boiling water reactors (BWRs).

only to bOiling (BWRs). On this basis, the staff agrees with the applicant's applicant's determination that LRA Table 3.1.1, determination 3.1.1, items items 2, 3, and 4, are not applicable, because BVPS is aa PWR. .

The staff noted noted that LRA Table 3.1.1,items 3.1.1,items 5 through 10, are AMR result lines with an aging effect of cumulative fatigue. SER Section 4.3 documents the staff's review of the applicant's applicant's evaluation of this TLAA.

evaluation The GALL GALL report for LRA Table 3.1.1 Item #5 #5 references GALL AMR Item IV.B1-14, IV.B2-31, IV.B2-31, IV.B3-24 and IV.B4-37, which recommends IV.B3-24 recommends that this is a TLAA and is evaluated accordance evaluated in accordance with 10 CFR 54.21(c) to manage cumulative fatigue damage damage in the Reactor Coolant System.

The staff verified that only core baffle/former assembly assembly components, core barrel components, instrumental support structure components, lower internal assembly components, upper instrumental upper internal assembly components and RCCA guide tube assembly components that align to GALL AMR AMR Internals that are fabricated IV.B2-31 for the Reactor Vessel Internals nickel-alloy fabricated from stainless steel, nickel-alloy and cast austenitic stainless steel materials are applicable to BVPS.

The GALL report for LRA Table 3.1.1 Item #6 references GALL AMR Item IV.D1-21 and IV.D2-15, which recommends that this is a TLAA and is evaluated evaluated in accordance with 10 CFR 54.21(c) to manage cumulative cumulative fatigue damage damage in the Reactor Coolant System. The staff Reactor staff verified that only steam generator components that align to GALL AMR IV.D1-21 for the Reactor Reactor Coolant System that are fabricated from nickel-alloy materials are applicable to BVPS.

The GALL report for LRA Table 3.1.1 Item #7 #7 references GALL AMR Item IV.C2-23, IV.C2-10, IV.D1-1 1, IV.D2-10 and IV.A2-4, which recommends that this is a TLAA and is evaluated in IV.D1-11, in accordance accordance with 10 CFR 54.21(c) to manage cumulative fatigue damage in the Reactor Coolant 3-218 3-218

System. TheThe staff verified that only only bolting, closure head, pressurizer pressurizer components components and and steam components that align to GALL AMR IV.A2-4, IV.C2-10 and IV.D1-11 generator components IV.D1-1 1 for the Reactor Reactor System that are Coolant System are fabricated from steel, steel, stainless steel, steel with nickel-alloy nickel-alloy cladding cladding and high-strength low-alloy low-alloy steel materials materials are applicable to BVPS.

The GALL report for LRA Table 3.1.1 Item #8 references GALL AMR Item IV.C2-25, which recommends that this is a TLAA and is evaluated in accordance accordance with 10 10 CFR 54.21(c) to manage cumulative fatigue damage in the Reactor Coolant Coolant System. The staff verified that only only hose, hydraulic isolator, orifices, piping, pressurizer flexible hose, pressurizer components, reactor coolant pump components, thermal sleeve and tubing that align to GALL AMR IV.C2-25 for the Reactor Coolant System that are fabricated from steel with stainless steel cladding, stainless steel, nickel-alloy and cast austenitic stainless steel materials materials are applicable to BVPS. BVPS.

The GALL report for LRA Table 3.1.1 Item #9 #9 references references GALL AMR Item IV.A2-21, IV.A2-21, which recommends that this is a TLAA and is evaluated in accordance recommends accordance with 10 CFR 54.21(c) to manage cumulative fatigue damage damage in the Reactor Reactor Coolant System. The staff verified that only bottom-mounted guide tube components, closure head and flange, core support pad and guide bottom-mounted guide lug, head penetrations, nozzles, penetrations and vessel shell components that align to GALL AMR IV.A2-21 for the Residual Heat Removal, Reactor Core Isolation Cooling and High High Pressure Coolant Injection Pressure Injection System that are fabricated from steel with stainless steel cladding, stainless steel, nickel-alloy, cast austenitic stainless steel materials and SA508-CI SA508-CI 2 forgings forgings clad with stainless steel using a high-heat-input high-heat-input welding process applicable to process materials are applicable BVPS.

The GALL report for LRA Table 3.1.1 Item #10 #10 references references GALL AMR AMR Item IV.D1-8 and IV. D2-3, IV.D2-3, which recommends recommends that this is a TLAA and is evaluated accordance with 10 CFR evaluated in accordance 54.21(c) to manage manage cumulative cumulative fatigue damage damage in the ReactorReactor Coolant System. The staff staff verified that only steam generator generator components that align to GALL AMR IV.D1-8 for the Reactor Reactor Coolant System System that are fabricated from stainless steel materials are applicable steel materials applicable to BVPS.

3.1.2.2.2 Loss of Material due to Pitting and Crevice Corrosion Once Through PWR SG Shell Assemblies and BWR Reactor Vessel Penetration BWR Reactor Penetration and RCIC RCIC Components. SRP-LR Section Section 3.1.2.2.2.1 states that loss of material due to general general corrosion, corrosion, pitting corrosion, and crevice corrosion may may occur in steel PWR steam generator generator shell assemblies assemblies that are exposed to feedwater feedwater or to steam steam and in steel BWR top head enclosure head enclosure (without cladding) cladding) top head head nozzles (vent, top head head spray) or reactor core isolation cooling isolation cooling (RCIC), and spare that are exposedexposed to the reactor coolant. The The SRP-LR SRP-LR Section Section states states that the the existing program existing program relies on control control of reactor reactor water chemistry to mitigate corrosion, chemistry mitigate corrosion, but qualifies qualifies this statement statement by stating that control control of water chemistry chemistry does not precludepreclude loss of material material due due to pitting and crevice corrosion at locations locations of stagnant flow conditions.

conditions. The SRP-LR SRP-LR Section therefore recommends that the effectiveness therefore recommends effectiveness of the chemistry chemistry control program be be verified verified to ensure ensure that corrosion corrosion is not occurring.

occurring. The The SRP-LR Section Section states that the GALL Report recommends further Report recommends further evaluation evaluation of programs programs to verifyverify the effectiveness effectiveness of the chemistry chemistry control program, control program, and that a one-time one-time inspection of select components select components at susceptible susceptible locations locations is an acceptable method an acceptable method to determine whether determine whether an aging aging effect is not occurring not occurring oror an aging aging effect effect is progressing progressing very slowly such that the component's that the component's intendedintended function will be maintained maintained during during the period of extended extended operation.

operation.

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For the BWR components referred to above, the GALL BWR components GALL AMRs referred to by this SRP-LR SRP-LR Section are AMR item 11 in Table 1 of the GALL Report, Revision 1, Volume Volume 2 (GALL1)

(GALL 1) and AMR item IV.A1-11 IV.A1-11 in Table IV.A1 of the GALL Report, Revision Revision 1, Volume 2 (GALL2).

(GALL2). The The applicant applicant identified that the BVPS units are PWR-designed PWR-designed and guidance guidance for these BWR BWR components components are not applicable applicable to the BVPS LRA.

Thus, based based on this review, the staff concludes that the applicant has provided an acceptable acceptable basis for concluding the guidance guidance for BWR components in SRP-LR BWR components SRP-LR Section Section 3.1.2.2.2, ItemItem (1) and the referenced referenced GALL GALL AMRsAMRs is not applicable to the BVPS LRA because because thethe recommendations in these NRC guidelines are only applicable to BWR recommendations BWR components and because the because the BVPS BVPS units are Westinghouse-designed Westinghouse-designed PWR reactors.

With regard to aging management management of loss of material material in the PWR assemblies under PWR SG shell assemblies exposure exposure to either either feedwater or steam, the GALL AMRs referred referred to by this SRP-LR SRP-LR Section Section are are AMR AMR item 12 in Table 1 of the GALL Report, Revision Revision 1, Volume 2 (GALL(GALL1) 1) and AMR item item IV.D2-8 in Table IV.02 IV.02-8 IV.D2 of the GALL Report, RevisionRevision 1, Volume 2 (GALL2), as applicable to the the evaluation evaluation of loss of material due material due to general, pitting, and crevice crevice corrosion in once-through once-through SGs.

