ML093200023
| ML093200023 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/14/2009 |
| From: | Robert Kuntz License Renewal Projects Branch 2 |
| To: | Franke J Progress Energy Florida |
| KUNTZ R, NRR/DLR, 415-2989 | |
| References | |
| TAC ME0274 | |
| Download: ML093200023 (98) | |
Text
December 14, 2009 Mr. Jon Franke, Vice President Crystal River Nuclear Plant (NA1B)
ATTN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, FL 34428-6708
SUBJECT:
AMP AUDIT REPORT REGARDING THE CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT, LICENSE RENEWAL APPLICATION (TAC NO.
ME0274)
Dear Mr. Franke:
By letter dated December 16, 2008, Florida Power Corporation, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating license for Crystal River Unit 3 Nuclear Generating Plant for review by the U.S.
Nuclear Regulatory Commission (NRC or the staff). On July 17, 2009, the NRC audit team completed the on-site audit of aging management programs. The audit report is enclosed.
If you have any questions, please contact Robert Kuntz at 301-415-3733 or by e-mail at robert.kuntz@nrc.gov.
/RA/
Robert F. Kuntz, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-302
Enclosure:
As stated cc w/encl: See next page
December 14, 2009 Mr. Jon Franke, Vice President Crystal River Nuclear Plant (NA1B)
ATTN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, FL 34428-6708
SUBJECT:
AMP AUDIT REPORT REGARDING THE CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT, LICENSE RENEWAL APPLICATION (TAC NO.
ME0274)
Dear Mr. Franke:
By letter dated December 16, 2008, Florida Power Corporation, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating license for Crystal River Unit 3 Nuclear Generating Plant for review by the U.S.
Nuclear Regulatory Commission (NRC or the staff). On July 17, 2009, the NRC audit team completed the on-site audit of aging management programs. The audit report is enclosed.
If you have any questions, please contact Robert Kuntz at 301-415-3733 or by e-mail at robert.kuntz@nrc.gov.
/RA/
Robert F. Kuntz, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-302
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION: See next page ADAMS Accession Number: ML093200023 OFFICE LA:DLR PM:RPB2:DLR BC:RARB:DLR BC:RASB:DLR JDozier RAuluck NAME SFigueroa RKuntz (JMedoff for) (MModes for)
DATE 11/24/09 12/11/09 12/9/09 12/11/09 OFFICE BC:RPB2:DLR BC:RAPB:DLR PM:RPB2:DLR RKuntz NAME DWrona DPelton (Signature)
DATE 12/1/09 12/14/09 12/14/09 OFFICIAL RECORD COPY
Letter to J. Franke from R. Kuntz, dated December 14, 2009 DISTRIBUTION:
SUBJECT:
AMP AUDIT REPORT REGARDING THE CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT, LICENSE RENEWAL APPLICATION (TAC NO.
ME0274)
HARD COPY:
DLR RF E-MAIL:
PUBLIC [or NON-PUBLIC, if applicable]
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________
RKuntz EKeegan AJones, OGC LLake, RII MSykes, RII TMorrissey, RII RReyes, RI
Crystal River Nuclear Generating Plant, Unit 3 cc:
Mr. R. Alexander Glenn Senior Resident Inspector Associate General Counsel (MAC-BT15A) Crystal River Unit 3 Florida Power Corporation U.S. Nuclear Regulatory Commission P.O. Box 14042 6745 N. Tallahassee Road St. Petersburg, FL 33733-4042 Crystal River, FL 34428 Mr. James W. Holt Ms. Phyllis Dixon Plant General Manager Manager, Nuclear Assessment Crystal River Nuclear Plant (NA2C) Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street 15760 W. Power Line Street Crystal River, FL 34428-6708 Crystal River, FL 34428-6708 Mr. William A. Passetti, Chief Mr. David T. Conley Department of Health Associate General Counsel II - Legal Dept.
Bureau of Radiation Control Progress Energy Service Company, LLC 2020 Capital Circle, SE, Bin #C21 Post Office Box 1551 Tallahassee, FL 32399-1741 Raleigh, NC 27602-1551 Attorney General Mr. Daniel L. Roderick Department of Legal Affairs Vice President, Nuclear Projects &
The Capitol Construction Tallahassee, FL 32304 Crystal River Nuclear Plant (SA2C) 15760 W. Power Line Street Mr. Ruben D. Almaluer, Director Crystal River, FL 34428-6708 Division of Emergency Preparedness Department of Community Affairs Mr. Mark Rigsby 2740 Centerview Drive Manager, Support Services - Nuclear Tallahassee, FL 32399-2100 Crystal River Nuclear Plant (SA2C) 15760 W. Power Line Street Chairman Crystal River, FL 34428-6708 Board of County Commissioners 110 North Apopka Avenue Mr. Robert J. Duncan II Inverness, FL 34450-4245 Vice President, Nuclear Operations Progress Energy Mr. Stephen J. Cahill Post Office Box 1551 Engineering Manager Raleigh, NC 27602-1551 Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Mr. Brian C. McCabe Crystal River, FL 34428-6708 Manager, Nuclear Regulatory Affairs Progress Energy Mr. Daniel R. Westcott Post Office Box 1551 Supervisor, Licensing & Regulatory Raleigh, NC 27602-1551 Programs Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428-6708
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION - DIVISION OF LICENSE RENEWAL AGING MANAGEMENT AUDIT REPORT Docket No: 050-302 License No: DPR-72 Licensee: Florida Power Corporation Facility: Crystal River Unit 3 Nuclear Generating Plant Location: Crystal River Unit 3 Nuclear Generating Plant 15760 W. Power Line Street Crystal River, Florida 34428-6708 Dates: July 13-17, 2009 Reviewers: R. Kuntz, Sr. Project Manager, Division of License Renewal (DLR)
A. Hiser, Senior Level Advisor, DLR D. Pelton, Branch Chief, DLR R. Auluck, Branch Chief, DLR D. Brittner, Reactor Engineer, DLR J. Shea, Sr. Reactor Engineer, DLR K. Karwoski. Senior Level Advisor, Division of Component Integrity (DCI)
D. Nguyen, Electrical Engineer, DLR C. Doutt, Sr. Electrical Engineer, DLR J. Davis, Sr. Materials Engineer, DLR W. Smith, Sr. Materials Engineer, DLR D. Alley, Materials Engineer, DLR A. Prinaris, Sr. Materials Engineer, DLR S. Min, Materials Engineer, DLR M. Sircar, Structural Engineer, DLR A. Sheik, Sr. Structural Engineer, DLR C. Yang, Sr. Mechanical Engineer, DLR A. Wong, Sr. Mechanical Engineer, DLR R. Vaucher, Mechanical Engineer, DLR B. Fu, Materials Engineer, DLR J. Collins, Sr. Materials Engineer, DCI A. Obodoako, Materials Engineer, DCI B. Harris, Project Manager, DLR D. Hoang, Structural Engineer, DLR T. Mintz, Center for Nuclear Waste Regulatory Analysis (CNWRA)
Y. Pan, CNWRA ENCLOSURE
Approved By: Jerry Dozier, Chief Aging Management of Reactor Systems and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation Rajender Auluck, Chief Aging Management of Structures, Electrical, and Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation David L. Pelton, Chief Aging Management of Plant Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation David Wrona, Chief Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation
Introduction An on-site audit was conducted by the NRC project team at the Crystal River Unit 3 Nuclear Generating Plant (CR-3) on July 13-17, 2009. The purpose of this audit was to examine the applicants Aging Management Programs (AMPs) for the CR-3 and to verify the applicants claim of consistency with the corresponding NUREG-1801, Generic Aging Lessons Learned (GALL) Report AMPs. Exceptions to the GALL Report AMP elements will be evaluated separately as part of the NRC staffs (the staffs) review of the CR-3 license renewal application (LRA) and documented in the staffs Safety Evaluation Report (SER).
The Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800, Revision 1) provides the staff guidance for reviewing a license renewal application (LRA). The Standard Review Plan allows an applicant to reference in its LRA the AMPs described in the GALL Report. By referencing the GALL Report AMPs, the applicant concludes that its AMPs correspond to those AMPs, and that no further staff review is required.
If an applicant credits an AMP for being consistent with a GALL Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL Report program. The applicants determination should be documented in an auditable form and maintained on-site.
During this audit, the staff audited program elements 1 - 6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria), and program element 10, (operating experience), of the applicants AMPs claimed to be consistent with the GALL Report against the equivalent elements of the associated AMP described in the GALL Report, unless otherwise indicated in this Audit Report.
Program elements 7 - 9 (corrective actions, confirmation process, and administrative controls) were audited by another NRC project team during the Scoping and Screening Methodology audit and are evaluated separately. In addition, the staff verified the conditions at the plant were bounded by the conditions for which the GALL Report program was evaluated.
The staff also examined the applicants program bases documents and related references for these AMPs and interviewed CR-3 representatives to obtain additional clarification related to the CR-3 AMPs.
LRA AMP B.2.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program The CR-3 LRA stated that AMP B.2.1 is an existing program that is consistent with the program elements in GALL Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the Final Safety Analysis Report (FSAR) Supplement in LRA Section A.1.1.1.
Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords: Class 1, weld, examination, inspection, ISI, indication, crack, and flaw. The staff screened these results for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date License Renewal Aging Management Program Description of the Rev. 1
- 1. L08-0600 ASME Section XI, Subsections IWB, IWC, and IWD, Inservice 11/13/2008 Inspection Program Crystal River Unit 3, Inservice Inspection Program Plan, Ten-Year
- 3. C-SP-07-01 09/18/2007 Processes Crystal River Unit 3 Day Inservice Inspection (ISI) Summary
- 4. 03/04/2008 Report Action Request - Key Project Attributes Required for Successful
- 6. NGGM-PM-0011 Nuclear NDE Manual Rev. 60
- 7. AI-701 Administration of the ASME Section XI ISI and IST Programs Rev. 17 Inservice Inspection (ISI)/ Inservice Testing (IST) and Special
- 8. C-SP-05-02 09/15/2005 Processes Assessment
- 9. C-FR-06-01 Results of the Ten-Year ISI Project Focus Review 01/03/2007
- 11. NCR00033653 Pipe Stress Analysis Supporting the Large Bore Piping Project 06/01/2001 During the audit of program elements 1 - 6, the staff found that:
Elements 1, 2, 3, 5 and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP;
Sufficient information was not available to determine whether element 4 of the LRA AMP was consistent with the corresponding element of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element 4 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
In element 4 of the LRA AMP it states that the licensee will use examination category R-A in accordance with risk-informed methodology approved by the NRC for use during the current ten-year interval for examination of Table IWB-2500-1 category B-F and B-J welds. In the GALL Report AMP Section XI.M1 recommends the use of ASME Section XI Table IWB-2500-1 to determine the examination of category B-F and B-J welds. It is not clear to the staff that these statements are consistent.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 4 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.2, Water Chemistry Program In the CR-3 LRA, the applicant states that AMP B.2.2, Water Chemistry Program, is an existing program that is consistent with the program elements in GALL Report AMP XI.M2, Water Chemistry. To verify this claim of consistency, the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as
contained in the Water Chemistry FSAR Supplement in LRA Section A.1.1.2. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns of the water chemistry laboratories and monitoring facilities, interviewed the applicants staff, and reviewed onsite documentation provided by applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords chemistry, pH, dissolved oxygen, fluoride, sulfate, chloride, primary water, and secondary water.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0601 Water Chemistry AMP Revision 1 11/12/2008
- 2. Crystal River Unit 3 Nuclear Power Plant Optimized Primary Revision 5 Chemistry Program 9/16/2008
- 3. Crystal River Unit 3 Nuclear Power Plant Optimized Secondary 2/15/2009 Water Chemistry Program
- 4. EPRI 1014986 Pressurized Water Reactor Primary Water Chemistry Guidelines, Revision 6 Volumes 1 and 2 12/2007
- 5. EPRI 1008224 Pressurized Water Reactor Secondary Water Chemistry Revision 6 Guidelines 12/2004
- 6. CP-142 Primary Water Chemistry Guidelines Revision 21 6/16/2009
- 7. CP-138 Secondary Water Chemistry Guidelines Revision 27 4/15/2009
- 8. CH-400 Nuclear Chemistry Master Scheduling Program Revision 46 5/1/2009
- 9. AREVA 51- PWR Fuel Reactor Coolant Chemistry Supplemental Guidelines Revision 6 9076054-000 3/24/2008 During the audit of program elements 1 - 6, the staff found that:
elements 1 - 4, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether element 5 of the LRA AMP was consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element number 5 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
element 5 of the LRA AMP states that the operating procedure CH-400 defines the sampling frequencies for the CR-3 Plant Chemistry program. In the GALL Report AMP it states that the frequency of sampling should be based upon plant operating conditions and the Electrical Power Research Institute (EPRI) water chemistry guidelines. It is not
clear to the staff that these statements are consistent, because the applicants CH-400 document does not include sampling frequency for silica in the reactor coolant during startup, which is included in both the EPRI guidelines and the CR-3 Optimized Primary Chemistry Program.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation. The staff identified operating experience that had not been included in the plant-specific operating experience described in either the LRA or the applicants basis documents. However, this additional operating experience is bounded by industrial experience and will not adversely affect the effectiveness of the LRA AMP.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit, the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 5 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement adequately describes the program.
LRA AMP B.2.3, Reactor Head Closure Studs Program In the CR-3 LRA, the applicant states that AMP B.2.3, Reactor Head Closure Studs Program is an existing program with an enhancement that is consistent with the program elements in GALL Report AMP XI.M3, Reactor Head Closure Studs Program. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.3. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The enhancement affects LRA program element 2. This enhancement expands on the existing program element by selecting an alternate lubricant that is compatible with the fastener material and the contained fluid. In the LRA transmittal letter dated December 16, 2008 (ADAMS Accession No. ML090080054), the applicant committed to implement this enhancement prior to the period of extended operation.
During its audit, the staff interviewed the applicants staff and reviewed on-site documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords: reactor, head, closure, stud, nut, leakage, corrosion, boric and acid The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the operating experience database of the applicant and the technical information related to the applicants AMP.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0602 License Renewal Aging Management Program Description of the Revision: 1 Reactor Head Closure Studs Program 11/11/2008
- 2. FSAR Table 4-16 Reactor Vessel - Physical Properties Revision: 30.4 3/6/2008
- 3. FSAR Section 4.3.3 Reactor Vessel, f. closure Revision: 31 5/9/2008
- 4. Form No. 10-731A-01 Dow Corning G-n Met Assembly Paste and Dow Corning G-n Revision: N/A Metal Assembly Spray 2000 (Note: Dow Corning Technical Data Sheet)
- 5. Letter from Florida Crystal River Unit 3, Docket No. 50-302, Operating License No. Revision: N/A Power Corp. to U.S. NRC DPR-72, IE Bulletin No. 82-02, Degradation of Threaded 8/2/1982 Fasteners in the Reactor Coolant Pressure Boundary in PWR Plants
- 6. Specification No. CS- Standard Equipment Specification for Reactor Vessel, The Revision: N/A 3-22 Babcock & Wilcox Company Power Generation Division 10/13/1970 Commercial Nuclear Components, Barberton, Ohio
- 7. FP-405 Reactor Vessel Closure Head Stud Removal and Cleaning Revision: 25 8/3/2004
- 8. FP-407 Reactor Vessel Stud Hole Seal Plug Installation Revision: 13 1/21/2009
- 10. Problem Report 92- Reactor Vessel Stud Hole Inspection Revision: N/A 9035 7/2/1992
- 11. Eng. Question 87- Engineering Question 87-3000 Revision: N/A 3000 12/15/1987
- 12. Letter from Crystal River Unit 3 day Inservice Inspection (ISI) Summary Revision: N/A Progressive Energy Report: including Attachment 1, ASME,Section XI, NIS-1, 3/4/2008 Florida, Inc. to U.S. NRC Owners Report of Inservice Inspections for RFO15
The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancement.