The applicant identified identified that the BVPS units are Westinghouse-designed Westinghouse-designed PWR with recirculating recirculating SGs. The applicant applicant therefore stated that the guidance guidance in SRP-LR SRP-LR Section 3.1.2.2.2, Item (1) and in AMR item 12 of TableTable 1 of GALL GALL11 and AMR item IV.D2-8 IV.02-8 of GALL2 are not applicable applicable to thethe because the BVPS SGs are not once-through BVPS LRA because once-through SG designs. Based on this review, the the staff concludes that the applicant applicant has provided an acceptable acceptable basis for concluding the guidanceguidance for PWR SG components in SRP-LR SRP-LR Section 3.1.2.2.2, Item (1) and the referenced referenced GALL AMRs GALL AMRs is not applicable applicable to the BVPS LRA because the recommendations recommendations in these NRC guidelines are are applicable to PWR with once-through only applicable once-through SG designs and because because the SGs at BVPS are Westinghouse-design Westinghouse-design recirculating recirculating SGs.

The staff has verified that the applicant includes its AMRs on loss of material applicant includes material due to general, pitting, and crevice corrosion of its steel SG components under under exposure exposure to the reactor coolant in AMR 3.1.1-83 3.1.1-83 of LRA Table 3.1.1, 3.1.1, and in the AMRs for steam generator generator components components in LRA Table 3.1.2-3 that align to LRA AMR 3.1.1-83. The staff has evaluated these AMRs in SER 3.1.2.1.

Section 3.1.2.1.

BWR Isolation Isolation Condenser Condenser Components.

Components. SRP-LR Section 3.1.2.2.2, Item (2) states that loss of material due to pitting and crevice crevice corrosion could occur in stainless steel BWR isolation isolation condenser components exposed condenser exposed to reactor coolant, and that loss of materialmaterial due to general, pitting, and crevice crevice corrosion corrosion could occur in steel BWR isolation condenser components BWR isolation components under under exposure to the reactor reactor coolant. The SRP-LRSRP-LR Section states states that the existing program program relies on control of reactor water chemistry to mitigate corrosion, but qualifies this statement by by identifying that control of water chemistry does identifying does not preclude preclude loss of material due to pitting and corrosion from occurring at locations crevice corrosion locations of stagnant flow conditions. Therefore, the SPR-LR SPR-LR Section recommends recommends that the effectiveness of the chemistry chemistry control program program should be verified to ensure ensure that corrosion is not occurring, occurring, and states that the GALL Report recommends further Report recommends further evaluation of programs to verify the effectiveness effectiveness of the chemistry chemistry control program. The SRP-LR Section states that a one-time inspection inspection of select components at susceptible locations is an an acceptable method acceptable method to determine determine whether an aging effect is not occurring or an aging aging effect effect is progressing very slowly such that the component's intended function will be maintained maintained during during the period period of extended extended operation. .

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For the BWR BWR isolation condenser components referred condenser components referred to above, the GALL GALL AMRs referred to by AMRs referred this SRP-LR Section Section are AMR item 13 in Table 1 of the GALL Report, Revision Revision 1, Volume 2 (GALL (GALL1) 1) and AMR item IV.C1-6 in Table IV.C1 IV.C1 of the GALL Report, Revision 1, Volume 2 (GALL2).

(GALL2). The applicant applicant identified that the BVPS units are PWR-designed PWR-designed and guidanceguidance forfor these BWR components applicable to the BVPS LRA. Thus, based on this review, the components are not applicable the staff concludes that the applicant staff applicant has provided provided an acceptable acceptable basis for concluding the guidanceguidance for BWR components in SRP-LR SRP-LR Section 3.1.2.2.2, Item (2) and the referencedreferenced GALL AMRs AMRs is not applicable applicable to the BVPS LRA recommendations in these NRC guidelines LRA because the recommendations guidelines are applicable to BWR components only applicable components and because the BVPS units are Westinghouse-designed Westinghouse-designed PWR reactors.

BWR Reactor Vessel Components Exposed to the Reactor Reactor Coolant. SPR-LR Section Section 3.1.2.2.2, Item (3)

(3) states that loss of material material due to pitting and crevice crevice corrosion could occur in BWR BWR reactor vessel (RV) flanges, nozzles, penetrations, pressure housings, safe ends, and vessel vessel shells, heads and welds that are made of stainless steel, nickel-alloy, or steel with internal stainless steel or nickel-alloy nickel-alloy cladding underunder exposure to reactor coolant. The SRP-LR Section states that the existing existing program relies on control of reactor water chemistry water chemistry to mitigate corrosion, but qualifies statement by identifying that control of qualifies this statement water water chemistry chemistry does does not preclude preclude loss of material material due to pitting and crevice corrosion from occurring at locations occurring stagnant flow conditions. Therefore, the SPR-LR locations of stagnant SPR-LR Section recommends recommends that the effectiveness effectiveness of the chemistry program should be verified to ensure that chemistry control program corrosion is not occurring, corrosion occurring, and states that the GALL Report recommends recommends further evaluation evaluation of programs programs to verify the effectiveness effectiveness of the chemistry control control program. The SRP-LR SRP-LR Section states that a one-time one-time inspection of select components components at susceptible susceptible locations is an acceptable method to determine whether an aging effect is not occurring acceptable occurring or an agingaging effect is progressing very slowly such that the component's progressing component's intended intended function will be maintained maintained during during the period period of extended extended operation.

operation.

For the BWR RV components components referred referred to above, the GALL AMRs AMRs referred to by this SRP-LR Section Section are AMR item 14 in Table Table 1 of the GALL Report, Revision Revision 1, Volume (GALL1)

Volume 2 (GALL 1) and AMR item IV.A1-8 IV.A1-8 in Table IV.A1 of the GALL Report, Revision 1, Volume 2 (GALL2). (GALL2). TheThe applicant identified identified that the BVPS units are PWR-designed PWR-designed and guidanceguidance for these BWR BWR components are not applicable components applicable to the BVPS LRA. Thus, based based on this review, the staff staff concludes that the applicant has provided concludes acceptable basis for concluding the guidance provided an acceptable guidance for BWR BWR components components in SRP-LRSRP-LR Section 3.1.2.2.2, Item Item (1) and the referenced referenced GALL AMRs is not applicable applicable to the BVPS LRA because because the recommendations recommendations in these NRC guidelines are only only applicable applicable to BWR RV components components and because because the BVPS units are Westinghouse-designed Westinghouse-designed PWR reactors.

reactors.

Generator Shell and Transition Cone. SRP-LR PWR Steam Generator SRP-LR Section 3.1.2.2.2.4 states that loss loss of material material due to general, general, crevice, and pitting corrosion could occur in the steam generator upper and lower lower shell and transition cone exposed to secondarysecondary feedwater and steam. The The existing program relied on control of water chemistry to mitigate corrosion corrosion and inservice inservice inspections to detect loss of material. The extent inspections extent and and schedule of the existing steam generator generator inspections are designed designed to ensure that flaws cannot attain a depth sufficient depth sufficient to threaten the the integrity of the welds. However, according according to NRC Information Notice (IN) (IN) 90-04, "Cracking of the Upper Shell-to-Transition Cone Girth Welds in Steam Upper Shell-to-Transition Steam Generators,"

Generators," the program program may not be be sufficient sufficient to detect pitting and crevice corrosion and pitting corrosion. NUREG-1801 NUREG-1801 clarifies that this issue is limited Westinghouse Model 44 and 51 Steam Generators limited to Westinghouse Generators where a high-stress high-stress 3-221

region exists region exists at at the shell-to-transition shell-to-transition conecone weld. In that case, the GALL Report the GALL Report recommends recommends augmented inspections augmented inspections to manage this to manage this aging aging effect.

effect.

The The staff noted inspections proposed by the applicant additional inspections noted that the additional applicant the ASME Section XI ASME Section Inservice Inspection, Subsections Inservice Inspection, Subsections IWB, IWB, IWC, and IWD Program Program for Class 2 components. The components. The also noted staff also noted that the BVPS Unit that the generators (SGs) have Unit 1 steam generators have been replaced with been replaced with Model generators and are therefore 54F generators therefore the ultrasonic testing the ultrasonic (UT) examination testing (UT) detection capability examination detection topic raised topic raised in SRP-LR SRP-LR Section Section 3.1.2.2.2.4 3.1.2.2.2.4 is not applicable applicable to the BVPS Unit Unit 1 SGs. The staffstaff has verified that, in LRA LRA Table 3.1.2-3, the applicant Table 3.1.2-3, aligned its AMR applicant has aligned material in AMR on loss of material the steel the steel Model Model 54F SG SG cones cones and shells for for BVPS BVPS UnitUnit 1 to GALL GALL AMR IV.D1-12, and AMR IV.D1-12, and that the the applicant credits both applicant credits both its Water Water Chemistry Program Chemistry Program and its and its ASME Section Section XI Inservice Inservice Subsections IWB, Inspection, Subsections Inspection, IWB, IWC, and IWD Program to manage IWD Program manage loss of of material material in the BVPS BVPS Unit 1 SG cones and Unit and shells. TheyThey confirmed confirmed that the the applicant's applicant's AMR AMR for the SG SG cones cones and and consistent with the staffs shells is consistent staff's AMR basis in GALL AMR IV.D1-12 IV.D1-12 for PWR recirculating PWR recirculating SGs that are not Westinghouse Westinghouse Model 44 or 51 SGs (i.e., (Le., the applicable aging the applicable effect of loss of aging effect material due to general, pitting, and crevice material applicable but does not require crevice corrosion is applicable require any any recommendations of SRP-LR evaluation under the recommendations further evaluation further Section 3.1.2.2.2.4). Thus, the staff SRP-LR Section staff concludes provided an acceptable applicant has provided concludes that the applicant acceptable basis for concluding concluding that the topic topic SRP-LR Section 3.1.2.2.2.4 raised in SRP-LR applicable to the applicant's AMR 3.1.2.2.2.4 is not applicable AMR on loss of materials in the BVPS Unit 1 SG because materials Westinghouse Model 44 or 51 SG because these SGs are not Westinghouse SG designs. Instead, the staff's evaluation evaluation of the applicant's applicant's AMRAMR on loss material in the BVPS loss of material BVPS Unit 1 SG cones and shells and its basis for managing Unit managing loss of material in the BVPS Unit Unit 1 Model 54F SG shells is given Model Section 3.1.2.1 for AMRs SER Section given in SER consistent with the AMRs that are consistent the GALL Report not requiring further evaluation under the guidance guidance of the SRP-LR.

The staff noted however that the BVPS the Unit 2 steam generators generators are Westinghouse Westinghouse Model 51 SGs and thus, the recommendations recommendations in SRP-LR Section Section 3.1.2.2.2.4 are applicable applicable to thethe BVPS Unit 2 SGs. The staff has confirmed confirmed that, in LRA Table applicant has aligned Table 3.1.2-3, the applicant material in the steel Model 51 SG shells and cones for BVPS Unit 2 to GALL its AMR on loss of material AMR IV.D1-12, and that the applicant credits both its Water Water Chemistry Program Program and its ASME ASME Subsections IWB, IWC, and IWD Program to manage Inspection, Subsections Xl Inservice Inspection, Section Xllnservice manage loss of material in the BVPS Unit 1 SG cones and shells. The staff confirmed that the applicant's material AMR applicant's AMR for the SG cones and shells is consistent with the staffs staff's AMR basis in GALL AMR IV.D1-12 for AMR IV.D1-12 Westinghouse Model 44 or 51 SGs, and that in LRA Section 3.1.2.2.2.4, the applicant provided discussion of its basis to manage its further evaluation discussion material due to pitting and crevice manage loss of material crevice corrosion in the BVPS Unit 2 cones and shells. The staff noted that in this section, the applicant applicant made the following statement regarding its evaluation evaluation for the BVPS Unit 2 SG cones and shells:

Additional inspection requirements Additional inspection incorporated into the ASME requirements have been incorporated ASME Section XI Inservice Inservice Inspection, Subsections Subsections IWB, IWC, and IWD Program (Section B.2.2) to detect generalgeneral and pitting corrosion and the resulting corrosion-fatigue cracking in the Unit 2 Model 51 steam generators.

guidance in SRP~LR staffs guidance The staff's SRP-LR Section 3.1.2.2.2.4 references NRC NRC Information Notice (IN) (IN) 90-04 which discussed impacts of abnormal geometries in Westinghouse Model 44 and 51 shell-to-transition cone welds on UT detection capability. In this IN, SG shell-to-transition IN, the staff indicated that, for ultrasonic tests (UT) performed on these welds. background noise welds, the intensity of background signals (reflectors) resulting from the weld geometries could be high and could potentially potentially mask any UT reflectors resulting from actual flaws in the welds (e.g.,

(e.g .. pits or cracks). The The 3-222

staff therefore therefore recommended, recommended, for these SG designs, that applicants develop develop methods and procedures that would result in a lowering procedures lowering of the background background noise levels resulting from the the welds geometries. The IN IN listed adjustment adjustment of the gain of the UT detection equipment as an detection equipment example of a method that could be used to reduce the noise levels resulting from the weld weld geometry.

The staff noted that the applicant applicant did address the staff's recommendation recommendation in SRP-LR SRP-LR to develop develop additional additional inspection inspection procedures Westinghouse Model 44 or 51 SG shell-to-procedures to inspection of Westinghouse transition cone welds. In its LRA update update dated dated December 19, 2008, the applicant amended amended LRA LRA Section 3.1.2.2.2.4 to clarify Section clarify how the additional procedures procedures were were modified modified to address the staff's staff's recommendations in IN 90-04. The staff finds that the amended recommendations amended basis is acceptable acceptable because because thethe applicant has clarified applicant clarified why its current procedures procedures are adequate to manage manage loss of material due due to pitting and crevice corrosion in the BVPS Unit 2 SG cone-to-shell cone-to-shell transition welds consistent consistent with the NRC IN 90-04 guidanceguidance and because applicant used the augmented because the applicant augmented inspection recommended in IN 90-04 to confirm methods recommended confirm the absence of UT geometric reflectorsreflectors that might otherwise otherwise mask indications from actual flaws in these transition transition cone welds.

3.1.2.2.3 Loss of Fracture Fracture Toughness Due to Neutron Irradiation Irradiation Embrittlement Embrittlement The staff reviewed reviewed LRA Section 3.1.2.2.3 against the following criteria in SRP-LR SRP-LR Section 3.1.2.2.3:

(1) LRA Section 3.1.2.2.3 states that neutron irradiation irradiation embrittlement embrittlement is a TLAA, as defined defined in 10 10 CFR 54.3. Applicants must evaluate TLMs TLAAs in accordance accordance withwith 10 CFR 54.21(c)(1).

54.21(c)(1). SER Section 4.2 documents the staff's review of the applicant's applicant's evaluation evaluation of this TLAA.

Section 3.1.2.2.3 3.1.2.2.3 of the Beaver Beaver Valley Valley Power Station Station (BVPS) License License Renewal Application (LRA) management review (AMR) results addressing the loss (LRA) provides aging management loss of reactor reactor vessel (RV)(RV) fracture toughness due to neutron irradiation irradiation embrittlement. The The staff reviewed reviewed LRA Section 3.1.2.2.3 to determine determine whether whether the applicant applicant provided provided sufficient information information to demonstrate demonstrate that the effects of aging due to RV neutron embrittlement will be adequately managed managed so that the intended intended function of the RV will be be maintained maintained consistent consistent with the current current licensing basis for the period of extended operation, as required required by 10 CFR 54.21(a)(3).

54.21(a)(3). The staff verified that LRA LRA Section 3.1.2.2.3 3.1.2.2.3 appropriately appropriately identifies (1) the time-limited aging analyses (TLMs) (TLAAs) associated with RV neutronneutron embrittlement, and (2) (2) the RV Integrity Integrity Aging Management Management Program (AMP)

(AMP) for monitoring monitoring the effects of RV neutron embrittlement. The RV neutron embrittlement embrittlement TLMs are presented TLAAs presented in Section 4.2 of the LRA. The RV Integrity AMP is presented in Appendix Appendix B of the LRA, Section B.2.35. The staff determined determined that thethe applicant's applicant's RV Integrity consistent with NUREG-1 Integrity AMP is consistent NUREG-1801, 801, "Generic Aging Lessons Lessons Learned Report," (GALL)

Learned (GALL) AMP XI.M31, XI.M31, "Reactor Vessel Surveillance."

Surveillance." The staffs staffs evaluation evaluation of the RV neutron embrittlement embrittlement TLMs TLAAs is documented documented in SER Section 4.2.

The staffs evaluation of the RV Integrity AMP is documented in SER Section Section B.2.35.

(2) LRA Section 3.1.2.2.3 3.1.2.2.3 addresses addresses loss of fracture toughness toughness due to neutron irradiation irradiation embrittlement that may occur in the reactor embritllement reactor vessel beltline, shell, nozzle, nozzle, and welds. A materials materials surveillance program monitors surveillance program irradiation embrittlement monitors neutron irradiation embrittlement of the reactor vessel. The safety injection lines connecting connecting to the loops are not exposedexposed to neutron flux, 3-223 3-223

and the safety injection nozzles nozzles are not managed managed by the Reactor Vessel Integrity Program. LRA Section B.2.35 presentspresents the results of the evaluation theresults evaluation of the Reactor Vessel Integrity Program for license renewal.