During the audit of program elements 1 - 6, the staff found that:
elements 1 and 3 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether element 2 of the LRA AMP was consistent with the corresponding element of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element 2 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing an RAI for the following subjects:
In relation to element 2 of the LRA AMP, the applicant states that an enhancement will be made to select an alternate lubricant that is compatible with the fastener material and the contained fluid.
The staff noted that NRC Regulatory Guide (RG) 1.65 is one of the technical references for GALL Report AMP XI.M3 and states in the regulatory position that lubricants for the stud bolting are permissible provided they are stable at operating temperatures and are compatible with the bolting and vessel materials and surrounding environment.
The staff noted that a molybdenum disulfide based lubricant is used for the reactor head closure studs. It should be clarified whether the lubricant, which is used, has caused detrimental effects on the bolting and vessel materials or not. In addition, the staff found a need to clarify how the selection of a new lubricant will consider the stability of the lubricant at operating temperatures as recommended in RG 1.65.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP that is provided in the FSAR Supplement.
The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 2 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.4, Boric Acid Corrosion Program In the CR-3 LRA, the applicant states that AMP B.2.4 Boric Acid Corrosion is an existing program that is consistent with the program elements in GALL Report AMP XI.M10 Boric Acid Corrosion. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.4 Boric Acid Corrosion Program. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keyword Boric Acid Corrosion.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date Volume 99 EGR-NGGC-0207 Boric Acid Corrosion Control Standard Procedure Book/Part 99, Rev 3 No date Boric Acid Corrosion Control Monitoring Log, Listing of High provided but NA Probability Locations 07/01/09 actions identified Rev. 1, License Renewal Aging Management Program Description Calculation Number Reviewed of the Boric Acid Corrosion Program, Nuclear Generation L08-0603 11/13/2008 by Group Wayne Bichlmeir Crystal River Unit 3 - Response to Request for Additional Letter from Progress Information,Bulletin 2002-01, Reactor Pressure Vessel Dated January Energy to the NRC Head Degradation and Reactor Coolant Pressure Boundary 28, 2003 Integrity Crystal River Unit 3 day Response to Bulleting 2002-Letter from Progress Dated May 15, 01, Reactor Pressure Vessel Head Degradation and Energy to the NRC 2002 Reactor Coolant Pressure Boundary Integrity
Document Title Revision / Date Crystal River Unit 3 - Summary of Alloy 600/82/182 Letter from Progress Dated January Pressurizer Butt Weld Mitigation and Closure of Energy to the NRC 24, 2008 Confirmatory Action Letter Number NRR-07-016 Crystal River Unit 3 - 60 Day Report Regarding NRC Dated Letter from Progress Bulletin 2003-02, Leakage from Reactor Pressure Vessel December 17, Energy to the NRC Lower Head Penetrations and Rector Coolant Pressure 2003 Boundary Integrity Crystal River Unit 3 Day Response to Bulletin 2003-Dated Letter from Progress 02, Leakage from Reactor Pressure Vessel Lower Head September 17, Energy to the NRC Penetrations and Reactor Coolant Pressure Boundary 2003 Integrity Standard Review Plan for Review of License Renewal NUREG-1800 Revision 1 Applications for Nuclear Power Plants (SRP-LR)
NUREG-1801 Generic Aging Lessons Learned (GALL) Report Revision 1 NRC Generic Letter Boric Acid Corrosion of Carbon Steel Reactor Pressure Dated March 17, 88-05 Boundary Components in PWR Plants 1988 Reactor Pressure Vessel Head Degradation and Reactor Dated March 18, NRC Bulletin 2002-01 Coolant Pressure Boundary Integrity 2002 Leakage from Reactor Pressure Vessel Lower Head Dated August NRC Bulletin 2003-02 Penetrations and Reactor Coolant Pressure Boundary 21, 2003 Integrity Inspection of Alloy 82/182/600 Materials Used in the Dated May 28, NRC Bulletin 2004-01 Fabrication of Pressurizer Penetrations and Steam Space 2004 Piping Connections at Pressurized Water Reactors (21) Boric Acid AMP OE Keyword Search Results for (21) Boric Acid Dated July 15, Corrosion Corrosion, 68 pages, 152 items 2009 Dated January NCR 262590 MUDM-1A Has An Active Boric Acid Leak 17, 2008 Dated January NCR 262594 MUDM-1B Has An Active Boric Acid Leak 17, 2008 Dated February NCR 264897 Step Change in Boric Acid Deposit on BSV-29 5, 2008 Dated February NCR 265440 WDV-24 Body to Bonnet Leak 7, 2008 Dated February NCR 322014 WDV-38 Leaking in Normally Non-Contaminated Area 26, 2008 Conduct Benchmarking to Oconee (Duke Power) Peer Dated March 4, NCR 323077 Assessor 2009 BM 323077R1, Fluid Leak Management Team Approach to Dated April 28, NCR 333026 BACC 2009 BM 323077, R2, Improved Guidance for Eng System Dated April 28, NCR 323077 Walkdowns 2009 CR3 Collective Significance Review of Potential RCS Dated March 11, NA Leakage Indicators, Period 8/29/08 to 3/10/09 2009 During the audit of program elements 1 - 6, the staff found that:
elements 1 - 5 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether element 6 of the LRA AMP was consistent with the corresponding element of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element number 6 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
For program element 6 the applicant states in Section 8 Acceptance Criteria of the Boric Acid Corrosion Control Standard Procedure, EGR-NGGC-0207, the following; Section 8.3: Deviations to the acceptance criteria shall be documented and reviewed for acceptability for continued service. See Section 9.4 [Evaluation of Active Leaks] for evaluating these conditions.
The staff asked how deviations are approved and monitored. The licensee was unable to provide a documented process to address this issue. Therefore, the staff may submit a request for additional information for the applicant to define the deviation process for the Boric Acid Corrosion Program including responsibilities, documentation requirements, as well as the review and authorization process.
During the audit of program element 10, the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 6 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.5, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program In the CR-3 LRA, the applicant states that AMP B.2.5, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors, is an existing program that is consistent with the program elements in GALL Report AMP XI.M11A, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement described in LRA Section A.1.1.5. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords penetration nozzle, vessel head, and EA-03-009.
The table below lists the documents that the staff reviewed and found relevant to the audit.
These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0605 License Renewal Aging Management Program Description of the Revision 0 Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program
- 2. Order EA 03-009 Issuance of Order Establishing Interim Inspection Requirements for 2/11/2003 Reactor Pressure Vessel Heads at Pressurized Water Reactors
- 3. Order EA 03-009 Issuance of Revised Order EA-09-003 Establishing Interim Revision 1, Inspection Requirements for Reactor Pressure Vessel Heads at 2/20/2004 Pressurized Water Reactors
- 4. Letter 3F0304-05 Twenty-Day Response to First Revised Order (EA-03-009) 3/9/2004 Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors
- 5. Letter 3F0108-10 Summary of Reactor Pressure Vessel Head Inspection per First 1/28/2008 Revised Order (EA-03-009)
- 6. E-Mail Examination and Analysis of Deposits Taken from a Reactor Head 11/28/2007 (Metallurgy Services Project Number 07-284)
- 7. 73 FR 52730 10 CFR Part 50 Industry Codes and Standards; Amended 9/10/2008 Requirements, Final Rule
- 8. ASME Code Case Alternative Examination Requirements for PWR Reactor Vessel 3/28/2006 N-729-1 Upper Heads with Nozzles Having Pressure-Retaining Partial-Penetration Welds,Section XI, Division 1
- 9. Program Plan ISI Components and Structures Examination Program Revision 8, 12/9/2008 During the audit of program elements 1 - 6, the staff found that:
elements 1, 2, 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP;
sufficient information was not available to determine whether element 4 of the LRA AMP was consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element 4 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing an RAI for the following subject:
In the GALL Report AMP XI.M11A, the augmented inspection requirements established in First Revised Order EA-03-009 include visual inspection (VT-2) and nondestructive examinations. 10 CFR 50.55a final rule that supersedes the Revised Order requires visual examination and volumetric and/or surface examination as specified in ASME Code Case N-729-1. It is not clear to the staff what the specific schedules will be for the visual and volumetric inspections and how the training for visual examination will be implemented.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit, the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 4 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement adequately describes the program.
LRA AMP B.2.6, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program In the CR-3 LRA, the applicant states that AMP B.2.6, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program, is a new program that is consistent with the program elements in GALL Report AMP XI.M13, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS). The applicant committed in the LRA transmittal letter dated December 16, 2008 to implementing this program during the last 10-year in-service inspection interval prior to the period of extended operation.
To verify this claim of consistency, the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.6. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords cast austenitic stainless steel, embrittlement, CASS, thermal, and irradiation.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0607 Thermal Aging and Neutron Irradiation Embrittlement of CASS Revision 0 7/9/2008
- 2. AI-701 Administration of the ASME Section XI In-service Inspection and In- Revision 17 service Testing Programs 8/14/2008
- 3. EPRI Report Plant Support Engineering: Utility Cast Austenitic Stainless Steel 12/2007 1015395 Component
- 4. Letter 3F0308-01 Crystal River Unit 3 Nuclear Power Plant90-Day In-service Revision 0 Inspection (ISI) Summary Report 3/4/2008
- 5. Letter 3F1207-04 Crystal River Unit 3 Nuclear Power PlantIn-service Inspection Revision 0 Program Plan, 10-Year Update 9/26/07
- 6. ASTM A351/A351M Standard Specification for Castings, Austenitic, Austenitic-Ferritic Revision A94 (Duplex), for Pressure-Containing Parts 1994 During the audit of program elements 1 - 6, the staff found that:
elements 2, 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether elements 1 and 4 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 1 and 4 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
in element 1 of the LRA AMP it states that the synergistic effect of thermal and irradiation embrittlement needs only be considered if the CASS component experiences a fluence level of 1021 n/cm2 (E > 1 MeV) or greater. In the GALL Report AMP it states that the synergistic effect should be considered for potentially susceptible components, which include components experiencing fluence levels of 1017 n/cm2 (E > 1 MeV) or greater. It is not clear to the staff that these statements are consistent, because the bases for the applicants claims were not adequately described in document L08-0607.
in element 4 of the LRA AMP it states that the augmented inspection program, which will be used to inspect the susceptible components, will be determined by the CR-3 ISI program manager and will consider recommendations from the GALL Report. In the GALL Report AMP it states that the augmented inspection program should be capable of detecting the critical flaw size with adequate margin. It is not clear to the staff that these statements are consistent, because the applicant has not provided any details on its ISI program to ensure that it will detect the critical flaw size with adequate margin.
During the audit of program element 10 the staff found that:
the operating experience identified by the staffs independent database search and supplemented by the applicant is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
the operating experience identified by the staffs independent database search and supplemented by the applicant is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit, the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1 and 4 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement adequately describes the program.
LRA AMP B.2.7, Flow-Accelerated Corrosion Program In the CR-3 LRA the applicant states that AMP B.2.7, Flow-Accelerated Corrosion [FAC]
Program is an existing program that is consistent with the program elements in GALL Report AMP XI.M17, Flow-Accelerated Corrosion. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.7. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keyword: flow-accelerated corrosion.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0610 License Renewal Aging Management Program Description Revision 2 of the Flow-Accelerated Program 7/8/2009
- 2. Action Request (AC) A steam leak was identified below an elbow at the top of Dec 2001 52145 MSR-3A
- 3. AR 56663 Three through-wall leaks developed in secondary pipe systems resulting in steam leaks; ASDT-3, HDV-66, and HDV-493. The damage mechanisms were not due to FAC, but rather impingement (HDV) and run to failure (ASDT-3)
- 4. EGR-NGGC-0202 Flow-Accelerated Corrosion Monitoring Program Revision 10
- 5. ESG000N Flow-Accelerated Corrosion (FAC) Program Manager Revision 0 Training Guide The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program.
During the audit, the staff found that:
elements 2, 4, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and sufficient information was not available to determine whether elements 1 and 3 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 1 and 3 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
In element 1 of the LRA AMP it states that the CR-3 FAC Program allows the use of later revisions to NSAC 202L. In the GALL Report AMP, revision 2 of NSAC 202L is
recommended. It is not clear to the staff that these statements are consistent because the documents may not be equivalent.
The LRA did not contain information regarding the accuracy of the FAC Program in predicting FAC degradation in components. In element 3 of the LRA AMP it states the FAC Program monitors the effects of FAC on the intended function of piping and components by measuring wall thickness. In the GALL Report AMP the effects of FAC on piping and components should be monitored by measuring wall thickness. It is not clear to the staff whether the FAC program is adequately predicting FAC degradation on wall thickness.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the standard review plan-license renewal and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1 and 3 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.8, Bolting Integrity Program In the CR-3 LRA, the applicant states that AMP B.2.8, Bolting Integrity is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M18, Bolting Integrity. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.8. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 1. This enhancement expands on the existing program element by including guidance for torquing and closure requirements based on the EPRI documents endorsed by the GALL Report.
The second enhancement affects LRA program element 2. This enhancement expands on the existing program element by identifying and removing instances where [a] molybdenum disulfide lubricant is allowed for use in specific procedures for bolted connections.
The third enhancement affects LRA program element 2. This enhancement expands on the existing program element by including guidance for torquing and closure requirements that include proper torquing of bolts and checking for uniformity of gasket compression after assembly.
The fourth enhancement affects LRA program element 2. This enhancement expands on the existing program element by including guidance for torquing and closure requirements based on the guidance of EPRI NP-5067, Good Bolting Practices, A Reference Manual for Nuclear Power Plant Personnel, Volumes 1 and 2.
The fifth enhancement affects LRA program element 3. This enhancement expands on the existing program element by including periodic ultrasonic examination of a representative sample of being identified as potentially having actual yield strength greater than 150 ksi.
The sixth enhancement affects LRA program element 4. This enhancement expands on the existing program element by including a centralized procedure based on EPRI NP-5067 and incorporating guidance regarding bolted joint leak tightness and pre-installation inspections consistent with the recommendation of this document.