SRP-LR SRP-LR Section 3.1.2.2.3 states that loss of fracture toughness toughness due to neutron neutron irradiation embrittlement may occur in BWR and PWR reactor vessel beltline shell, irradiation embrittlement nozzle, and welds exposed exposed to reactor coolant and neutronneutron flux. A reactor vessel materials surveillance surveillance program monitors monitors neutron irradiation embrittlement neutron irradiation embrittlement of the reactor vessel. Reactor Reactor vessel surveillance surveillance programs are plant-specific, depending on matters plant-specific, depending matters such as the composition composition of limiting materials, availability of surveillance surveillance capsules, and projected fluence levels. In accordance projected accordance with 10 CFR Part 50, Appendix H, H, an applicant is required to submit its proposed proposed withdrawal schedule schedule for approval prior to to implementation. Untested implementation. Untested capsules placed in storage must be maintained capsules placed maintained for future insertion.

insertion. Thus, further staff evaluation evaluation is required for license license renewal. Specific Specific recommendations for an acceptable recommendations acceptable AMP are provided in GALL GALL Report Chapter XI, Section M31.

M31.

3.1.2.2.3.2 of the Beaver Section 3.1.2.2.3.2 Beaver Valley Power Station (BVPS) (BVPS) License Renewal (LRA) provides aging management Application (LRA) management review (AMR) results addressing reactor reactor neutron embrittlement.

vessel (RV) neutron embrittlement. The staff 3.1.2.2.3.2 to staff reviewed LRA Section 3.1.2.2.3.2 to determine whether determine provided sufficient whether the applicant provided sufficient information information to demonstrate demonstrate that the the effects of aging due to RV neutron embrittlement will be adequately neutron embrittlement adequately managed so that the the intended intended function of the RV will be maintained maintained consistent consistent with the current licensing basis basis for the period of extended extended operation, as required by 10 CFR 54.21 (a)(3). The staff 54.21(a)(3). staff verified that LRA Section 3.1.2.2.3.2 3.1.2.2.3.2 appropriately appropriately identifies the RV Integrity AgingAging Management Program (AMP) for monitoring the effects of RV neutron embrittlement.

Management The RV Integrity Integrity AMP is presented presented in Appendix Appendix B of the LRA, Section B.2.35. The staff staff determined determined that the applicant's applicant's RV Integrity Integrity AMP is consistent with NUREG-1801, NUREG-1 801, "Generic Aging Lessons LearnedLearned Report," (GALL)

(GALL) AMP XI.M31, XI.M31, "Reactor Vessel Surveillance."

Surveillance." The staff's staffs evaluation evaluation of the RV Integrity Integrity AMP is documented in SER Section B.2.35.

Section Based Based on the programs programs identified above, the staff concludes that the applicant'sapplicant's programs meet SRP-LR Section 3.1.2.2.3 SRP-LR 3.1.2.2.3 criteria. For those line items that apply to LRA Section 3.1.2.2.3, the the staff determines determines that the LRA is consistent with the GALL Report and that the applicant has GALL Report has demonstrated that the effects of aging will be adequately demonstrated adequately managed managed so that the intended function(s) will be maintained maintained consistent with the CLB during the period period of extended operation, operation, as required by 10 10 CFR 54.21 (a)(3).

54.21(a)(3).

3.1.2.2.4 3.1.2.2.4 Cracking Cracking Due to Stress Corrosion Cracking and IntergranularIntergranular Stress Corrosion Cracking Cracking BWR Reactor Reactor Vessel Top Head Enclosure Flange Leakage Detection Lines. LRA provides the applicant's Section 3.1.2.2.4.1 provides applicant's discussion on whether the recommended recommended guidance guidance and the AMRrecommendations AMR recommendations in GALL AMR IV.A1-10 IV.A1-10 on management management of cracking in BWR BWR RV flange leakage detection lines is applicable applicable to the BVPS LRA. In this Section of the LRA, the the applicant states that SRP-LR Section Section 3.1.2.2.4.1 on cracking cracking of BWR vessel flange leakageleakage detections lines is applicable applicable to BWR BWR plants only.

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SRP-LR Section 3.1.2.2.4.1 identifies cracking due to SCC and IGSCC identifies cracking IGSCC could occur in the the stainless steel and nickel-alloy BWR top head enclosure enclosure vessel flange leak detection detection lines. TheThe SRP-LR SRP-LR Section states that the GALL Report recommends that aa plant-specific Report recommends plant-specific AMP be be evaluated because existing programs may not be capable evaluated because capable of mitigating or detecting detecting cracking cracking due to SCC and IGSCC.

SRP-LR Section 3.1.2.2.4.1 3.1.2.2.4.1 references references AMR Item 19 in Table 1 of the GALL GALL Report, Volume 1 and AMR Item IV.A 1-10 of the GALL Report, Volume 2 on management IV.A1-10 management of cracking cracking due to SCC and IGSCC in stainless steel and nickel-alloy nickel-alloy BWR BWR reactor vessel (RV) (RV) flange leakage leakage detection lines that are exposed exposed to the treated water environment environment of the reactor coolant. The aging aging management management position taken in these GALL-based AMRs is consistent GALL-based AMRs consistent with the staffs staff's position recommendations in SRP-LR and recommendations 3.1.2.2.4.1.

SRP-LR Section 3.1.2.2.4.1.

The staff determined determined that NUREG-1390, NUREG-1 390, Volume 19 identifies the BVPS reactors reactors as as Westinghouse 3-Loop PWRs with dry ambient containments. Based on this review, the staff Westinghouse staff concludes that the recommendations recommendations in SRP-LRSRP-LR Section Section 3.1.2.2.4.2 and in GALLGALL AMR IV.C1-4 IV.C1-4 are not applicable to the BVPS LRA because the staff guidance guidance is applicable BWR BWR isolation isolation Westinghouse-designed PWRs.

condenser components and because the BVPS reactors are Westinghouse-designed BWR BWR Isolation Condenser Condenser Components. LRA Section Section 3.1.2.2.4.2 3.1.2.2.4.2 provides the applicant's applicant's discussion on whether the recommended discussion recommended guidance guidance and the AMR recommendations recommendations in GALL IV.C1-4 on management AMR IV.C1-4 management of cracking due to stress corrosion cracking cracking (SCC) and/or intergranular stress corrosion cracking (IGSCC) intergranular (IGSCC) in stainless steel BWRBWR isolation condenser components components is applicable to the BVPS LRA. In this Section Section of the LRA, the applicant applicant states that SRP-LR Section 3.1.2.2.4.2 3.1.2.2.4.2 on cracking of BWR isolation condenser condenser components is applicable components applicable to BWR plants only.

SRP-LR SRP-LR Section 3.1.2.2.4.2 3.1.2.2.4.2 identifies identifies cracking due to SCC/IGSCC SCCIIGSCC could occur in the stainlessstainless steel BWR isolation condenser condenser components under exposure to the treated water environment of water environment the reactor coolant. The SRP-LR SRP-LR sections states that the GALL Report recommends recommends that a plant-specific AMP be evaluated plant-specific evaluated because because existing programs programs may not be capable capable of mitigating mitigating or detecting cracking due to SCC/IGSCC.

SCCIIGSCC.

SRP-LR 3.1.2.2.4.2 references SRP-LR Section 3.1.2.2.4.2 references AMR Item 20 in Table 1 of the GALL GALL Report, Volume 1 and AMR Item IV.C1-4 IV.C1-4 of the GALL GALL Report, Volume 2 on management management of cracking due to SCC and IGSCC IGSCC in stainless stainless steel BWR BWR isolation condenser condenser components that are exposed to the the treated water environment environment of the reactor coolant. The aging management position taken in aging management these GALL-based GALL-based AMRs is consistent with the staff's position and recommendations recommendations in SRP-LR Section Section 3.1.2.2.4.2.

3.1.2.2.4.2.

The staff determined determined that NUREG-1390, NUREG-1390, Volume 19 19 identifies identifies the BVPS reactors reactors as as Westinghouse Westinghouse 3-Loop PWRs with dry ambient containments. Based on this review, the staff staff concludes concludes that the recommendations recommendations in SRP-LR Section 3.1.2.2.4.2 3.1.2.2.4.2 and in GALL AMR IV.C1-4 IV.C1-4 are not applicable applicable to the BVPS LRA becausebecause the staff guidance guidance is applicable applicable BWR isolation isolation condenser components components and because the BVPS reactors reactors are Westinghouse-designed Westinghouse-designed PWRs.

3.1.2.2.5 Crack Growth Due to Cyclic Loading Loading 3-225

LRA Section Section 3.1.2.2.5 3.1.2.2.5 states states that growth growth ofof intergranular intergranular separations separations (underclad cracks) in (underclad cracks) in the the heat-affected heat-affected zonezone under under austenitic austenitic steel steel cladding is is aa TLAA TLAA as as defined defined inin 10 10 CFR CFR 54.3.