The seventh enhancement affects LRA program element 4. This enhancement expands on the existing program element by including periodic ultrasonic examination of a representative sample of bolting identified as potentially having actual yield strength greater than 150 ksi. The applicant stated that the enhancement includes periodic in situ ultrasonic testing examinations of these bolts for stress corrosion cracking (SCC) or, alternatively, bolting may be removed for surface examinations or replaced.
The eighth enhancement affects LRA program element 5. This enhancement expands on the existing program element by performing examination of nuclear steam supply system (NSSS) support high strength bolting for SCC concurrent with examinations of the associated supports with a minimum frequency of once per 10-year inservice inspection period.
The ninth enhancement affects LRA program element 7. This enhancement expands on the existing program element by including guidance for torquing and closure requirements based on the recommendations of EPRI NP-5769.
The tenth enhancement affects LRA program element 7. This enhancement expands on the existing program element by utilizing the acceptance standards for high strength structural bolting that are consistent with the recommendations of EPRI NP-5769.
In the LRA transmittal letter dated December 16, 2008, the applicant committed to implement these enhancements prior to the period of extended operation.
During its audit, the staff interviewed the applicants staff, and reviewed on-site documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: bolt, corrosion, stress corrosion, crack, steam generator, manway, reactor coolant pump, pressurizer, boric acid, and leakage.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0633 License Renewal Aging Management Program Description of the Revision: 1 Bolting Integrity Program 11/13/2008
- 2. L07-0372 License Renewal Aging Management Review for the Reactor Revision: 2 Building, Section 6.3.14.14 Threaded Fasteners 12/03/2008
- 3. AR 00158342 SWHE-1C Expansion Joints Failed PMT Require Rework Revision: N/A 5/9/2005
- 4. AR 00037291 99-4692 While Placing SCHE-1B In Service A Large Break was Revision: N/A D 12/13/1999
- 5. AR 00299996 Discontinue Use of Molykote-G Lubricant Revision: N/A 7/10/2009
- 6. AR 00227062 SDP-2A Discharge Flange Is Leaking ~1 Drop per Second Revision: N/A 3/24/2007
- 7. AR 00033604 99-0633 CWV-195 Fasteners Have Broken Off At Both Ends Revision: N/A 2/24/1999
- 8. AR 00050122 MUH-80 Found with Loose Anchor Bolt Nut on Attachment Plate Revision: N/A 10/18/2001 The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff found that:
element 6 of the LRA AMP was consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether elements 1 - 5 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program elements, 1 - 5 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects. An issue regarding yield strength criterion for categorization of materials in terms of SCC susceptibility (> 150 ksi versus 150 ksi") was resolved during the audit and no RAI will be issued as described below in more detail:
In relation to element 2 of the LRA AMP, the applicant states that an enhancement will be made to identify and remove instances where [a] molybdenum disulfide lubricant is allowed for use in bolting applications in specific procedures and to add a specific prohibition against use of molybdenum disulfide lubricants in the CR-3 procedure for bolted connections. The staff noted that this enhancement is in agreement with the NRC staff findings summarized in the Conclusions section of NUREG-1339. However, the staff also noted that it should be clarified whether the molybdenum disulfide lubricant, which was used previously or is used currently, has caused detrimental effects on the bolting materials or not.
In relation with elements 1 and 3 - 5, LRA Appendix B, Section B.2.8 indicated that program enhancements will be made to perform periodic ultrasonic (UT) examination of a representative sample of bolting identified as potentially having actual yield strength >
150 ksi.
GALL Report AMP XI.M18 indicates that high strength low alloy steel with the actual yield strength 150 ksi may be subject to stress corrosion cracking (SCC). The Conclusions section of NUREG-1339 recommends that the yield strength criterion for categorization of materials in terms of SCC susceptibility should be based on actual measured yield strength (or yield strength determined by conversion of measured hardness values), but not on the specified minimum yield strength.
In contrast, the staff noted that on-site program document, L07-0372, License Renewal Aging Management Review for the Reactor Building, Revision 2, Section 6.3.14.14, Threaded Fasteners addressed a calculation of the maximum yield strength using the specified minimum yield strength and specified maximum and minimum tensile strength values as described on page 67 in relation with categorization of materials in terms of SCC susceptibility. This calculation suggests that the applicant might use specified yield and/or tensile strength values to calculate yield strength and the calculated yield strength might be used as input for SCC susceptibility categorization of materials.
Based on the foregoing information, the staff found a need to clarify whether the enhancements will be performed on the bolting with yield strength > 150 ksi or on the bolting with yield strength 150 ksi. In the further discussion with the applicant during the audit, the applicant agreed that the yield strength criterion should be corrected from
> 150 ksi to 150 ksi in a manner consistent with the recommendation of NUREG-1339 and the FSAR Supplement should be revised in a way to reflect the correction.
Therefore, no RAI will be issued for this specific topic.
However, the staff still needs to clarify how the yield strength of the bolting materials will be determined as input for the yield strength criterion to categorize materials in terms of SCC susceptibility (For example, based on actual measured yield strength, conversion of actual measured hardness, or specified values of yield strength, tensile strength and/or hardness in material specifications).
In relation with elements 1, 3 and 4, LRA Appendix B, Section B.2.8 and on-site program documentation indicated that program enhancements will use EPRI-5067 (EPRI NP-
5067, Volumes 1 and 2) as guidance for torquing and closure requirements and as a basis to develop a centralized procedure for joint leak tightness and pre-installation inspections.
GALL Report AMP XI.M18, Bolting Integrity, refers to EPRI NP-5769 and EPRI TR-104213 as guidance for industry recommendations. The staff also noted that EPRI NP-5769 Volume 1, Section 2 (page 2-8) states that EPRI NP-5067 will serve as a repository of useful information learned from EPRI experimental and analysis programs and will give the utility industry guideline. EPRI NP-5769 Volume 1, Section 2 also states that It is believed that the bolting reference manuals [NP-5067, Volumes 1 and 2]
will satisfy the industrys need for guidance in this area.
However, the staff noted that EPRI TR-104213, Section 1.1 indicates that the development objectives for TR-104213 were to update and consolidate the existing information (including NP-5067 and NP-6316) into a single document and to provide additional information necessary to allow a seamless integration of the material. The staff also noted that NUREG-1339 takes some exceptions for safety-related bolting to EPRI NP-5769 such as yield strength criteria for categorization of materials in terms of SCC susceptibility.
Therefore, the staff found a need to clarify whether EPRI NP-5769 with the exceptions noted in NUREG-1339 and EPRI TR-104213 will be considered and used as industry recommendations for the applicants enhancements as well as EPRI NP-5067 that the applicant is currently planning to use.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR Supplement was an adequate description of the LRA AMP.
A subject that required further clarification was whether the yield strength criterion for material categorization in terms of SCC susceptibility is based on yield strength > 150 ksi or yield strength 150 ksi. As described above, during the audit the applicant agreed that the yield strength criterion should be corrected from > 150 ksi to 150 ksi in a manner consistent with the recommendation of NUREG-1339 and the FSAR Supplement should be revised in a way to incorporate the correction. Therefore, no RAI will be issued for this specific topic.
In order to obtain the information necessary to verify the sufficiency of the FSAR Supplement program description, the staff may request additional information for the following subject as part of the RAIs for program element consistency evaluation as described above in more detail:
The staff found a need to clarify whether EPRI NP-5769 with the exceptions noted in NUREG-1339 and EPRI TR-104213 will be considered and used as industry recommendations for the applicants enhancements as well as EPRI NP-5067 that the applicant is currently planning to use. Depending on the final resolution on this topic, the FSAR Supplement in the submitted LRA will be kept as prepared or revised relevantly.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1 - 5 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the applicant has committed to modify the FSAR Supplement so as to make the program description adequate and identified a need for additional information regarding the adequacy of the program description in the FSAR Supplement LRA AMP B.2.9, Steam Generator Tube Integrity Program In the CR-3 LRA, the applicant states that AMP B.2.9, Steam Generator Tube Integrity Program is an existing program that is consistent with the program elements in GALL Report AMP XI.M19, Steam Generator Tube Integrity. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.9.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords: steam generator tube, eddy current, and primary secondary leak.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date License renewal aging management program description of the Revision 1
- 1. L08-0634 steam generator tube integrity program 11/13/2008
- 2. EGR-NGGC-0208 Steam generator integrity program Revision 6
Document Title Revision / Date Standard procedure 4/15/2009
- 3. AI-701 Administration of the ASME section XI and ASME OM Code - Revision 17 Plant operating Inservice inspection, examination and testing programs 8/14/2008 manual
- 5. CH-266 Revision 18 Plant operating Primary to secondary leak rate monitoring guideline 6/26/2009 manual
- 6. MNT-NGGC-0007 Revision 8 Foreign material exclusion program Standard procedure 9/10/2008
- 7. Inservice Eddy current data guidelines for the Once-Through Steam Revision 4 inspection manual Generator inservice inspection 10/22/2007
- 8. CP-152 Revision 19 Plant operating Primary to secondary leakage operating guideline 11/11/2008 manual
- 9. 51-9072151-000 A CMOA Evaluation of Steam Generator Tubing for Crystal Revision 00 Engineering River Unit 3 at 15R 2/27/2008 information record Once-Through Steam Generator Degradation Assessment for Revision 0
- 10. N/A Crystal River Unit 3 - Refueling outage 15 November 2007 Degradation Assessment for the CR3 replacement once- Revision 0
- 11. N/A through steam generators - Pre-service inspection June 2009 During the audit of program elements 1 - 6, the staff found that:
sufficient information was not available to determine whether elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 1 - 6 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
In element 1 of the LRA AMP it states that the Steam Generator Tube Integrity program is an existing program consistent with the recommendations of the GALL Report,Section XI.M19, Steam Generator Tube Integrity and it meets the intent of NEI 97-06 as recommended by the GALL Report. The aging management program states the program is consistent with the GALL Report with no exceptions. Element 1 of the GALL Report states that the licensees SG degradation management program is, in part, implemented in accordance with the Nuclear Energy Institute (NEI) 97-06, Steam Generator Program Guidelines. The GALL Report references revision 1 of these guidelines, whereas the applicants program documents, such as CR-3 program document, Nuclear Generation Group L08-0634, references revision 2 of NEI 97-06.
In elements 3, 4 and 6 the LRA AMP is supported by a standard procedure, EGR-NGGC-0208, which summaries all the aspects of the steam generator tube integrity program, such as inservice inspections, assessment of degradation mechanisms, plugging or repair, etc. During its review of this document and other procedures dealing with these elements, the staff noted that some definitions, criteria or expressions used by the applicant were too restricting or insufficiently documented to verify their consistency
with the requirements of the ASME Code or with the recommendations of the GALL Report. Thus, the staff may request further precision to confirm the consistency of the LRA AMP with the GALL Report AMP; Moreover, in a more general sense involving all the elements 1 - 6 (mainly element 6) of the LRA AMP, the applicant stated that the steam generator tube integrity program at CR-3 meets the intent of NEI 97-06 as recommended by the GALL Report. This program is supported by many implementing documents. During the review of the program and some of these documents, the staff identified numerous potential discrepancies within the same procedure, between different procedures, between the CR-3 procedures and various industry guidelines (referenced in NEI 97-06), and between the procedures and the technical specifications. These issues potentially concern all the elements 1 - 6 of the LRA AMP. Given the number of potential discrepancies, the staff may request the applicant to discuss its plans to perform a comprehensive review of its steam generator program to ensure the procedures are internally consistent, will ensure compliance with the technical specifications, and are consistent with NEI 97-06.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
identified certain aspects of LRA program elements 1 - 6 for which additional information or additional evaluation is required before consistency with the corresponding program elements in the GALL Report can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.10, Open-Cycle Cooling Water System Program In the CR-3 LRA, the applicant states that AMP B.2.10 Open Cycle Cooling Water System is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M20, Open Cycle Cooling Water System. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.10.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 2. This enhancement expands on the existing program element by adding periodic inspection/rebuild of RW pumps. This enhancement will be initiated during the current license period and will ensure that one or more pumps are inspected prior to the period of extended operation.
The second enhancement affects LRA program element 2. This enhancement expands on the existing program element by adding inspection of the RW discharge conduits prior to the period of extended operation.
The third enhancement affects LRA program element 2. This enhancement expands on the existing program element by adding periodic maintenance activities for expansion joints RWEJ-3 through 10.
In the LRA transmittal letter dated December 16, 2008 the applicant committed to implement these enhancements prior to the period of extended operation.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: clams, mussels, biofouling, pipe lining, microb, service water test, chlorination, bromination, and biofouling.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. PM-164 Raw Water Pipe Lining Inspection Revision 7 1/14/2008
- 2. PM-275 General Preventive Maintenance Work Revision 26 12/4/2008
- 3. AR149036149036 Service Water Reliability, GL 89-13 Program Assessment 9/26/06
- 4. EGR-NGGC-0008 Engineering Programs Rev 8 5/29/2008
- 5. CAP-NGGC-0202 Operating Experience Program Rev 15 5/27/2009
- 6. Response to Generic Letter 89-13 01/30/1990
Document Title Revision / Date
- 7. AR item 00033749 Clamtrol Ineffective 02/17/2000
- 11. AR item 00195143 Heat exchanger flaw evaluation 05/21/2006
- 12. AR item 00207935 Flume cleaning inspection 10/01/2006 The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff found that:
elements 1, 2, 3, and 5 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether elements 4 and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 4 and 6 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
LRA AMP program element 4 contains inspection techniques typically employed by generic letter 89-13 and which are consistent with the corresponding element in the GALL Report AMP. Section 7.5 of the applicants document L08-0613 (License Renewal Aging Management Program Description of the Open Cycle Cooling Water System Program) indicates that in addition to its normal uses, the LRA AMP will be used to detect selective leaching. The selective leaching AMP utilizes both visual inspection techniques and hardness/scratch tests to identify selective leaching. It is not clear to the staff that the LRA AMP will adequately detect selective leaching unless it is enhanced to include some form of hardness testing.
Section A.1.2.3.6 of the SRP-LR states that the program element acceptance criteria should contain information concerning the acceptance criteria against which the need for corrective action will be measured. This section of the SRP-LR also states that the acceptance criteria should consist of numerical values or methods by which they are determined. The staff notes that this information is absent from this section of the LRA AMP. In order for the staff to evaluate the consistency of this LRA program element with the corresponding GALL Report program element, it is necessary that the applicant provide this information in the LRA AMP.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the following subjects:
Assessment number 149036, Observation number JL06, Service Water Reliability, GL 89-13 Program Assessment indicates that the concrete lining is missing from some sections of the concrete lined, cast iron, 48 inch, piping. This assessment also indicates that the sections of the piping from which the concrete is missing are not being monitored for loss of material. Since the GALL Report AMP is designed to manage aging for lined piping and since corrosion of unlined piping is expected to be greater than for lined piping, it is not clear that the LRA AMP will adequately manage aging for the areas of pipe without concrete lining without additional inspection or control measures.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 4 and 6 for which additional information or additional evaluation is required before consistency can be determined; identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.11, Closed-Cycle Cooling Water System Program In the CR-3 LRA, the applicant states that AMP B.2.11, Closed-Cycle Cooling Water System Program is an existing program with exceptions that is consistent with the program elements in GALL Report AMP XI.M21, Closed-Cycle Cooling Water System. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.11. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first exception affects LRA program element 3. In the GALL Report AMP, this program element recommends that key parameters of the closed-cooling water pumps be monitored in accordance with the EPRI guidance. Alternatively, this program element in the LRA states that the Secondary Services Closed-Cycle Cooling Water and Industrial Cooling System pumps are not subject to a formal testing program.