Applicants must Applicants must evaluate evaluate TLAAs TLAAs in in accordance accordance withwith 10 10 CFR CFR 54.21(c)(1).

54.21 (c)( 1). SER SER Section 4.7 4.7 documents documents the staffs review of the applicant's staffs review the applicant's evaluationevaluation of this TLAA.

TLAA.

3.1.2.2.6 3.1.2.2.6 Loss of of Fracture Toughness due to Neutron Fracture Toughness Neutron Irradiation Embrittlement and Void Irradiation Embrittlement Void Swelling Swelling LRA Section LRA Section 3.1.2.2.6 3.1.2.2.6 addresses addresses the applicant's evaluation that on whether applicant's evaluation whether the recommended recommended guidance in SRP-LR guidance SRP-LR Section 3.1.2.2.6, "Loss of Fracture Fracture Toughness Toughness Due Due to Neutron Neutron Irradiation Irradiation Embrittlement and Void Swelling," is applicable Embrittlement applicable to the the BVPS BVPS LRA. In this Section of of the LRA, the LRA, the states that loss applicant states applicant loss of fracture toughness toughness could occur occur in reactor vessel in the reactor vessel internal internal (RVI)

(RVI) components made components made from nickel-alloy stainless steel nickel-alloy or stainless steel (including (including cast austenitic stainless steels) cast austenitic as result of neutron neutron irradiation embrittlement or void swelling.

irradiation embrittlement swelling.

The The applicant states that itit credits its commitments for PWR RVI components applicant states components to manage manage loss of fracture toughness due to neutron irradiation fracture toughness embrittlement or void swelling in the nickel-alloy irradiation embrittlement nickel-alloy components and includes and stainless steel RVI components includes these these commitments Commitment No. 18 commitments in Commitment 18 of Unit 1 UFSAR Supplement Table UFSAR Supplement Table A4-1 andand Commitment Commitment No. No. 20 of Unit 2 UFSAR Supplement Supplement A5-1, as follows:

Table A5-1, (1) applicable to BVPS Unit 1/Unit Participate in the industry programs applicable Participate 1/Unit 2 for investigating and managing investigating managing aging effects on reactor reactor internals; (2) Evaluate and implement the results of the industry applicable to the industry programs as applicable the BVPS Unit 1/Unit 2 reactor internals; and, (3)

(3) Upon completion of these programs, but not less than 24 months months before entering the period period of extended extended operation, submit an inspection inspection plan 1/Unit for the BVPS Unit 1/Unit 2 reactor internals to the NRC for review and approval."

Evaluation. SRP-LR Section 3.1.2.2.6 states that fracture toughness due to neutron Staff Evaluation. neutron irradiation embrittlement and void swelling could occur in stainless steel and nickel-alloy reactor vessel internals exposed to reactor coolant and neutron components exposed internals components neutron flux. The SRP-LR Section states that the GALL Report recommends no further aging management management review ifif the the applicant provides a commitment in the FSAR Supplement Supplement to (1 participate in the industry (1)) participate investigating and managing aging effects programs for investigating effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for reactor internals internals to the NRC for review and approval.

approval.

applicable nickel-alloy and stainless steel RVI components, SRP-LR Section 3.1.2.2.6 For applicable 3.1.2.2.6 invokes AMR Item 22 in Table 11 of the GALL Report, Volume 1, and specific AMR items in the the GALL Report Volume 2, as applicable applicable to the management of loss of fracture toughness due to Westinghouse-designed RVI neutron irradiation embrittlement or void swelling in the following Westinghouse-designed components:

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• • plates plates in the baffle and former assemblies (GALL AMR IV.B2-3) assemblies (GALL IV. B2-3)

• • bolts and screws screws in the baffle baffle and former assemblies (GALL AMR IV.B2-6) IV.B2-6)

• core barrel (CB), CB flange, CB outlet nozzles, and thermal shield shield (GALL (GALL AMR IV.B2-9)

• • fuel alignment alignment pins, core support plate column bolts, clevis insert bolts in the lower lower internal assembly (GALL (GALL AMR IV.B2-17)

AMR IV.B2-17)

• " lower core plate in the lower internal internal assembly (GALL AMR IV.B2-18) assembly (GALL IV.B2-18)

• • lower support casting or forging and lower support plate columns in the lower internal assembly (GALL AMR IV.B2-22) assembly (GALL IV. B2-22) guidance in these AMR items is consistent with the guidance The staff's guidance guidance in SRP-LR SRP-LR Section 3.1.2.2.6.

The staff reviewed LRA Section 3.1.2.2.6 and the applicant's AMRs of management management of loss of fracture toughness due to neutron irradiation embrittlement and void swelling in the BVPS RVI irradiation embrittlement components against components against the staffs staff's recommended recommended guidance guidance in SRP-LR Section 3.1.2.2.6; AMR Item Item 22 in Table 1 of the GALL Report, Volume 1; and AMR items IV.B2-3, IV.B2-3, IV.B2-6, IV.B2-9, IV.B2-IV.B2-17, IV.B2-18, and IV.B2-22 17, IV.B2-22 in the GALL Report, Volume 2.

The staff verified that the applicant applicable AMR applicant does include the applicable AMR items in thethe LRA Table 3.1.2-2 that align to the recommendations recommendations in GALLGALL AMRs IV.B2-3,IV.B2-3, IV.B2-6, IV.B2-9, IV.B2-17, IV.B2-18, and IV.B2-22, as applicable IV.B2-17, applicable to the following nickel-alloy nickel-alloy and stainless steel steel RVI components:

• • core baffle/former assembly bolts (aligning to GALL baffle/former assembly GALL AMR IV.B2-6)

IV.B2-6)

• • assembly and former assembly core baffle assembly assembly plates (aligning (aligning to GALL AMR IV.B2-3)

IV.B2-3)

• • core barrel barrel shell, ring, flange, nozzle, and thermal shield/pad shield/pad (aligning toto GALL AMR IV.1B2-9)

IV.B2-9)

• core barrel barrel assembly assembly bolts (aligning to GALL AMR IV.B2-9) IV.B2-9)

• internals assembly core support lower internals support forging and lower support column (aligning (aligning to IV.B2-22)

GALL AMR IV.B2-22)

• lower internals internals assembly support column bolts, clevis insert bolts, and fuel alignmentalignment pins (aligning to GALL GALL AMR IV.B2-17)

• lower lower internals internals assembly core plate (aligning (aligning to GALL AMR IV.B2-18)

AMR IV.B2-18)

For these nickel-alloy nickel-alloy or stainless stainless steel RVI component component commodity commodity groups, the staff verified that the applicant credits its commitments for PWR RVI components components to manage manage loss of fracture toughness due to neutron irradiation embrittlement embrittlement or void swelling in the nickel-alloy nickel-alloy and stainless stainless steel RVI components, as follows:

"For the PWR Vessel Internals Program, regarding activities for managing the aging of "For the PWR Vessel Internals Program, regarding activities for managing the aging of Reactor Vessel internal components Reactor components and and structures, BVPS commits to:

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(1) Participate Participate in the industry programs applicable to BVPS Unit 1/Unit programs applicable 1/Unit 2 for investigating investigating and managing aging aging effects effects on reactor internals; internals; (2) Evaluate and implement implement the results of the industry industry programs programs as applicable to the BVPS Unit 1/Unit 2 reactor internals; internals; and, (3)

(3) Upon Upon completion completion of these programs, but notless not less than 24 months before before entering entering the period period of extended operation, submit an inspection plan for the the BVPS Unit 1/Unit 2 reactor internals internals to the NRC for review and approval."

The staff verified verified that the applicant applicant includes includes this commitment in Commitment Commitment No. 18 18 of LRA UFSAR Supplement Supplement Table A.4-1 for BVPS Unit 1 and in Commitment No. 20 of LRA UFSAR Supplement Table A.5-1 for BVPS Unit 2. As a result as this review, the staff finds that the the applicant applicant has credited an acceptable acceptable AMR basis to manage manage 1055loss of fracture toughness due to neutron irradiation embrittlement neutron irradiation embrittlement and void swelling in the nickel-alloy and stainless steel stainless steel components components of the core baffle/former baffle/former assemblies, core barrel assembly, and lower internals internals assembly assembly because because the commitments commitments credited to further evaluate evaluate these components, components, and to to manage loss of fracture toughness due to neutron irradiation irradiation embrittlement embrittlement and void swelling in the components, have have been verified to be in conformance conformance with the staffs recommended recommended criteria criteria in SRP-LR SRP-LR Section 3.1.2.2.6 and the GALL AMRs that are invoked invoked by this SRP-LR SRP-LR section.

Based on the applicant's applicant's crediting of the commitments commitments identified identified and discussed discussed above, the staff staff concludes that the applicant has conservatively applied the criteria of SRP-LR SRP-LR Section 3.1.2.2.6 Section 3.1.2.2.6 to manage manage 1055 loss of fracture toughness toughness due to neutron neutron irradiation irradiation embrittlement and void swelling swelling nickel-alloy and stainless steel components in the nickel-alloy components of the core baffle/former assemblies, core core barrel assemblies, and lower internals internals assemblies under under exposure exposure to the reactor coolant and an integrated neutron flux, and that for these components, the applicant has met the criteria in integrated SRP-LR Section Section SRP-LR SRP-LR Section 3.1.2.2.6 to manage this aging effect. For those AMR AMR items items that apply to LRA Section 3.1.2.2.6, the staff determined that the LRA is consistent with the the GALL Report and the applicant applicant has demonstrated demonstrated that the effects effects of aging aging will be adequately adequately managed so that the intended functions will be maintained managed maintained consistent with the CLB during the the extended operation, period of extended operation, as required by 10 CFR 54.21 54.21(a)(3).

(a)(3).

3.1.2.2.7 Cracking Due to Stress Corrosion Cracking Cracking PWR Vessel BottomBottom Mounted Instrument Guide Guide Tubes. LRA Section 3.1.2.2.7.1 addresses the 3.1.2.2.7.1 addresses the evaluation on whether the recommended applicant's evaluation recommended guidance guidance in SRP-LR SectionSection 3.1.2.2.7.1, 3.1.2.2.7.1, "Cracking Due to Stress Corrosion Cracking, PWR Vessel Bottom Mounted Instrument Instrument Guide Tubes," is applicable Tubes," applicable to the BVPS LRA. In this Section of the LRA, the applicant applicant states that cracking due to stress corrosion crackingcracking (SCC) could occur in the stainless steel bottom mounted instrument (BMI) guide tubes. The applicant states instrument (BMI) states that it credits its Water Chemistry Program Program to manage cracking due to SCC in the stainless steel BMI guide tubes as a result of exposure of the tubes to the reactor coolant. The applicant also states that it credits its One-Inspection Program Time Inspection Program to verify the effectiveness effectiveness of its Water Chemistry Chemistry Program in managing cracking managing cracking due to SCC in the BMI guide tubes as a result of exposure exposure to the reactor coolant. The applicant clarifies clarifies that the evaluation evaluation of cracking due to SCC in the RV flange flange leakage detection leakage detection tubes provided in LRA Section 3.1.2.2.13 and that the AMRs for these Section 3.1.2.2.13 these components are aligned to GALL AMR AM_R IV.A2-19 through LRA AMR item 3.1.1-31. 3.1.1-31.

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SRP-LR Section 3.1.2.2.7.1 states that cracking due to SCC could occur in in the PWR stainless PWR stainless steel reactor vessel flange leak detection lines and bottom-mounted bottom-mounted instrument (BMI) (BMI) guide guide tubes exposed exposed to reactor coolant. The The SRP-LR Section states that the GALL Report recommends recommends further evaluation to ensure that these aging effects are adequately managed and that a plant-specific AMP be evaluated to ensure ensure that this aging effect is adequately adequately managed.

SRP-LR SRP-LR Section 3.1.2.2.7.1 3.1.2.2.7.1 invokes AMR Item 23 in Table 1 of the GALL Report, Volume 1, IV.A2-1 and IV.A2-5 and AMR items IV.A2-1 IV.A2-5 in the GALL Report Volume 2, as applicable applicable to the the management of cracking due to SCC in in stainless steel BMI guide tubes and in stainless steel steel reactor vessel (RV) flange leakage detection lines (or tubes). The staff's aging management management recommendations in these AMRs are consistent with the guidance in SRP-LR recommendations 3.1.2.2.7.1.

Section 3.1.2.2.7.1.

The staff reviewed LRA Section 3.1.2.2.7.13.1.2.2.7.1 and the applicant's AMRs of management of cracking due to SCC in the BVPS BMI guide tubes and RV flange leakage detection tubes tubes against the staff's recommended guidance guidance in SRP-LR Section 3.1.2.2.7.1; AMR Item 23 in in Table 1 of the GALL Report, Volume 1; and AMR items IV.A2-1 IV.A2-1 and IV.A2-5 IV.A2-5 in the GALL Report, Volume 2. The staff verified applicant does include applicable AMR items in verified that the applicant recommendations in GALL AMRs IV.A2-1 on management LRA Table 3.1.2-1 that align to the recommendations management of cracking due to SCC in BMI guide tubes as a result of exposure to the reactor coolant. The The verified that the applicant staff verified applicant credited its Water Chemistry Program to manage cracking due to stress corrosion cracking in the BMI guide tubes as a result of exposure of the tubes to the the reactor reactor coolant. The staff also verified that the applicant credits its One-Time Inspection One-Time Inspection effectiveness of its Water Chemistry Program for managing cracking due Program to verify the effectiveness due to SCC in the stainless steel BMI guide tubes that are exposed to the reactor coolant.

noted that crediting The staff noted crediting a One-Time One-Time Inspection effectiveness of a Inspection Program to verify the effectiveness Water Chemistry Program in precluding or mitigating Water mitigating cracking due to SCC implies that there has has BVPS-specific or generic not yet been any BVPS-specific experience on cracking due to SCC in these generic experience components. These BMI guide tubes are ASME Code Class 1 reactor reactor coolant pressure boundary (RCPB) components.

components. The staff questioned the basis for using using a One-Time One-Time Inspection Inspection manage this aging effect in lieu of a BVPS defined Program to manage defined periodic inspection program.

inspection program. In In RAI 3.1.2.2.7.1-1, 3.1.2.2.7.1-1, the staff asked the applicant to: (1) identify whether whether there is any applicable applicable BPVS-specific in industry generic BPVS-specific experience on cracking due to SCC of stainless generic operating experience stainless steel PWR BMI guide tubes, and (2) justify why a One-Time steel One-Time Inspection Program Program is justified to manage cracking manage due to SCC in the BMI guide tubes in lieu of crediting a periodic cracking due periodic condition condition monitoring program, such as the ASME Section XI, monitoring Subsections IWB, IWC, XI, Subsections IWC, and IWD Program, particularly when the component type in question (I.e.,

particularly guide tube), is categorized (i.e., BMI guide categorized as an an ASME ASME Code Class 1 RCPB component. component.

applicant responded to RAI 3.1.2.2.7.1-1 The applicant dated July 3.1.2.2.7.1-1 in aa letter dated July 21, 2008. To address 21,2008. address the the part of the RAI that asked the applicant to clarify whether part whether there is any any applicable applicable BVPS specificspecific or industry generic experience related operating experience generic operating related to SCC-induced crackingcracking of stainless stainless steel steel BMI guide tubes, the applicant guide applicant stated has not identified stated that it has identified any any plant-specific plant-specific operating operating experience regarding experience cracking of the bottom-mounted regarding cracking instrument guide bottom-mounted instrument guide tubes. Further, the the applicant applicant stated stated that that aa search of search of thethe Institute for Nuclear Nuclear Power Operations Operations (INPO)(INPO) Operating Operating Experience database Experience database identified 1989 event at Turkey identified aa 1989 Turkey Point Point in which which transgranular transgranular stressstress corrosion cracking (TGSCC) was corrosion cracking was identified several bottom-mounted identified in several bottom-mounted instrument instrument guide guide tubes tubes 3-229 3-229

and that the cracking cracking occurred above the seal table due to chloride chloride contamination contamination and intermittent wetting.

intermittent The applicant Information Notice applicant stated that additionally, NRC Information Notice 2003-11, 2003-11, "Leakage Found on on Bottom-Mounted Instrumentation Bottom-Mounted Instrumentation Nozzles," describes describes axially-oriented axially-oriented cracks that were identified identified in two bottom-mounted instrumentation penetration bottom-mounted instrumentation penetration nozzles at South South Texas Project Unit 1 and that the utility concluded that the most likely root cause explanation explanation for the degradation degradation was was "manufacturing (welding) flaws resulting in excessive stress in the nozzle/weld material leading "manufacturing (welding) flaws resulting in excessive stress in the nozzle/weld material leading to crack initiation initiation with low cycle fatigue/primary fatigue/primary water stress stress corrosion cracking then supporting supporting crack propagation."