The second exception also affects LRA program element 3. In the GALL Report AMP, this program element recommends that key parameters of the closed-cooling water heat exchangers be monitored in accordance with the EPRI guidance. Alternatively, this program element in the LRA states that the Secondary Services Closed-Cycle Cooling Water and Instrument Air Systems heat exchangers are not subject to a formal testing program.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: closed cycle water piping corrosion, crevice corrosion, pitting, cracking, fouling, biologically influenced corrosion, leakage, corrosion inhibitor, diesel engine jacket cooling water, compressor cooling water, hydrazine, nitrite, and glycol.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0614 License Renewal Aging Management Program Description of the Revision 1 Closed-Cycle Cooling Water System Program 11/13/2008
- 2. CP-160 Closed Cooling Water Systems Chemistry Program Guidelines Revision 10 11/05/2008
- 3. CH-400 Nuclear Chemistry Master Scheduling Program Revision 46 05/01/2009
- 4. No document # Crystal River-3 Optimized Closed Cycle Cooling Water Chemistry 02/11/09 Control Program
- 5. OP-410 Secondary Services Closed Cycle Cooling System Revision 63 11/06/2008
- 6. OP-411 Instrument and Station Air System Revision 98 06/15/2009
- 7. SP-349C EFP-3 and Valve Surveillance Revision 20 06/12/2009
- 8. SP-354A Monthly Functional Test of the Emergency Diesel Generator Revision 90 EGDG-1A 05/12/2009
- 9. SP-385A Control Complex Chiller (CHHE-1A) Functional Test Revision 8 04/07/2009
- 10. SP-395 CHHE-2 Appendix R Chiller Surveillance Revision 1 01/23/2008
- 11. AR 00161283 Rework Incurred on CHP-1A (to repair a leak in the pump casing) 06/15/05
- 12. AR 00163476 CHV-49 Is Leaking and the Valve/Piping Has Corrosion 07/13/05
- 13. AR 00173724 Rework - Jacket Coolant Leak during Restoration of EGDG-1B 10/21/05
- 14. NCR# 00034288 00-0939 SCV-81 Leak by Caused Fluctuations in the SC Header 06/21/2001 Pressure
- 15. NCR# 00067934 Benchmarking the CR-3 CCCW Chemistry Control Program against 02/27/2003
Document Title Revision / Date the Calvert Cliffs CCCW Chemistry Program
- 16. NCR# 00037837 00-0411 Increased Leakage from the Nuclear Closed Cycle Cooling 04/24/2004 System
- 17. NCR# 00038953 The Clamtrol Procedure Has not Been Integrated into the FPC 06/01/2001 System as a PM Procedure
- 18. NCR# 00040890 00-3219 Review of All Secondary Systems and Secondary Closed 03/08/2009 Cycle Cooling Water Chemistry Data from 07/25/00 to 11/20/00
- 19. NCR# 00041940 From a Minor Chemistry Self-Assessment Performed in February 10/24/2001 2001, There Were Several Items Identified Requiring Management Consideration.
- 20. NCR# 00042364 01-1183 Chemistry Minor Self-Assessment Identified that Total 06/29/2009 Sulfur Analysis Was Being Performed on the CI, DC-A, DC-B, SC, and SW Systems
- 21. NCR# 00042388 Minor Chemistry Self-Assessment of Closed Cycle Cooling Water 10/25/2001 System Chemistry Data for the Period of 1/25/01 - 4/18/01
- 22. NCR# 00094247 Nuclear Service Closed Cycle Branch Flow May Be Degraded 03/26/2007
- 24. NCR# 00185229 Nuclear Service System Leakage Discovered Elevated 03/27/2006
- 25. NCR# 00233519 Out-of-Spec SC Chemistry not Logged in the Autolog 08/16/2007
- 26. NCR# 00259954 SC System Hydrazine Concentration below Minimum Specification 01/09/2008
- 27. NCR# 00268185 SC Iron Concentration Is Out-of-Specification 04/16/2008
- 28. NCR# 00286693 Decay Heat A Closed Cycle Cooling Hydrazine OOS Low 07/22/2008
- 29. NCR# 00339342 DC System Morpholine Out-of-Spec High 06/17/2009
- 30. NCR# 00034595 99-1714 EGDG-1A Intercooler Coolant System Nalco 07/28/2008 Concentration above Limit
- 31. NCR# 00169953 Potential Safety Hazards when Ethylene Glycol Is Vaporized 05/14/2004
- 32. NCR# 00218008 Large Drops in Reported Tolytriazole in the Diesel Jacket Coolant 01/08/2008
- 33. NCR# 00033622 99-0641 CWV-195 Flange Face is MIC/Crevice Corroded 02/23/2007
- 34. NCR# 00277288 SWHE-1A Tubesheet Appears to Have Minor Dealloying 05/28/2009
- 35. NCR# 00036050 99-3629 Condenser Tube Eddy Current Results Show 5 Tubes 05/12/2009 Degraded
- 36. NCR# 00038304 00-0911 During Draindown of the SW Side of the Control Complex 06/01/2001 Chiller CHHE-1B, Some Foreign Material and Corrosion Products Were Dicovered
- 37. NCR# 00254799 FWHE-2B Eddy Current Results Show Degrdation 07/28/2008
- 38. NCR# 00033603 99-0620 RWP-1 Discharge Pressure Reached 32 psig due to the 06/01/2001 Combination of SWHE-1A Being OOS and Fouled Detailed Problem Description
- 39. NCR# 00033749 99-0955 Clamtrol is Ineffective Based on the Fouling Occurring in 06/01/2001 the SWHEs
- 40. NCR# 00039838 00-2385 SHWE-1A Was Determined to Be Fouled Based on RWP- 03/24/2008 1 Discharge Pressure
- 41. NCR# 00039845 00-2394 SWHE-1A Was Discovered to Be 46.8% Blocked 03/24/2008
- 42. NCR# 00039851 00-2408 SWHE-1B Was Found to Have 216 Tubes (39.6%) 03/24/2008 Blocked
- 43. NCR# 00040241 CW Box D Became Fouled without Being Identified under Trend 06/01/2002 Program
- 44. NCR# 00097740 Turbine Lube Oil Temperature Long Term Increasing Trend 12/18/2003
- 45. NCR# 00133068 OP-103B Immediate Actions for SWHE-1B Fouling not Met 09/15/2004
- 46. NCR# 00135456 SWHE-1D Fouling Exceeds Op-103B Limits 09/24/2004
- 47. NCR# 00172144 SCHE-1A Performance Appears to Be Degraded 11/18/2005
Document Title Revision / Date
- 48. NCR# 00812542 CIHE-10 Is Fouled with Unexpected Heavy Mineral Deposits 06/20/2008
- 49. NCR# 00243845 DCHE-1B As-Found Tube Blockage 11/06/2007
- 50. NCR# 00329555 IAHE-6B and IAHE-6C Chemistry Control 04/08/2009
- 51. NCR# 00196159 B-EGDG Jacket and Intercooler Ethylene Glycol High 11/10/2006
- 52. NCR# 00196172 EGDG-1B Glycol Coolant Concentration Exceeds Limit 06/05/2006
- 53. NCR# 00036547 99-3904 SWHE-1C Developed Approximately 1.5 gpm Tube Leak 03/24/2008
- 54. NCR# 00036689 99-4047 SW & CI Systems Contain Excessive Concentrations of 03/24/2008 Impurities due to Heat Exchanger Tube Leaks
- 55. NCR# 00038515 00-1197 Apparent Tube Leak in SWHE-1C 04/24/2004 rd
- 56. NCR# 00039264 SWHE-1D Has a 0.7 gpm Tube Leak. This Is the 3 SWHE to 03/24/2008 Develop a Tube Leak in a One-Week Period.
- 57. NCR# 00125800 SW System Leakage 07/16/2004
- 58. NCR# 00154891 SWHE-1B Leak on Cathodic Protection 04/06/2005
- 59. NCR# 00080854 Source of Fluoride Unknown in Plant Cooling Water Systems 02/03/2004
- 60. NCR# 00042300 01-1189 SWHE-1A Tube Leak 04/22/2004 The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of program element 3 of the LRA AMP associated with the exceptions were not evaluated during this audit. Aspects of these program elements that are not associated with the exceptions were evaluated and are described below During the audit, the staff found that:
elements 1 and 4 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and sufficient information was not available to determine whether elements 2, 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 2, 3, 5, and 6 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
The Closed-Cycle Cooling Water System AMP is structured by following the EPRI guidance. In its LRA CCCW AMP implementation procedures the applicant referenced EPRI Closed Cooling Water Chemistry Guideline, Revision 1, 10078020 (2004). In the GALL Report AMP it recommends EPRI TR-107396 (1997).
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 2, 3, 5, and 6 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.12, Inspection of Overhead Heavy Load and Light Load Handling Systems Program In the CR- 3 LRA, the applicant states that AMP B.2.12 Inspection of Overhead Heavy Loads and Light Load Handling Systems Program is an existing program that with enhancements is consistent with the program elements in GALL Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.12. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 1. This enhancement expands on the existing program element by adding all cranes that are within the scope of License Renewal.
The second enhancement affects LRA program element 3. This enhancement expands on the existing program element by adding requirements to notify the responsible engineer of unsatisfactory inspection results involving loss of material, including loss of material owing to wear of rails, for cranes in scope of License. This enhancement also adds all cranes that are within the scope of License Renewal.
The third enhancement affects LRA program element 4. This enhancement expands on the existing program element by adding revised administrative controls to clarify that crane rails are to be inspected for abnormal wear, and that members to be inspected for cracking include welds. This enhancement also adds revised administrative controls to specify frequency of
inspections for in-scope cranes to be every refueling outage for cranes inside the RB and every two years for cranes outside the RB.
During its audit, the staff conducted walkdowns of cranes, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords: overhead, heavy load, and crane.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. Technical Report: License Renewal Aging Management Program Description Revision 1 L08-0628 of the Inspection of Overhead Heavy Load and Light Load 11/12/2008 (Related to Refueling) Handling Systems
- 2. Procedure: CAP- Operating Experience Program Revision 15 NGGC-0202 No Date
- 3. Procedure: CAP- Corrective Action Program Revision 27 NGGC-0200 No Date
- 4. Procedure: CAP- Work Management Process Revision 33 NGGC-0104 No Date
- 5. Procedure: CAP- Condition Monitoring of Structures Revision 14 NGGC-0351 No Date
- 6. Procedure: PM-143 Check/Inspections and Maintenance of Whiting Cranes Revision 15
- 7. Procedure: PM-109 Check and Maintenance of Miscellaneous Cranes and Revision 20 Hoists
- 8. Procedure: OP- Operation of the Auxiliary Building Overhead Crane FHCR- Revision 30 421C 5 No Date During the audit of program elements 1 - 6, the staff found that:
elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report AMP; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the applicant has committed to modify the FSAR Supplement so as to make the program description adequate.
LRA AMP B.2.13, Fire Protection Program In the CR-3 LRA, the applicant states that AMP B.2.13, Fire Protection Program is an existing program with exceptions and enhancements that is consistent with the program elements in GALL Report AMP XI.M26, Fire Protection. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.13.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program elements 1 and 6. This enhancement expands on the existing program element by adding a procedure for periodic inspections for fire barrier walls, ceilings, and floors. In addition, a step to notify the Fire Protection personnel upon discovery of any deficiencies that may adversely affect the fire barrier function will be added to the inspection procedure.
The second enhancement affects LRA program elements 3 and 5. This enhancement expands on the existing program element by adding inspections for seal separation from walls and components, separation of layers of material, and rupture and puncture of seals due to age-related degradation phenomena.
The third enhancement affects LRA program elements 3 and 5. This enhancement expands on the existing program element by adding a visual inspection acceptance criterion for corrosion of fire doors.
The fourth enhancement affects LRA program element 4. This enhancement expands on the existing program element by adding a minimum qualification requirement for personnel performing visual inspections of penetration seals and fire doors.
In the LRA transmittal letter dated December 16, 2008 the applicant committed to implement these enhancements prior to the period of extended operation.
The first exception affects LRA program elements 3 and 4. In the GALL Report AMP, this program element recommends the Halon fire suppression system be visually inspected and functionally tested every six months. Alternatively, this program element in the LRA states that the Halon system is functionally tested every 18 months.
The second exception affects LRA program elements 4 and 5. In the GALL Report AMP, this program element recommends that the fire barrier walls, ceilings and floors are visually inspected at least once every refueling outage. Alternatively, this program element in the LRA states that the fire barrier inspection frequency is commensurate with the safety significance of the structure and its condition but not to exceed 10 years.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: fire door inoperability, corrosion or misalignment, fire barrier floors, walls, and/or ceilings spalling, cracking, or other openings, fire barrier penetration seals crack or harden, fire wraps, degradation, fire diesel fuel suppy, and Halon inoperable or malfunctioning.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L-08-0612 Licensing Renewal Aging Management Program Description of Revision 1 the Fire Protection Program 06/17/2009
- 2. 03-0920-1103 Crystal River Unit 3 Fire Hazard Analysis Revision 12 12/02/2008
- 3. C-FP-07-01 Fire Protection Assessment (Triennial) 05/10/2007
- 4. EGR-NGGC-0351 Condition Monitoring of Structures Revision 14 (no approval date)
- 5. No document # Crystal River Unit 3 Fire Protection Plan Revision 26 11/24/2008
- 6. SP-363 Fire Protection System Tests Revision 39 Date 09/23/2002
- 7. SP-365B Diesel Fire Service Pump, FSP-2A Operability Revision 19 Date 05/07/2008
- 8. SP-407 Fire and Flood Barrier Penetration Seals Inspection Revision 34 Date 12/15/2008
- 9. SP-408 Fire System Flow Test Revision 15 Date 10/17/2008
- 10. SP-501A Halon ASC Weight and Pressure Check Revision 12 Date 02/05/2009
- 11. SP-501B Halon System Functional Check Revision 16 Date 02/12/2008
- 12. SP-805 Monthly Surveillance of Plant Fire Doors Revision 31 Date 06/06/2007
- 13. SP-805A Annual Inspection of Plant Fire Doors Revision 18 Date 11/29/2004
- 14. SP-810 TSI Fire Barrier Check Revision 9 Date 03/25/2008
- 15. SP-810A Reactor Building Radiant Energy Shielding Revision 1
Document Title Revision / Date Date 05/16/1996
- 16. SP-820 Mecatiss Fire Barrier Inspection Revision 6 Date 04/03/2008
- 17. AR 00229364 SP-407 Contains Discrepancies in the Data Tables 04/12/2007
- 18. AR 00233770 Fire Barrier Penetration Seals Failed SP-407 05/21/2007
- 19. AR 00278197 Fire Barrier Penetration Seals PIB-37 & PIB-38 Are Breached 05/06/2008
- 19. AR 00278642 SP-407 Does Not Match Field Conditions for PIB-35 and PIB-36 05/08/2008
- 20. NCR# 00222352 New H202 Door Hinge Does not Align 03/23/2007
- 20. NCR# 00040283 00-0526 Fire Door C503 Upper Seal Is Degraded 06/01/2001
- 21. NCR# 00196743 Degraded CCHE Seals on Two Doors 07/14/2006
- 22. NCR# 00286627 Non-Fire Protection Plan Fire Door Degradation 02/16/2009
- 23. NCR# 00041461 00-3145 MeCatiss Fire Barrier Degraded 06/01/2001
- 24. NCR# 00225494 Unplanned FPP Entry - IB Fire Barrier PIB-37 & 38 Degraded 03/23/2007
- 25. NCR# 00035574 99-2809 Received Information from the Gator Team That Cable 12/03/2008 Tray 662 TSI Fire Barrier Material Had a Crack
- 26. NCR# 00040430 MeCatiss Fire Barrier Found Not Sealed from the Environment 06/01/2001
- 26. NCR# 00040928 00-3252 Unplanned MeCatiss Breach during Maintenance 06/01/2001
- 26. NCR# 00209449 MeCatiss Fire Barrier Apparently Damaged by Work Practices 12/20/2006
- 26. NCR# 00116984 Unexpected Inoperability of Fire Door C105 02/20/2004
- 27. AR 00134878 NFPA 72D - Recording of Signals & Recording Device Capability 08/16/04 The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of program elements 3 -
5 of the LRA AMP associated with the exceptions were not evaluated during this audit. Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.
During the audit, the staff found that:
elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.14, Fire Water System Program In the CR-3 LRA, the applicant states that AMP B.2.14, Fire Water System Program is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M27, Fire Water System. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A1.1.14. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 3. This enhancement expands on the existing program element by adding one or both of the following activities: (i) periodic flow testing consistent with the intent of NFPA 25, and (ii) a piping thickness evaluation to the fire water system piping.
The second enhancement affects LRA program element 4. This enhancement expands on the existing program element by adding a piping internal inspection requirement to verify that the intended function the piping has not been impaired due to loss of material.
The third enhancement affects LRA program element 4. This enhancement expands on the existing program element by adding an annual visual inspection of yard fire hydrants requirement to detect possible degradation.
The fourth enhancement affects LRA program element 4. This enhancement expands on the existing program element by adding a testing or replacing the sprinkler heads clause prior to reaching their 50th year of service.
In the LRA transmittal letter dated December 16, 2008, the applicant committed to implement these enhancements prior to the period of extended operation.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: fire water pipe
thinning, fire hydrant or sprinkler obstruction, scaling, corrosion, fouling, microbiologically influenced corrosion, fire water system degradation, and fire water system testing.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L-08-0611 Licensing Renewal Aging Management Program Description of the Revision 0 Fire Water System Program 11/13/2008
- 2. 03-0920-1103 Crystal River Unit 3 Fire Hazard Analysis Revision 12 12/02/2008
- 3. No document # Crystal River Unit 3 Fire Protection Plan Revision 26 11/24/2008
- 4. SP-363 Fire System Annual Valve Surveillance Revision 39 Date 09/23/2002
- 5. SP-367 Fire Service Valve Alignment and Operability Check Revision 35 Date 10/29/2008
- 6. SP-408 Fire System Flow Test Revision 15 Date 10/17/2008
- 7. SP-411D Fire Protection for Emergency Diesel Generators Revision 21 Date 03/19/2009
- 8. SP-802 Fire Hose Hydro Test and Hose Reel Inspection Revision 34 Date 06/17/2009
- 9. NCR# 00033340 99-0354 Fire Hydrant Removed not Conspicuously Marked as Out- 06/01/2001 of-Service
- 10. NCR# 00035742 99-2449 The Emergency Diesel Generator Coolant Samples 01/18/2002 Indicate the Presence of Microbiological Organisms
- 11. NCR# 00035820 99-3059 Operating Experience AI-404B Guideline Significant Event 07/23/2002 Notification 203 Rupture of Drain Line from Moisture Separator Reheater Drain Tank Due to Pipe Thinning
- 12. NCR# 00038814 High Aerobic Bacteria in DC-B System 03/08/2009
- 13. NCR# 00061957 Potential for Legionnaires Disease Exists at CR-3 06/07/2002
- 14. NCR# 00095648 FSV-834 Is Leaking Resulting in Isolation of Fire Hydrant 22 04/30/2004
- 15. NCR# 00224738 Continuous Water Flow from Fire Water System 12/26/2008
- 16. NCR# 00266312 FP Triennial Inspection - Sprinkler Head Obstruction 02/18/2008
- 17. NCR# 00291648 FSV-503 Seat Leakage 11/13/2008
- 18. NCR# 00306070 1 1/2 Sprinkler Header Obstruction in EDGB 1B Room 1/13/2009 The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of these program elements were evaluated and are described below.
During the audit, the staff found that:
elements 1 - 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP;
sufficient information was not available to determine whether element 4 of the LRA AMP was consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element number 4 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing an RAI for the following subject:
Testing or replacing the sprinkler heads after they have been in service for 50 years and repeating the same procedure at a ten-year interval thereafter. Element 4 of the LRA AMP states that the applicant is committed to either test or replace the sprinkler heads after they have been in service for 50 years. The subsequent test intervals will be based on the initial test results. In the GALL Report AMP states that the sprinkler heads will either be tested or replaced after 50 years of service and at a 10-year interval thereafter.
It is not clear to the staff that these statements are consistent because the applicants subsequent sprinkler heads replacement/testing frequency will be based on the initial test results, not at a fixed time interval of 10 years per NFPA 25 (2002).
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 4 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B2.15, Aboveground Steel Tanks Program In the CR-3 Nuclear Power Plant LRA, the applicant states that AMP B2.15, Aboveground Steel Tanks Program, is a new program that is consistent with the program elements in GALL Report AMP XI.M29, Aboveground Steel Tanks. The applicant committed to implementing this program prior to the period of extended operation, as stated in LRA Commitment No. 10 in the applicants letter dated December 16, 2008. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.15. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns of the condensate storage tank and fire service water storage tank facilities, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords storage tank, tank rust, and fire service water.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0621 License Renewal Aging Management Program Description of Revision 0 the Aboveground Steel Tanks Program
- 2. AI-1701 System Engineering Standards Revision 9
- 3. EGR-NGGC-0351 Condition Monitoring of Structures Revision 14
- 4. Work Request 0349224 Holes Found in Bottom of Condensate Storage Tank 1997
- 5. Action Request 62846 Internal Inspection of Fire Service Water Storage Tank 1B 2002
- 6. Action Request 131424 External Inspection of Fire Service Water Storage Tank 1A 2004
- 7. Action Request 160289 External Inspection of Fire Service Water Storage Tank 1A 2005
- 8. Action Request 175027 Imperfections in Floor Coating of Condensate Storage Tank 2005
- 9. Action Request 183041 External Coating Repair Identified Rust on Fire Service Water 2006 Storage Tank Vents
- 10. Action Request 220826 External Inspection of Fire Service Water Storage Tank 1B 2007
- 11. Action Request 261231 External Inspection of Fire Service Water Storage Tank 1B 2008 During the audit of program elements 1 - 6, the staff found that:
elements 1, 2, 3, and 6 of the LRA were consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether elements 4 and 5 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program elements 4 and 5 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing an RAI for the following subject:
In the GALL Report AMP XI.M29, the effects of corrosion on the aboveground steel tanks are detectable by (i) periodic system walkdowns during each outage to monitor degradation of the external coating on the tank surface and the sealant at the metal-concrete interface and (ii) thickness measurement of the tank bottom to assess the underground surface condition. The applicant states that tank bottom surface thickness measurement and internal visual inspections will be performed using the planned preventive maintenance activities. It is not clear to the staff how tank bottom thickness measurement and internal visual inspection and the frequency of these procedures will adequately detect and manage aging effects during the period of extended operation.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit, the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 4 and 5 for which additional information is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging. The staff further verified that the description provided in the FSAR Supplement is an adequate description of the program; and verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.16, Fuel Oil Chemistry Program In the CR-3 LRA, the applicant states that AMP B.2.16, Fuel Oil Chemistry is an existing program with enhancements and exceptions that is consistent with the program elements in
GALL Report AMP XI.M30, Fuel Oil Chemistry. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.16.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program elements 2 and 4. This enhancement expands on the existing program element by adjusting the inspection frequency for the diesel-driven emergency feedwater pump fuel oil storage tank to ensure an inspection is performed prior to the period of extended operation.
The second enhancement affects LRA program elements 2 and 4. This enhancement states that the internal surfaces of the diesel-driven fire pump fuel oil storage tanks will be inspected and develop a work activity to periodically inspect the internal surfaces of these tanks. Prior to the inspection, fuel, water and sediment will be removed as much as practical due to limited access. UT or other NDE will be performed if visual inspection proves inadequate or indeterminate.
In the LRA transmittal letter Dated December 16, 2008 the applicant committed to implement these enhancements prior to the period of extended operation.
The first exception affects LRA program element 1. In the GALL Report AMP, this program element recommends the use of American Society for Testing and Materials (ASTM) Standards D1796, D2276, D2709, D6217 and D4057. Alternatively, this program element in the LRA states CR-3 uses ASTM standards D2709 and D2276 instead of D1796 and D6217, respectively.
The second exception affects LRA program element 2. In the GALL Report AMP, this program element recommends periodic cleaning and draining of water collected at the bottom of tanks.
Alternatively, this program element in the LRA states that water is not periodically drained from the bottom of the Diesel-Driven Emergency Feedwater and Fire Pump Oil storage Tanks.
Instead, the tanks are recirculated (Emergency Feedwater tank) and are sampled quarterly (Fire tank) to determine water buildup.
The third exception affects LRA program element 3. In the GALL Report AMP, this program element recommends the use of ASTM D2276, Method A, D2709 and D1796. Alternatively, this program element in the LRA states that CR-3 uses D2276-91 instead of ASTM D2276, Method A.
The fourth exception affects LRA program element 4. In the GALL Report AMP, this program element recommends the use of periodic multilevel sampling to assure that fuel oil contaminants are below unacceptable levels. The GALL also recommends the performance of ultrasonic testing of the tank bottom surface to assure that significant degradation is not occurring.
Alternatively, this program element in the LRA states that CR-3 does not perform multilevel sampling instead performs a two-volume recirculation of the Diesel-Driven Emergency Feedwater Pump and Fire Pump Fuel Oil Storage Tanks. The LRA states that this action provides for sampling of mixed contents. In addition, the LRA states that routine sampling is not performed on the Emergency Diesel Fuel Oil Day Tanks; instead, the Day tank fuel volumes are
cycled and refreshed each month during the Emergency Diesel surveillance runs. Furthermore, this program requires ultrasonic testing be performed only if visual inspections reveal significant internal damage due to loss of material.
The fifth exception affects LRA program element 6. In the GALL Report AMP, this program element recommends the use of ASTM D2276, Method A, D2709 and D1796. Alternatively, this program element in the LRA states that CR-3 uses D2276-91 and D2709 instead of ASTM D2276, Method A, and D1796, respectively.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: fuel oil, sulfur, biodiesel.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. License Renewal Aging Management Program Description Revision 1 L08-06022 of the Fuel Oil Chemistry Program
- 2. NCP-G-0001 Common Diesel Fuel Oil (Grade 2-D) Testing Specification Revision 3
- 3. 2602.102-02 Flow Accelerated Corrosion Susceptibility Non-modeled Revision 0 (SNM) Program Sept 19, 2008
- 4. 2602.102-01, Flow Accelerated Corrosion Susceptibility Evaluation (SSE) Revision 0, Sept 19, 2008
- 5. Non-Conformance Deteriorating condition of the tank with sediment and May 20, 2009 Report (NRC) 313507 potential loss of tank material
- 6. NCR 309256 Deteriorating condition of the tank with sediment and potential loss of tank material
- 7. Analysis Results 3-FST-2B Offsite-Particles Graph
- 8. Analysis Results 3-FST-2A Offsite-Particles Graph
- 9. Testing Laboratory No. 2 Diesel Fuel Results The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.
During the audit, the staff found that:
elements 1 - 6 of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the following subjects:
The LRA did not provide information discussing the concerns of Information Notice 2009-02 and the acceptable or unacceptable use of bio-diesel at CR-3.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the standard review plan-license renewal and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report; identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant to detect and manage aging can be reached; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.18, One-Time Inspection Program In the CR-3 LRA, the applicant stated that AMP B.2.18, One-Time Inspection Program is a new program that is consistent with the program elements in GALL Report AMP XI.M32, One-Time Inspection. The applicant committed to implementing this program prior to the period of extended operation. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.18. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: one, time, one-time, and inspection.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date License Renewal Aging Management Program Description of One
- 1. L08-0624 Rev. 1 Time Inspection Program
- 2. NGGM-PM-0011 Nuclear NDE Manual Rev. 60 License Renewal Aging Management Program Description of
- 3. L08-0601 Rev. 1 Water Chemistry Program License Renewal Aging Management Program Description of
- 4. L08-0631 Rev. 1 Lubricating Oil Analysis Program Action Request - Key Project Attributes Required for Successful
- 5. AR215536215536 12/06/2006 Completion of the Ten Year ISI Project During the audit of program elements 1 - 6, the staff found that:
elements 1 - 6 were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report;
verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.19, Selective Leaching of Materials Program In the CR-3 LRA, the applicant states that AMP B.2.19 Selective Leaching of Materials Program is a new program that is consistent with the program elements in GALL Report AMP XI.M33, Selective Leaching of Materials, with one exception. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.19. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of the exception. Issues identified but not resolved in this report are addressed in the SER.
The exception affects LRA program elements 1, 3, and 4. In the GALL Report AMP XI.M33, these program elements recommend a one-time inspection consisting of a visual inspection and hardness measurement to identify the presence of selective leaching. Alternatively, these program elements in the LRA state that a qualitative determination of selective leaching may be used in lieu of the hardness testing to determine if selective leaching is present. This would permit other mechanical means, i.e., scraping, or chipping.
During its audit, the staff conducted interviews of the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: selective leaching, dealloying, decarbonization, and dezincification.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. Calculation No. L08- License Renewal Aging Management Program Description for Revision 0625 Selective Leaching of Materials Program 11/21/2008 The staff conducted its audit of LRA program elements 1 - 6 without considering aspects of program elements 1, 3, and 4 of the LRA AMP which are associated with the exception.
Aspects of these elements not associated with the exception were evaluated and are described below.