address the part of the RAI 3.1.2.2.7.1-1 To address 3.1.2.2.7.1-1 which asked for the applicant to provide aa basis basis why the One-Time One-Time Inspection Program is justified to manage manage cracking cracking due to SCC in the the stainless steel BMI guide tubes in lieu of crediting a periodic periodic condition monitoring monitoring program, the the applicant applicant stated that it is crediting it crediting the BVPS ASME Section Section XI Inservice Inspection Subsections Inservice Inspection Subsections IWB, IWC, and IWD IWD Program as a periodic periodic condition monitoring program for the bottom-bottom-mounted instrumentation guide tubes. The applicant referred to the Enclosure to this letter for mounted instrumentation the revision to the BVPS LRA. Specifically, applicant explained Specifically, the applicant explained that it determined determined that the the BVPS ASME Section XI Inservice Inservice Inspection Inspection Subsections Subsections IWB, IWC, and IWD Program Program is applicable applicable to the bottom-mounted bottom-mounted instrumentation instrumentation guide tubes. The applicant stated that the the BVPS LRA, Table 3.1.2-1 is revised to replace row 2, which assigns the One-Time Inspection Inspection Program to manage cracking of the bottom-mounted bottom-mounted guide tubes, with a row that assigns assigns thethe ASME Section XI Inservice Inservice Inspection Inspection Subsections IWB, IWC, and IWD Program Program to manage manage cracking cracking of the bottom-mounted bottom-mounted guide guide tubes. Further, the applicant stated that based on this this change, LRA Table 3.1.1, 3.1.1, row 23 and LRA Further Evaluation Section 3.1.2.2.7.1 Further Evaluation 3.1.2.2.7.1 are revised to to identify the assignment of the ASME Section Inservice Inspection Section XI Inservice Inspection Subsections Subsections IWB, IWC, and IWD Program instead of the One-Time One-Time Inspection Program to manage manage cracking of the the bottom-mounted guide bottom-mounted guide tubes. The applicant also stated that, LRA Section 3.1.2.1.1, 3.1.2.1.1, list of assigned programs, is revisedrevised to remove the One-Time Inspection Inspection Program Program from the list of aging management management programs for the Reactor Vessel System, because there are no other component types in the system that credit the One-Time Inspection component Inspection Program.

Program. The staff verified verified that the applicant made the applicable applicable amendments amendments of the LRA to creditcredit the ASME Section Section XI Inservice Inservice Inspection, Inspection, Subsections Subsections IWB, IWC, and IWD Program Program in Enclosure Enclosure 1 of the letter of 21, 2008. The staff finds the amended July 21, amended aging management management basis to be acceptable acceptable because because the BMI guide tubes are stainless steel componentscomponents that are within the scope of the applicant's applicant's ASME Section Inservice Inspection,Section XI Inservice Inspection, Subsections Subsections IWB, IWC, and IWD Program and because because this satisfies the staff's recommendation staffs recommendation in SRP-LR SRP-LR Section 3.1.2.2.7, Item (1) to evaluate aa plant-specific aging management plant-specific management program is to be evaluated evaluated to manage manage cracking cracking due to SCC in in these stainless stainless steel components.

Based Based on the staffs review of the applicant's applicant's response of RAI 3.1.2.2.7.1-1 3.1.2.2.7.1-1 and the staffs staffs verification of the applicable verification applicable amendments amendments of the LRA, the staff finds that that the applicant has applicant has provided an acceptable provided acceptable basis for managing managing cracking cracking due to SCC of the BMI guide guide tubes because: (1) the BMI guide tubes are stainless steel components that are within the scope of because:

the applicant's applicant's ASME Section XI Inservice Inspection, Xllnservice Inspection, Subsections IWB, IWC, and IWD IWD Program, (2) the applicant applicant has appropriately amended the LRA to credit the ASME appropriately amended ASME Section XI Inservice Inservice Inspection, Subsections Subsections IWB, IWC, and IWD Program Program for management management of cracking in components instead these components instead of the One-Time Inspection Program, and (3) this satisfies satisfies the staff's recommendation in SRP-LR Section 3.1.2.2.7, Item (1) and GALL AMR recommendation IV.A2-1 to evaluate a AMR IV.A2-1 3-230 3-230

plant-specific plant-specific aging management program aging management for management program for management of of cracking cracking due due to to SCC SCC in these in these stainless steel components. Therefore, the staff's staffs concern in RAI3.1.2.2.7.1-1 RAI 3.1.2.2.7.1-1 is resolved.

resolved.

The staff also verified that the RV flange leakage detection lines (tubes) at BVPS are fabricated leakage detection from nickel-alloy material and that the applicant appropriately aligned its AMR on management applicant appropriately management of cracking due to SCC in in the lines to GALL AMR IV.A2-19.

IV.A2-19. Based on this review, the staff findsfinds that the applicant has a valid basis for not including an AMR item on the RV flange leakage leakage detection detection tubes that aligns to GALL AMR IV.A2-5. IV.A2-5. The staff evaluates evaluates the applicant's AMRs for the RV flange leakage detection detection tubes in in SER Section Section 3.1.2.2.13.

Based on the programs identified identified above, the staff concludes concludes that the applicant applicant has has conservatively applied conservatively applied the criteria of SRP-LR SRP-LR Section 3.1.2.2.7.1 to manage manage cracking cracking due to SCC in in the stainless steel BMI guide tubes that are exposed to the reactor coolant, and that for reactor coolant; these components, the applicant has met the criteria in in SRP-LR SRP-LR SRP-LR Section SRP-LR Section 3.1.2.2.7.1 to manage manage this aging effect. For those AMR items that apply to LRA 3.1.2.2.7.1, the staff concludes Section 3.1.2.2.7.1, concludes that the LRA is consistent with the GALL Report Report and the the demonstrated that the effects of aging will be adequately applicant has demonstrated adequately managed so that the the intended functions will be maintained consistent with the CLB during the period of extended extended operation, as required by 10 CFR 54.21(a)(3).

54.21 (a)(3).

Based Based on this review, the staff also concludes that the applicant has a valid basis for not including an AMR item on the RV flange leakage including leakage detection detection tubes that aligns to GALL AMR AMR IV.A2-5 IV.A2-5 and that the applicant's applicant's AMR basis for the RV flange leakage leakage detections detections tubes do not need to conform to the guidance in in SRP-LR SRP-LR Section 3.1.2.2.7.1 because because the RV flange leakage leakage detection lines are not fabricated fabricated from stainless steel. The staff evaluates the applicant's AMRs AMRs for the nickel-alloy RV flange leakage detectiondetection tubes in in SER Section 3.1.2.2.13.

Cast Austenitic Austenitic Stainless Steel (CASS) Reactor Coolant Coolant System System Components.

Components. LRA 3.1.2.2.7.2 addresses Section 3.1.2.2.7.2 addresses the applicant's applicant's evaluation evaluation on whether recommended whether the recommended guidance in guidance in SRP-LR Section Section 3.1.2.2.7.2, "Cracking Due to Stress Corrosion Cracking,Cracking, Cast Austenitic Stainless Austenitic Stainless Steel Steel (CASS) Reactor Reactor Coolant Coolant System System Components,"

Components," is applicable applicable to thethe BVPS LRA.LRA. InIn this Section Section of the LRA, the applicant applicant states that cracking due to stress corrosion cracking (SCC) could occur in in the BVPS Code Class 1 CASS piping components as a result of exposure to the reactor reactor coolant.

The applicant states states that itit credits a combination combination of its Water Chemistry Program and its its ASME Section ASME Section Xl, Subsection IWB, IWC, and IWD Program to manage cracking due to XI, Subsection SCC in SCC in the the ASME Code Code Class 1 CASS piping components components as a result of exposure of the the components to the reactor coolant.

components SRP-LR Section 3.1.2.2.7.2 3.1.2.2.7.2 states that cracking due to SCC could occur in Class 1 PWR PWR cast austenitic austenitic stainless steel (CASS) reactor coolant system system piping, piping components, and piping and piping elements elements exposed to reactor coolant. The SRP-LR Section states that, although the existing the program relies existing program relies on on control control of water chemistry to mitigate SCC, SCC could occur for CASS components that do not meet the NUREG-0313 NUREG-0313 guidelines guidelines with regard to ferrite ferrite and carbon carbon content. The SRP-LR SRP-LR Section states that the GALL Report recommends further further evaluation of a plant-specific plant-specific program for these components components to ensure that this aging effect effect adequately managed.

is adequately 3-231

SRP-LR SRP-LR Section 3.1.2.2.7.2 3.1.2.2.7.2 invokes AMR Item 24 in Table 1 of the GALL Report, Volume 1, and AMR item IV.C2-3, IV.C2-3, as applicable to the management management of cracking due to SCC in ASME ASME Code Class 1 CASS piping, piping components, and piping elements as aa result of exposure to the reactor coolant. In these AMR items, the staff recommendsrecommends that a plant-specific plant-specific aging aging management management programprogram is to be evaluated to manage manage cracking due to SCC in these stainless stainless steel components components as a result of exposure exposure to the reactor coolant. This is consistent consistent with thethe guidance in guidance SRP-LR SRP-LR Section 3.1.2.2.7.2.