During the audit, the staff found that:
elements 2 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP;
sufficient information was not available to determine whether element 1 of the LRA AMP is consistent with the corresponding element of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element number 1 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
In element 1 of the LRA AMP, brackish water is not specifically identified as an environment managed by this AMP. In the GALL Report AMP, brackish water is identified as an environment that the AMP is intended to address. It is not clear to the staff that these statements are consistent.
During the audit of program element 10 the staff found that:
The operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
The operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the following subjects:
The LRA information regarding program element 10, industry experience is not addressed, and in the supporting calculation, industry experience beyond Progress Energy plants is not addressed. It is not clear to the staff that the industry operating experience and practices beyond CR-3 and other Progress Energy plants will be utilized for this AMP.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 1 for which additional information or additional evaluation is required before consistency can be determined; identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached;
verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.20, Buried Piping and Tanks Inspection Program In the CR-3 LRA, the applicant states that AMP B.2.20, Buried Piping and Tanks Inspection is a new program that is consistent with the program elements in GALL Report AMP XI.M34, Buried Piping and Tanks Inspection. The applicant committed to implementing this program prior to the period of extended operation in commitment number 15 which was provided in the LRA transmittal letter dated December 16, 2008. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.20.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords:
cathodic, microb, mic, buried, buried coatings, and buried corrosion.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. EGR-NGGC-0513 License Renewal Buried Piping and Tanks Inspection Program Revision 1 1/15/2008
- 2. EGR-NGGC-0209 Buried Piping Program Revision 0 9/15/2008
- 3. SP-2891-1 Field Fabrication and Erection of Piping Specification Add O 2/17/75
- 4. SP-5206 CR3 Piping Specification Rev 9 6/15/2009
- 5. RO-2961 Requirement Outline for Underground Oil Tanks 1972
- 6. Diesel Fuel Storage Tanks DFT-1A and DFT-1B Modified API-653 Nov 2007 Tank Inspection and Integrity Assessment
- 7. AR 262706262706 Benchmark Report for Buried Piping Users Group Feb 2008
- 8. SP-349C EFP-3 and Valve surveillance Rev 18 6/12/2009
- 9. SP-5629 Specification Excavation and Placement of Structural Fill Add C 05/14/73 During the audit of program elements 1 - 6, the staff found that:
elements 1 - 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and
sufficient information was not available to determine whether element 4 of the LRA AMP was consistent with the corresponding element of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element number 4 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing an RAI for the following subject:
Section A.1.2.3.4 of the SRP-LR states that the program element detection of aging effects should contain information concerning the frequency, extent, sample size and methods used to detect aging. The staff notes that much of this information is absent from this section of the LRA AMP. Based on its review of the applicants reference document EGR NGGC-513, the staff also notes that some, but not all, of this information is provided for one of the other Progress Energy Plants. In order for the staff to evaluate the consistency of this LRA program element with the corresponding GALL Report program element, it is necessary that the applicant provide information concerning at least the number of inspections to be performed (sample size), the increase in sample size should a defect be discovered, and the minimum size of each excavation.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 4 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.21, One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program In the CR-3 LRA, the applicant stated that AMP B.2.21 is a new program that is consistent with the program elements in GALL Report AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping. The applicant committed to implementing this program, and inspections completed and evaluated, prior to the period of extended operation in 2016. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.21. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: one, time, one-time, inspection, and small-bore.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date License Renewal Aging Management Program Description of the
- 1. L08-0627 One-Time Inspection of ASME Code Class 1 Small-Bore Piping Rev. 1 Program
- 2. NGGM-PM-0011 Nuclear NDE Manual Rev. 60 Action Request - NEI 03-08 Needed Thermal Fatigue
Action Request - Key Project Attributes Required for
- 4. AR215536215536 12/06/2006 Successful Completion of the Ten Year ISI Project During the audit of program elements 1 - 6, the staff found that:
elements 1, 2, 3, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether elements 4 and 5 of the LRA AMP were consistent with the corresponding element of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 4 and 5 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
Element 4 of the LRA AMP states that small bore socket welds will be excluded from the volumetric examination. In the GALL Report AMP it recommends one-time volumetric inspection of small bore piping. The staff will consider issuing an RAI requesting
technical basis why small bore socket welds are excluded from the volumetric examination.
Element 5 of the LRA AMP did not provide information regarding weld population, and inspection sampling location and size. In the GALL Report AMP it recommends that this inspection be performed at a sufficient number of locations to assure an adequate sample. The staff will consider issuing an RAI requesting information regarding the inspection sampling size and locations, and its methodology.
During the audit of program element 10 the staff found that:
the operating experience identified by the staffs independent database search and supplemented by the applicant is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience identified by the staffs independent database search and supplemented by the applicant is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 4 and 5 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.22, External Surfaces Monitoring Program In the CR-3 LRA, the applicant states that AMP B.2.22, External Surfaces Monitoring is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M36, External Surfaces Monitoring. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and the description of the program as contained in the updated FSAR Supplement. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 1. This enhancement will enhance implementing procedures to ensure that the program encompasses all of the systems and components that credit the program for aging management.
The second enhancement affects LRA program element 1. This enhancement will enhance program procedures to include inspection attributes adequate for identifying aging effects for the ranges of materials and aging effects within the scope of the program.
The third enhancement affects LRA program element 1 and 4. This enhancement will enhance implementing procedures to include measures to assure that aging effects are managed on surfaces that are inaccessible or not readily visible during both plant operations and refueling outages, such that assurance is provided that applicable components will perform their intended function during the period of extended operation.
The fourth enhancement affects LRA program element 3. This enhancement will enhance the program procedures to detect aging effects/mechanisms and qualify degradations consistent with the demand of components crediting the External Surfaces Monitoring Program for aging management. Indentified aging effects include loss of material, hardening and loss of strength of elastomers, and reduction of heat transfer caused by fouling.
In the LRA transmittal letter dated December 16, 2008, the licensee committed to implement the enhancements listed in the LRA prior to the period of extended operation.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: corrosion, together with copper, and aluminum, and stainless. This effort yielded three hits (two for copper and one for stainless steel) covering an 8 year period. The exercise was repeated for the same commodities, but now the keyword degradation replaced corrosion. This time, there were no hits. The coupling of degradation and elastomer, however, yielded one nuclear condition report (NCR). A further search of the database produced the following results: for keyword rust, 293 hits; for keywords oxidation, 11; for corrosion, 304; for wastage, 14; for flaking, 7; and for loss of material, 4. Searches in the database with the keywords: reinforced plastics and thermoplastics yielded no hits. In contrast, searches in the database for fiberglass, plastics, and PVC, yielded respectively 27, 172, and 29 hits. A search for leakage produced 2,438 hits. Upon closer examination of the search results, it appears not all of the NCRs are specific to CR-3 and only few relate to this particular AMP. Moreover, not necessarily the keywords used in this search, in congruence with the intent of the AMP, maybe used in the same context by the plant.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. NGG L08-0635 License Renewal Aging Management Program description Revision 1 of the External Surfaces Monitoring Program - Nuclear 11/14/2008 Generating Group (NGG)
- 2. CAP-NGGC-0202 Operating Experience Program Revision 15
- 3. EGR-NGGC-0504 Mechanical Systems Aging Management Review for Revision 8 License Renewal
- 4. FSAR, Section 1.7 Quality Program (Operational) Revision 31
- 5. ADM-NGGC-0101 Maintenance Rule Program Revision 20
- 6. ADM-NGGC-0104 Work Management Process Revision 33
- 7. AI-605A Predictive Maintenance Program Revision 6
- 8. EGR-NGGC-003 Design Review Requirements Revision 10
- 9. ESG0081N System Engineering Self Study. Common ESP Training Revision 1 Guide 07/01/2008
- 10. AI-1701 System Engineering Standards Revision 9
- 11. TRN-NGGC-0007 Engineering Support Personnel Training/Qualification Revision 6 Program & Common Qualification Process
- 12. C-ES-07-01-R1; Engineering Self-Assessment, CR3 Engineering Section Revision 1 CNAS 2007-24 04/03/2007
- 13. NCR-00174509 Inactive leaks w/Boron deposits 14R Mode 3 Walkdown 12/09/2005
- 14. NCR-00174506 Active leaks w/Boron deposits 14R Mode 3 Walkdown 01/04/2006
- 15. NCR-00161869 MUP Cyclone separator material discrepancy 06/27/2005
- 16. NCR-00134899 Wastage noted on isolation valve for WD-89-PT 08/24/2004
- 17. NCR-00064756 CWCR-1 Support track and baseplate corroded 12/26/2002
- 18. NCR-00038260 Loose urethane liner (writeup describes rusted piping) 06/01/2001
- 19. NCR-00036438 CRDM Motor tube housing has rejectable flaw indication 06/01/2001 (writeup describes wastage)
- 20. NCR-00035208 Operating experience (OE) entry (global) 01/18/2007
- 21. NCR-00255531 CWP-1D Scope decision making (loss of metal) 11/13/2008
- 22. NCR-00328103 Surface corrosion on EF piping in EFP-3 building 04/01/2009
- 23. NCR-00228856 Observed crack in flood protection wall near door 9 05/08/2007 (potential rebar oxidation)
- 24. NCR-00176060 CD-61-LT2 Incorrectly terminated in NNI cabinet (oxidation 12/09/2005 of electronic circuitry)
- 25. NCR-00034354 Battery cells do not meet cleanliness criteria 06/01/2001
- 26. NCR-00228811 Ineffective scheduling for rotation of CC Chillers 06/19/2007 (steel/copper interaction)
- 27. NCR-00035565 Flaking paint on the South end of spent fuel pool floor of the 10/19/2003 auxiliary building
- 28. NCR-00107952 Unqualified coatings in RB - small quantity of paint on 11/28/2005 actuators is flaking
- 30. NCR-00107955 Failed (flaking) CLASS 1 concrete coatings in RB 10/26/2003 The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff found that:
elements 2 and 4 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether element 1, and 3 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 1 and 3 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing a RAI for the following subjects:
The program took no exception to the added range of materials (stainless steel, aluminum, copper, elastomers, PVC, thermoplastics, fiberglass and fiber reinforced plastics) identified in Nuclear Generating Group (NGG) document L08-0635, Revision 1, dated 11/14/2008 (see item 1 in the table below), and provided by the applicant as calculation for License Renewal Aging Management Program during the on-site audit.
Traditionally, the staff considered the addition of the above materials included by CR-3 in the LRA to be an exception to the GALL Report AMP, because it is virtually impossible for the applicant to ascertain integrity of the above commodities used in systems, structures, and components (SSCs) by applying the same examination methods called for in GALL Report AMP XI.M36, i.e. visual inspections. This exception affects LRA program element 1 and 3.
In program element 1 in the LRA, the applicant extends the scope to include a range of materials for all of the systems and components that credit the Program. According to program element 3 of the LRA, the applicant intends to monitor hardening, loss of strength, and fouling. The applicant presents these disparities from the GALL to be enhancements to the AMP. In the GALL Report AMP, program element 1 requires the monitoring of only steel and ferrous based commodities in SSCs for corrosion; while element 3 limits identification of corrosion and corrosion stains on insulated surfaces, wastage, leaks on external surfaces, protective coating degradation to visual inspections. It is not clear to the staff that these statements are consistent because this AMP should focus only on identifying rust/corrosion in steel and ferrous based materials.
During the audit of program element 10, the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider adding in the proposed RAI stated above the following:
How does the applicant track and identify:
- loss of strength or hardening in elastomers?
- wastage, loss of strength, loss of material in the included non-metallic materials?