The staff reviewed reviewed LRA Section Section 3.1.2.2.7.2 and the applicant's AMRs on management management of cracking due to SCC in the ASME Code Class 1 CASS piping against the staff's staff's recommended regulatory criteria in SRP-LR recommended 3.1.2.2.7.2; AMR Item 24 in Table 1 of SRP-LR Section 3.1.2.2.7.2; the GALL the GALL Report, Report, Volume 1; and AMR item IV.C2-3 in the GALL Report, Volume 2.

The staff verified that the applicant applicant does include applicable AMR items in LRA Table 3.1.2-3 3.1.2-3 that align to the recommendations recommendations in GALL GALL AMRs IV.C2-3 on management AMRs IV.C2-3 management of cracking due to SCC in the ASME Code Class 1 piping as a result of exposure exposure to the reactor reactor coolant. The staffstaff verified that the applicant credited its Water Chemistry Program and its ASME Section Section XI Inservice Inspection, Subsections Inservice Subsections IWB,IWB, IWC, and IWD IWD Program to manage manage cracking due to SCC in these ASME Code Class 1 CASS piping components components as a result of exposure exposure of the tubes to the reactor coolant.

The program description description in GALL AMP XI.M2, XI.M2, "Water Chemistry," states that water chemistry programs programs for PWRs PWRs rely on monitoring monitoring and control of reactor water chemistry based on industry guidelines guidelines for primary primary water and secondary secondary water chemistry chemistry such as EPRI TR-1 05714, TR-105714, Revision 3 and TR-102134, Revision 3 or later revisions. The staff verified verified that the applicant applicant identifies that its Water Chemistry Program is an AMP that is used for the purpose Chemistry Program purpose of controlling controlling the ingress ingress of impurities impurities into the reactor coolant or other plant coolants in order to prevent prevent or mitigate mitigate the occurrence of corrosion-based occurrence corrosion-based aging effects, such as loss of material due to

general, general, pitting, or crevice corrosion or cracking cracking due to SCC (including (including PWSCC). The staff also also verified that the applicant categorizes categorizes its Water Chemistry Chemistry Program Program as an AMP that will be be consistent consistent with the staffs recommended recommended program element criteria in GALL AMP XI.M2, "Water enhancement of program elements. Based Chemistry," with enhancement Based on this review, the staff determined determined that the applicant's applicant's crediting of its Water Chemistry Chemistry Program Program to prevent or mitigate the the consequences of cracking consequences cracking due to SCC in the ASME Code Class 1 CASS piping components is valid because the basis for program is in conformance conformance with the program description in GALL program description AMP XI.M2, XI.M2, Water Chemistry." The staff evaluates the program elements and the capabilitycapability of the applicant's applicant's Water Chemistry Program to prevent or mitigate mitigate corrosion-induced corrosion-induced aging effectseffects in SER Section Section 3.0.3.2.14.

program description The program description in GALL AMP XI.M1, XI.M1, "ASME Section XI Inservice Inservice Inspection, Inspection, Subsections IWB,IWB, IWC, and IWC," states that ASME Section Xl XI inservice inspection inspection (ISI)

(lSI) programs, implemented implemented in accordance accordance with the requirements requirements 10 in 10 CFR 50.55a and the ASMEASME Code Section XI, XI, Subsections Subsections IWB, IWC, or IWD has been shown to be generally effective in managing aging effects managing effects in ASME Code Class 1, 2, or 3 components and their integral attachments.

attachments. The program description states program description states that, in certain certain cases, the ASME ASME lSI ISI program program should be augmented augmented to managemanage effects of aging for license license renewal and that the GALL Report identifies those components components in which augmentation augmentation of the AMP is necessary necessary for aging management.

3-232 3-232

CASS piping components The CASS components within the scope scope of applicant's AMR are ASME Code Code Class 1 piping components that are part of the RCPB. The The staff verified that the applicant identifies identifies its Inspection, Subsections ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program Program as as a condition condition monitoring program for ASME Code Class 1, 2, and 33 pressure-retaining pressure-retaining components, including including welds, pump casings, valve bodies, integral integral attachments, and pressure-retaining pressure-retaining bolting. The The staff also verified that the applicant categorizes its ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program as an AMP that is consistent with the staff's Subsections recommended program element criteria in GALL AMP XI.M1, recommended XI.M1, "ASME Section XI Inservice Inservice Inspection, Subsections IWB, IWC, and IWD," with an exception. Based Inspection, Based on this review, the staffstaff concluded that itit is valid for the applicant's to credit its ASME Section XI InserviceInservice Inspection, Subsections IWB, IWC, and IWD IWD Program for management management of cracking due to SCC in in the ASME Code Class 11 CASS CASS piping components components because the basis for program management management is is conformance with the program description in GALL AMP XI.M1, in conformance XI.M1, ASME Section Xllnservice XI Inservice Subsections IWB, IWC, and IWD."

Inspection, Subsections IWD." The staff evaluates evaluates the program program elements elements and the capability of the applicant's ASME Section XI Inservice Inspection, Subsections Subsections IWB, IWC, and IWD Program to cracking due to SCC SCC in the ASME Code Class 1 CASS piping in SER Section 3.0.3.2.1.

3.0.3.2.1.

Based on this review, the staff finds that the applicant has included appropriate appropriate AMR items on management of cracking management cracking due to SCC in the ASME Code Class 1 CASS piping components components that align to GALL AMR Item 24 in Table 1 of the GALL Report, Volume 1 and to AMR item IV.C2-3 IV.C2-3 in the GALL Report, Volume 2. The staff also finds that the applicant has evaluated applicable evaluated applicable plant-specific programs and has provided a valid basis for crediting the Water Chemistry Program and the ASME Section XI Inservice Inservice Inspection, Inspection, Subsection Subsection IWB, IWC, and IWD IWD Program credited valid AMPs to manage cracking due to SCC in the ASME Code Class 1 CASS CASS piping.

Based on the programs identified above, the staff concludes that the applicant programs identified applicant has has conservatively applied the criteria of SRP-LR Section 3.1.2.2.7.2 conservatively 3.1.2.2.7.2 to manage manage cracking due to SCC in the ASME Code Class 1 CASS piping components components that are exposed exposed to the reactor reactor coolant, and that for these components, the applicant has met the criteria in SRP-LR SRP-LR Section SRP-LR Section Section 3.1.2.2.7.2 manage this aging effect. For those AMR items that 3.1.2.2.7.2 to manage apply to LRA Section 3.1.2.2.7.2, 3.1.2.2.7.2, the staff determined determined that the LRA is consistent with the GALL Report and the applicant applicant has has demonstrated demonstrated that the effects effects of aging will be adequately adequately managed so that the intended functions functions will be maintained maintained consistent consistent with the CLB during during the period of extended operation, extended operation, as required required by 10 CFR CFR 54.21(a)(3).

54.21(a}(3}.

3.1.2.2.8 Cracking Cracking Due to CyclicCyclic Loading Loading BWR Jet Jet Pump Pump Sensing Sensing Lines Under Exposure Exposure to the Reactor Reactor Coolant. SRP-LR SRP-LR Section Section 3.1.2.2.8, 3.1.2.2.8, Item (1) states that cracking cracking due due to cyclic loading loading could occur occur in the the stainless steel BWR BWR jet pump pump sensing lines under exposure exposure to the reactor reactor coolant. The The SRP-LR SRP-LR Section Section states that the GALL GALL Report Report recommends recommends that a plant-specific plant-specific AMP AMP be be evaluated evaluated toto ensure ensure that this agingaging effect effect is adequately adequately managed, managed, and that that acceptance acceptance criteria criteria are are described described in Branch Branch Technical Technical Position RLSB-1 (Appendix A. A.11 of this SRP-LR).

For the BWR components components referred referred to above, the the GALL GALL AMRs AMRs referred to to by this SRP-LR SRP-LR Section Section are AMR item 25 in Table Table 1 of the GALL the GALL Report, Revision Revision 1, Volume 22 (GALL1)

(GALL 1) and AMR AMR item item IV.B1-12 IV.B1-12 inin Table IV.B1 IV.B1 of the the GALL GALL Report, Revision Revision 1, Volume Volume 2 (GALL2).

(GALL2). The The 3-233 3-233

appli