The staff also audited the description of the LRA AMP provided in the updated FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1 and 3 for which additional information or additional evaluation is required before consistency can be determined; identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.23 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program In the CR-3 LRA, the applicant states that AMP B.2.23 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components is a new program that is consistent with the program elements in GALL Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. The applicant committed to implementing this program prior to the period of extended operation in CR-3 License Renewal Commitments. To verify this claim of consistency the staff audited the LRA AMP in LRA Section A.1.1.23. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: internal surface, degradation, and internal degradation.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. Calculation No. L08- License Renewal aging Management Program Description of the Revision 1 0630 Inspection of Internal Surfaces in Miscellaneous Piping and 12/12/2008 Ducting Components Program
- 2. EGR-NGCC-0512 Licensing Renewal Aging Management Activities Revision 4 During the audit of program elements, the staff found that:
Program elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 the staff found that:
the operating experience identified by the staffs independent database search and supplemented by the applicant is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience identified by the staffs independent database search and supplemented by the applicant is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.24, Lubricating Oil Analysis Program In the CR-3 LRA, the applicant states that AMP B.2.24, Lubricating Oil Analysis Program is an existing program with an exception that is consistent with the program elements in GALL Report of AMP XI.M39, Lubricating Oil Analysis Program. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the
description of the program as contained in the updated FSAR Supplement. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The program takes an exception to the GALL Report AMP on the measurement of the flash point on a periodic basis. This exception affects LRA program element 3. In the GALL Report AMP, this program element recommends that components that do not have regular oil changes, the use of oil viscosity, neutralization number, and flash point can be used to verify the suitability and continued use of lube oil. A Change in flash point value usually indicates oil contamination or degradation.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed on-site documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: lube oil, combined, one at a time, with water, zinc, silver, particles, ferrous, and contamination. The search yielded 12 nuclear condition reports (NCRs) covering an eight year period. Because of the lack of results, an additional search was conducted using the keywords lube oil and circulating water, with and without the keyword pump. Additionally lube oil, was paired successively with outboard motor, stainless steel, gray cast iron, carbon steel, copper, and aluminum. This search resulted in 6 NCRs.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. NGG L08-0631 License Renewal Aging Management Program Description Revision 1 of the Lubricating Oil Analysis Program - Nuclear 11/19/2008 Generation Group (NGG)
- 2. External Web Page Decoding the ISO Cleanliness Code Retrieved (http://www.polarislabs1.com) 07/21/2008
- 3. CHE-NGGC-0009 Particle Count in Lubricating Oils - Plant Operating Manual Revision 4 05/31/2006
- 4. PM-133 Equipment Lubrication and General Inspection - Plant Revision 60 Operating Manual 03/14/2007
- 5. AI - 605A Predictive Maintenance Program (PdM) - Plant Operating Revision 6 Manual
- 6. Internal Web Page Vibration & Oil Sample Guidebook Retrieved (In NGG L08-0631 Records) 07/17/2009
- 7. Assessment No: Predictive Maintenance - Lubricating Oil & Analysis; Self- Revision 12 SAST-351940; Assessment and Benchmark Programs (Debrief Notes) 09/15/2008 CAP-NGGC-0201
- 8. Lab Unit ID: ARP1A/172 Lubrication DATA Sheet - Equipment Tag ID: ARP-1A; PMP 07/16/2009
- 9. To be inserted in a Newly Equipment Issue Monthly Report 07/06/2009 Created DataBase
- 10. To be inserted in a Newly Oil Sampling Guidelines Revision 2 Created DataBase
- 11. ADM-NGGC-0104 Work Management Process Revision 33
- 12. NCR-140546 Lube Oil Analysis Results CHHE-1A 10/19/2004
- 13. CHE-NGGC-0001 Chemistry Laboratory Services Quality Control Revision 7
Document Title Revision / Date
- 14. CHE-NGGC-0012 Flash Point for Petroleum Products Revision 4
- 15. EGR-NGGC-0008 Engineering Programs Revision 8
- 16. EPRI-1003085 Lubrication Guide (Formerly NP-4916-R2) Revision 3 10/01/2001
- 17. EPRI-NP7205 Predictive Maintenance Primer Revision 3 04/01/1991
- 18. ESG0034N Lubrication Technology Training Guide Revision 1 07/07/2008
- 19. MCP-NGGC-0003 NGG Control of Testing and Related Activities in Chemistry Revision 11 Services and Metallurgical Services
- 20. NGGM-PM-0007 Quality Assurance Program Manual, Nuclear Oversight Revision 15 Department
- 21. NCR283696 CCJ Filtration System (Steam Turbine, Power Generation) 06/18/2008 Lube Sample Results, Polaris Labs
- 22. Polaris Laboratories CWP 1D In-Board Motor Bearing, Fluid Analysis Report 06/05/2009 TRACKING No: 09091Y02690 (I/B Motor Sleeve Bearing, Power Generation)
- 23. Polaris Laboratories CWP 1D Out-Board Motor Bearing, Fluid Analysis Report 06/08/2009 TRACKING No: 09091Y02696 (Kingsbury Thrust Sleeve Bearing, Power Generation)
- 24. Polaris Laboratories CWP 1C In-Board Motor Bearing, Fluid Analysis Report 06/08/2009 TRACKING No: 09091Y02688 (I/B Motor Sleeve Bearing, Power Generation)
- 25. Polaris Laboratories CWP 1C Out-Board Motor Bearing, Fluid Analysis Report 06/08/2009 TRACKING No: 09091Y02767 (O/B Motor Ball Bearing, Power Generation)
- 26. Polaris Laboratories CWP 1B In-Board Motor Bearing, Fluid Analysis Report 06/08/2009 TRACKING No: 09091Y02766 (I/B Motor Sleeve Bearing, Power Generation)
- 27. Polaris Laboratories CWP 1B Out-Board Motor Bearing, Fluid Analysis Report 06/05/2009 TRACKING No: 09091Y02692 (Kingsbury Thrust Sleeve Bearing, Power Generation)
- 28. Polaris Laboratories CWP 1A In-Board Motor Bearing, Fluid Analysis Report 06/08/2009 TRACKING No: 09091Y02697 (I/B Motor Sleeve Bearing, Power Generation)
- 29. Polaris Laboratories CWP 1A Out-Board Motor Bearing, Fluid Analysis Report 06/08/2009 TRACKING No: 09091Y02691 (O/B Motor Ball Bearing, Power Generation)
- 30. AR-135940135940 Performance Self-Assessment for PdM Lube Oil Program Origination Date 08/27/2004
- 31. AR-155651155651 Lubrication Program Self-Assessment (Series) Origination Date 04/05/2005
- 32. AR-155662155662 Lubrication Program Self-Assessment (Series) Origination Date 04/05/2005
- 33. AR-217281217281 PdM Program Weakness (Collection of Vibration DATA and Origination Date Lube Oil Samples) (Series) 12/22/2006
- 34. NCR-140546 Lube Oil Analysis Results CHHE-1A 10/19/2004
- 35. NCR-279035 Small Amount of Water Found in EDG-1A Crankase Sump 06/20/2008
- 36. NCR-296854 Turbine Lube Oil Water Content 01/23/2009
- 37. NCR-097740 Turbine Lube Oil Temperature Long Term Increasing Trend 12/18/2003
- 38. NCR-077849 Lube Oil Analysis of DCP-1A Pump Reservoir 05/06/2003
- 39. NCR-138396 Oil Analysis Indicates Increase in Wear Particles for SW1-B 02/072005
- 40. NCR-038715 AHF-1A, B, and C Inboard and Outboard Motor Bearing 08/08/2003 The staff conducted its audit of LRA program elements 1 - 6 without considering aspects of program element number 3 of the LRA AMP which are associated with the exception. Aspects of this elements not associated with the exception were evaluated and are described below.
During the audit, the staff found that:
elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 the staff found that:
The operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
The operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B2.25, ASME Section XI, Subsection IWE Program In the CR-3 LRA, the applicant states that AMP B2.25-01, ASME Section XI, Subsection IWE Program is an existing program that is consistent with the program elements in GALL Report AMP XI.S1, ASME Section XI, Subsection IWE. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.25.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords: IWE, liner plate corrosion, liner plate degradation, and moisture barrier.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0616 ASME Section XI, Subsection IWE Aging Magement Revision 1 Program November 12, 2008
- 3. AR 256012256012 Various Areas of The RB Moisture Barrier Are Degraded May 21, 2008
- 4. REA-1217 Evaluation of the liner plate September 9, 1997 During the audit of program elements 1 - 6, the staff found that:
element 2 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; elements 1, and 3 - 6 of the LRA AMP were not strictly consistent with the corresponding elements of the GALL Report AMP but that sufficient information was available to allow the staff to determine that these elements of the LRA AMP are equivalent to the corresponding elements of the GALL Report AMP.
The basis for the staffs determination that elements 1, and 3 - 6 of the LRA AMP are equivalent to the corresponding GALL Report AMP is:
During the audit, the staff noted that the applicants AMP is based on the 2001 Edition, 2003 Addenda of the ASME code while the elements 1, and 3 - 6 of the GALL Report use excerpts of the 1995 Edition. The applicant compared the elements of their program against the 2001 Edition of the ASME code, which is referenced in the GALL Report Program description. The staff finds this acceptable because it compares the applicants AMP to their current code edition approved under 10 CFR 50.55a and captures the intent of the GALL Report.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the following subjects:
The containment liner was found to be degraded in 1997 adjacent to the moisture barrier which is located at the junction of containment shell and base slab. The measured thickness at one of the degraded area was 21 percent less than the original thickness.
The staff may request the applicant to provide the details of any examination/
measurements of the degraded area since 1997 as recommended in ASME Section XI, Subsection IWE, Subarticle IWE-1241.
The moisture barrier located at the junction of containment shell and base slab was found to be deteriorated and replaced in 1997. However, in all the refueling outages since 2003, the moisture barrier was again found to be deteriorated at significant number of locations. The staff may request the applicant to provide the details of additional testing and investigation that are planned during the 2009 outage to verify the condition of the liner plate at or below the moisture barrier.
During the 2007 refueling outage the licensee found bulges in the liner plate at numerous locations. There appears to be a separation of the liner plate and concrete at these locations. In addition, liner plate coating has failed at numerous locations. The staff may request the applicant to provide the details of testing and engineering evaluation performed to address the bulge in the liner plate and how the aging of liner plate coating is managed at CR-3 plant.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report AMP; identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.26, ASME Section XI, Subsection IWL Program In the CR-3 LRA, the applicant states that AMP B2.26-01,ASME Section XI, Subsection IWL Program, is an existing program that is consistent with the program elements in GALL Report AMP XI.S2, ASME Section XI, Subsection IWE. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.26.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords: IWL, prestressing, and tendon surveillance.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0617 ASME Section XI, Subsection IWL Aging Magement Revision 1 Program November 12, 2008
- 2. S07-033 8th Tendon Surveillance Vendor Technical Information October 10, 2007
- 3. L07-0373 License Renewal Review of Civil Operating Experience for Revision 0 CR3 November 12, 2007
- 4. NCR 251318 Containment Tendon Test Results Exceed Acceptance May 29, 2008 Criteria During the audit of program elements 1 - 6, the staff found that:
Element 1 - 3, and 5 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; Sufficient information was not available to determine whether elements 4 and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 4 and 6 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
Element 4.3 of the LRA AMP L08-0617 states that statement in the GALL Report AMP X1.S2, detection of aging effects, is incorrect and inconsistent with ASME Section XI, Subsection IWE, 2001 edition including the 2002 and 2003 Addenda since the code no longer specify VT-1, VT-1C, VT-3 and VT-3C examinations. However, the LRA AMP L08-0617 is for ASME Section XI, Subsection IWL and not for Subsection IWE program.
Pages 20-21, Section 6.3 of AMP L08-617 state that ACI 201.1R-60 and R-92 were used in the development of the conditions indicative of degradation of IWL components.
However, GALL Report AMP X1.S2 recommends the use of ACI 201.1R-77 for identification of concrete degradation.
During the audit of program element 10 the staff found that:
Operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
Operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the following subjects:
The applicant states in LRA Section B2.26 that NRC Information Notice (IN) 99-10 was reviewed for applicability to CR-3. However, a review of the applicants supplied design documents indicate that IN 99-10 recommendations concerning trending analysis and loss in prestress due to relaxation may not have been considered during tendon surveillance activities. Staff may request the applicant to provide additional information to clarify this issue since it may affect the structural integrity of CR-3 containment during the period of extended operation.
During the several prestressing tendon surveillance inspections over the last 20 years the lift-off forces in the hoop prestressing tendons have been consistently found to be lower than the 95 percent of the predicted value. Staff may request the applicant to provide the status of investigation for this discrepancy in the lift-off and predicted forces since it may affect the structural integrity of CR-3 containment during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 4 and 6 for which additional information or additional evaluation is required before consistency can be determined; identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached;
verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.27, ASME Section XI, Subsection IWF Program In the CR-3 LRA, the applicant states that AMP B.2.27, ASME Section XI, Subsection IWF Program is an existing program that is consistent with the program elements in GALL Report AMP XI.S3, ASME Section XI, Subsection IWF Program. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.27.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords: pipe support, hanger, IWF.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date 1 EGR-NGGC-0504 Mechanical Systems Aging Management Review for Revision 8 License Renewal
- 2. EGR-NGGC-0506 Civil/Structural Screening and Aging Management Review Revision 7 for License Renewal
- 3. CAP-NGGC-0202 Operating Experience Program Revision 12
- 4. EGR-NGGC-0008 Engineering Programs Revision 8
- 5. SP-208 Visual Examination of Component Supports Revision 7
- 6. EGR-NGGC-0003 Design Review Requirements Revision 10
- 7. AI-701 Administration of the ASME Sect. XI and ASME OM Codes Revision 17 During the audit of program elements 1 - 6, the staff found that:
elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR Supplement was an adequate description of the LRA AMP.
Based on this audit, the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report AMP.
verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.
verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B2.28, 10 CFR PART 50, Appendix J Program In the CR-3 LRA, the applicant states that AMP B2.28-01, 10 CFR Part 50, Appendix J Program, is an existing program that is consistent with the program elements in GALL Report AMP XI.S4, 10 CFR Part 50, Appendix J. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.28. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords:
Appendix J, Type A test, Type B test, and Type C test.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0615 Crystal River Aging Management Program Description of Revision 1 the 10 CFR 50, Appendix J Program November 5, 2008
- 2. CP-120 Review of Leak Rate Tests May 21, 2008
- 3. Appendix J Testing, Program Health Report December, 2008
- 4. Audit QP-269 Audit QP-269 Finding Closure February 4, 1986
During the audit of program elements 1 - 6, the staff found that:
Elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the following subjects:
Appendix J of 10 CFR 50 requires a general inspection of the external surfaces to be performed prior to Type A test. The LRA AMP for 10 CFR 50, Appendix J states that a technical specification change may be generated to take credit for IWE examinations that are carried within a 10 year period. The staff may request the applicant explain how IWE examination performed during a period of 10 years can be credited for general inspection required to be performed prior to Type A Test.
Appendix J, 10 CFR 50 specify halide leak-detection method or rate of pressure loss method as acceptable methods for performing Type B and C tests. CR-3 performs Type B and C tests using make-up-flow method. In addition AMP states that make-up-flow method as the USNRC preferred method. The staff may request the applicant provide justification for using make-up-flow method and documentation that indicate that make-up-flow method as the USNRC preferred method.
The Type A containment leakage rate test is effective in detecting degradation of containment boundary. According to the AMP, the containment leakage rate during 2005 test was two times of that recorded during the previous test performed during 1991. This may indicate degradation of the containment system. Therefore, the staff may request the applicant to identify the root cause for the 100 percent increase in the leakage rate between two successive Type A tests.
Based on this audit the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report AMP;
identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.29, Masonry Wall Program In the CR-3 LRA, the applicant states that AMP B.2.29, Masonry Wall Program is an existing program with enhancement that is consistent with the program elements in GALL Report AMP XI.S5, Masonry Wall Program. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.29. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
The first enhancement affects LRA program element 1. This enhancement expands on the existing program element by revising the Condition Monitoring of Structures procedure to identify the structures which have masonry walls in the scope of license renewal.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: masonry wall, concrete block, and masonry block.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. EGR-NGGC-0506 Civil/Structural Screening and Aging Management Review Revision 7 for License Renewal
- 2. CAP-NGGC-0202 Operating Experience Program Revision 7
- 3. EGR-NGGC-0351 Condition Monitoring of Structures Revision 7
- 4. CAP-NGGC-0200 Corrective Action Program Revision 7
- 5. L07-0373 License Renewal Review of Civil Operating Experience for Revision 7 CR3 The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff found that:
elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP;
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.30, Structures Monitoring Program In the CR-3 LRA, the applicant states that AMP B.2.30, Structures Monitoring Program is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.S6, Structures Monitoring Program. The applicant has included aging management of water-control structures in its Structures Monitoring Program which is acceptable as noted in the GALL Report program XI.S7. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.30.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The first seven (7) enhancements affect LRA program element 1.
Administrative controls that implement the Program will be revised to:
(1) Specifically identify all License Renewal Structures and Systems that credit the program for aging management in the condition monitoring of structures corporate procedure.
(2) Require notification of the Responsible Engineer when below-grade concrete including concrete pipe is exposed so an inspection may be performed prior to backfilling.
(3) Require periodic inspections of the water control structures (Circulating Water Intake Structure, the Circulating Water Discharge Structure, the Nuclear Service Sea Water Discharge Structure, Intake Canal, and the Raw Water Pits on a frequency not to exceed five (5) years.
(4) Require periodic inspections of the Circulating Water Intake Structure submerged portions on a frequency not to exceed five (5) years.
(5) Require periodic groundwater chemistry monitoring including consideration for potential seasonal variations.
(6) Require inspection of inaccessible surfaces of reinforced concrete pipe when exposed due to removal of backfill for any reason in the condition monitoring of structures corporate procedure.
(7) Include additional in-scope structures and specific civil/structural commodities in the periodic engineering activity (PMID).
These enhancements expand on the existing program element.
The next seven (7) enhancements affect LRA program element 3.
Administrative controls that implement the Program will be revised to:
(1) Identify additional civil/structural commodities along with the associated inspection attributes and performance standard required for License Renewal in the corporate procedure for condition monitoring of structures.
(2) Require notification of the Responsible Engineer when below grade concrete including concrete pipe is exposed so an inspection may be performed prior to backfilling.
(3) Require inspection of inaccessible surfaces of reinforced concrete pipe when exposed due to removal of backfill for any reason in the condition monitoring of structures corporate procedure.
(4) Identify additional inspection criteria for structural commodities in the site system walkdown checklist (5) Add corrosion to the inspection criteria for the bar racks at the Circulating Water Intake Structure in the periodic maintenance activity (PMID).
(6) Add an inspection of the earth for loss of form and loss of material for the Wave Embankment Protection Structure in the periodic engineering activity (PMID).
(7) Require inspection of the Fluorogold slide bearing plates used in structural steel platform application located in the Reactor Building on an established frequency.
In the LRA transmittal letter December 16, 2008, under commitment no. 20 (enclosure 2 pg 7 of 9), the applicant committed to implement the following commitments prior to the period of extended operation:
(1) Identify all License Renewal structures and systems that credit the Program for aging management in the corporate procedure for condition monitoring of structures.
(2) Require notification of the responsible engineer when below grade concrete including concrete pipe is exposed so an inspection may be performed prior to backfilling.
(3) Require periodic groundwater chemistry monitoring including consideration for potential seasonal variations.
(4) Require periodic inspections of the water control structures, i.e., Circulating Water Intake Structure, Circulating Water Discharge Structure, Nuclear Service Sea Water Discharge Structure, Intake Canal, and Raw Water Pits, on a frequency not to exceed five years.
(5) Require periodic inspections of the Circulating Water Intake Structure submerged portions on a frequency not to exceed five years.
(6) Identify additional civil/structural commodities and associated inspection attributes and performance standard required for License Renewal in the corporate procedure for condition monitoring of structures.
(7) Identify additional inspection criteria for structural commodities in the site system walkdown checklist.
(8) Add inspection for corrosion to the inspection criteria for the bar racks at the Circulating Water Intake Structure as a periodic maintenance activity.
(9) Add an inspection of the earth for loss of form and loss of material for the Wave Embankment Protection Structure as a periodic maintenance activity.
(10) Include additional in-scope structures and specific civil/structural commodities in periodic maintenance activities.
(11) Require periodic inspections of the Fluorogold slide bearing plates used in structural steel platform applications in the Reactor Building.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: leaching, corrosion, crack, ground water, and water intrusion.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date 1.L08-0608 Description of the Structures Monitoring Program. Revision 1 11/13/2008
- 2. WO 901892 Condition Monitoring of Structures Aux. Building and Int. Building 4/25/2008
- 2. WO 952470 Condition Monitoring of Structures Intake and Discharge 05/07/07 Structures
- 3. WO 952467 Condition Monitoring of Structures Bridges and Vault 05/15/07
- 4. WO 804636 Spent Fuel Pool: 12/19/06 WO 952471 Hair line crack in Spent Fuel Pool south wall. 03/12/07 WO 1030125 3/12/08 WO 1313834 3/11/09
- 5. WO 439677 Snake Spent Fuel Pool Drain Lines 8/18/04 The staff conducted its audit of LRA program elements 1 - 6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of these program elements were evaluated and are described below.
During the audit, the staff found that:
elements 1, 2, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; sufficient information was not available to determine whether elements 3 and 4 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 3 and 4 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
a) to clarify frequency of inspection for the structures and components under Structure Monitoring Program.
b) to gather more information on ground water monitoring.
Although LRA AMP B.2.30, Structures Monitoring Program is credited for the GALL report AMP XI.S7, Inspection of Water-Control Structures Associated with Nuclear Power Plant, program basis document of LRA AMP B.2.30 evaluation section does not present element by element comparison with the GALL Report AMP XI-S7. Further information is required to allow the staff to determine that all the element(s) of the LRA AMP B.2.30 has incorporated the corresponding elements of the GALL Report AMP X1.S7.
In order to obtain the information necessary to verify whether the LRA program elements are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subject:
to describe how all the attributes of the GALL Report program XI-S7 will be incorporated in CR-3 Structures Monitoring Program.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the following subjects:
a) Aging effects on the walls of the Tendon Access Gallery at El. 75.
b) Verification of any blockage in the leak chase channel piping system.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 3 and 4 for which additional information or additional evaluation is required before consistency can be determined; identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.31 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program In the CR-3 LRA, the applicant states that AMP B.2.31, Electrical Cables and Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program, is a new program that is consistent with the program elements in GALL Report AMP XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. The applicant committed to implementing this program prior to the period of extended operation in the LRA transmittal letter dated December 16, 2008. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 -
6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.31. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: cables, connections, cracking, melting, discoloration, and embrittlement.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0640 License Renewal Aging Management Program Description of the Revision 0, Electrical Cables and Connections Not Subject to 10 CFR 50.49 06/03/2008 Environmental Qualification Requirements Program
- 2. EGR-NGGC-0507 Cable Aging Management Program Revision 3
- 3. L07-0300 Electrical Integrated Plant Assessment Revision 1 During the audit of program elements 1 - 6, the staff found that:
Elements 1 - 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
Sufficient information was not available to determine whether element 4 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element number 4 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing an RAI for the following subjects:
In LRA Section B.2.31, under the operating experience element, the applicant states that this program is a new program with no site-specific operating experience history.
However, in element 4 of the AMP it states the CR-3 program utilizes plant operating experience to determine the plant areas to be inspected. It also states that based on this review of operating experience, the plant areas to be inspected become localized in
nature, consisting of limited area (or subset) of a much larger plant area or zone. It further states that the sample selection of cables and connections inspected within the limited plant area bound all cables and connections in the area since the inspection focuses on the worst case environments. In the corresponding GALL Report AMP element, it states a representative sample of accessible electrical cables and connections installed in adverse localized environment are visually inspected for cable and connection jacket surface anomalies. It is not clear to the staff that these statements are consistent because the GALL Report AMP recommends inspection of cables and connections installed in adverse localized environments while the applicants AMP determines the areas to be inspected based on the plant operating experience.
During the audit of program element 10 the staff found that:
the operating experience identified by the staffs independent database search and supplemented by the applicant is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff).
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 4 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.
verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.32, Electrical Cables and Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Used In Instrumentation Circuits Program In the CR-3 LRA, the applicant states that AMP B.2.32, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits is a new program that is consistent with the program elements in GALL Report AMP XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits. The applicant committed to
implementing this program prior to the period of extended operation in the LRA transmittal letter dated December 16, 2008. To verify this claim of consistency, the staff audited the LRA AMP.
This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.32. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: instrumentation, resistance, insulation, cable, melt, and crack.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0641 License Renewal Aging Management Program Description of Revision 1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 12/01/08 Environmental Qualification Requirements Used in Instrumentation Circuits Program
- 2. L07-0300 Electrical Integrated Plan Assessment Revision 1, 12/01/08
- 3. DBD/52 Enhanced Design Basis Document for the Nuclear Instrumentation Revision 10, System 1/29/04 During the audit of program elements 1 - 6, the staff found that:
elements 1, - 3, 5, and 6 of the LRA AMP was consistent with the corresponding elements of the GALL Report AMP.
Sufficient information was not available to determine whether Element 4 of the AMP was consistent with the corresponding element of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element Number 4 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing a RAI for the following subjects:
In LRA Section B2.32, the applicant states that this is a new program and will be consistent with the GALL Report AMP XI.E2. Under Detection of Aging Effects of the basis document (L08-0641), the applicant states that as an alternate to the review of calibration or surveillance results, CR-3 will test the cable system used in the power range (PR) circuits of the excore monitoring system. In the corresponding GALL AMP element, its states that in cases where a calibration or surveillance program does not include the cable system in the testing circuit, the applicant will perform cable system testing for detecting deterioration of the insulation system. Since the cable system of PR used in the excore monitoring systems is disconnected during the calibration or surveillance procedures, the cable systems of these systems should be tested and
should not be considered as an option or an alternate to calibration or surveillance program. The wording as an alternate to the review of calibration or surveillance could mean that the applicant could perform either a calibration or test of these cable systems.
This is not consistent with GALL Report AMP XI.E2.
During the audit of program element 10 the staff found that:
the operating experience identified by the staffs independent database search and supplemented by the applicant is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff).
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 4 for which additional information or additional evaluation is required before consistency can be determined; verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.
verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.33, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program In the CR-3 LRA, the applicant states that AMP B.2.33, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new program that is consistent with the program elements in GALL Report AMP XI.E3, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. The applicant committed to implementing this program for in-scope, medium-voltage cables exposed to significant moisture and significant voltage prior to the period of extended operation as referenced to Enclosure 2, List of Regulatory Commitments, of the CR-3 application letter dated December 16, 2008. To verify this claim of consistency the staff audited LRA AMP B.2.33. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.33.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: manhole, electrical, duct, water, submergence, cable, water tree, and underground.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. NUREG 1801 Generic Aging Lessons Learned (GALL) Report Chapter XI, Vol. 2, Aging Management Programs (AMPS), AMP XI.E3, Revision 1 Inaccessible Medium-Voltage Cables Not Subject To 10 09/2005 CFR 50.49 Environmental Qualification Requirements.
- 2. L08-0642 License Renewal Aging Management Program Description Revision 1 of the Inaccessible Medium-Voltage Cables Not Subject to 12/01/2008 10 CFR 50.49 Environmental Qualification Requirements Program
- 3. CAP-NGGC-0202 Operating Experience Program Revision 12 Date N/A
- 4. L07-0300 Electrical Integrated Plant Assessment Revision 1 12/01/2008
- 5. CAP-NGGC-0200 Corrective Action Program Revision 27 Date -N/A
- 6. GL 2007-01 Inaccessible or Underground Power Cables Failures that 02/07/2007 Disable Accident Mitigation Systems or Cause Plant Transients
- 7. EC-206-011 Electrical One Line Diagram Composite Revision 67 02/21/73
- 8. CAP-NGGC-0202 Operating Experience Program Revision 15 Date - N/A
- 9. E-226-103 Electrical Conduit Layout Intake Structure Revision 24 05/20/08
- 10. B-208-072 SD-09 Elementary Diagram - Intake Elect vault Sump Pump SDP- Revision 8 6 08/18/89
- 11. E-201-034 Electrical Arrangement - Diesel, Intake and Wtr. Treat. Revision 5 Conduit Duct Runs - Sections 01/15/1975
- 12. E-201-033 Electrical Arrangement - Diesel, Intake and Wtr. Treat. Revision 7 Conduit Duct Runs - Plan 01/15/1975
- 13. NCR#00344215 Inspection of Manholes for License Renewal 07/09/2009
- 15. Model W/O M, PM, Site Manhole & Handhole Inspections Revision - N/A 00614384 Date - N/A During the audit of program elements 1 - 6, the staff found that:
elements 1 - 6 were consistent with the corresponding elements of the GALL Report AMP XI.E3.
During the audit of program element 10 the staff found that:
the operating experience identified by the staffs independent database search and supplemented by the applicant is bounded by industry operating experience for GALL AMP XI.E3 (i.e. no previously unknown aging effects were identified by the applicant or the staff).
The operating experience identified by the staffs independent database search and supplemented by the applicant is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
A walk down of in-scope manholes E-2, E-3, and E-7 was also performed by the staff with assistance from the site senior resident and a NRC Region II senior reactor inspector. During the walkdown standing water was identified (at a depth of approximately 4 to 6 inches) in manhole E-2. Although water was observed in the manhole E-2, no cable or raceway submergence was observed by the staff. Manholes E3 and E7 were dry. Manhole E-7 is equipped with a sump pump with automatic actuation and a high level alarm annunciated in the control room. As a result of a recent applicant manhole inspection for LR, the applicant generated an action request to address the water and material conditions in these manholes including pumping water from manhole E-2. The action report had not been dispositioned at the time of the staff walk down. Region II will follow up the disposition of the applicants action report during the Region II LR inspection. In addition, the staff reviewed the applicants work control program and associated model work orders. These work orders inspect in-scope manholes on an annual basis and perform an operational check of the sump pumps every 6 months. The applicants model work order documents whether standing water was found, the level of water, if standing water covered any cables and raceway, and records the volume of water pumped from the manhole.
The staff also audited the description of the LRA AMP B.2.33 provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR Table 3.6-2 and, therefore, acceptable.
Based on this audit the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report AMP XI.E3.
verified that the operating experience is sufficient to indicate that the LRA AMP B.2.33, as implemented by the applicant, is sufficient to detect and manage aging.
verified that the description provided in the FSAR Supplement A.1.1.33 is an adequate description of the program.
LRA AMP B.2.34, Metal Enclosed Bus Program In the CR-3 LRA, the applicant states that AMP B.2.34,Metal Enclosed Bus is a new program that is consistent with the program elements in GALL Report AMP XI.E4, Metal Enclosed Bus.
The applicant committed to implementing this program prior to the period of extended operation in the LRA transmittal letter dated December 16, 2008. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.34.
Program elements 7 - 9 were audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: bus, metal, connections, duct, and phase.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0643 License Renewal Aging Management Program Description of The Revision 1, Metal Enclosed Bus Program 12/01/08
- 2. L07-0300 Electrical Integrated Plan Assessment Revision 1, 12/01/08
- 3. CAP-NGGC-0202 Operating Experience Program Revision 12 During the audit of program elements 1 - 6, the staff found that:
elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 the staff found that:
the operating experience identified by the staffs independent database search and supplemented by the applicant is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff).
the operating experience identified by the staffs independent database search and supplemented by the applicant is sufficient to allow the staff to verify that the LRA AMP, to be implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit, the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report AMP.
verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.
verified that the description provided in the FSAR Supplement is an adequate description of the program LRA AMP B.2.35, Fuse Holder Program In the CR-3 LRA, the applicant states that AMP B.2.35, Fuse Holder Program is a new program with an exception that is consistent with the program elements in GALL Report AMP XI.E5, Fuse Holders. The applicant committed to implementing this program prior to the period of extended operation in the LRA transmittal letter dated December 16, 2008. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in LRA Appendix A, Final Safety Analysis Report Supplement Section A.1.1.35. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues Identified but not resolved in this report are addressed in the SER.
The exception affects LRA program element 3. In the GALL Report AMP, this program element recommends monitoring thermal fatigue in the form of high resistance caused by ohmic heating, thermal cycling or electrical transients, mechanical fatigue caused by frequent removal/replacement of the fuse or vibration, chemical contamination, corrosion, and oxidation.
Alternatively, this program element in the LRA states, Loss of continuity due to corrosion and oxidation will be managed by the Fuse Holder Program. Fatigue due to ohmic heating, thermal cycling, electrical transients, frequent manipulation, vibration, and chemical contamination are not applicable aging effects for CR-3 fuse holders located outside of active devices.
During its audit, the staff interviewed the applicants staff and reviewed onsite documentation including inspection results provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: Fuse, Fuse Holder, Corrosion, Oxidation, Block, and Contamination.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. NUREG 1801 Generic Aging Lessons Learned (GALL) Report Chapter XI, Vol. 2, Aging Management Programs (AMPS), AMP XI.E5, Fuse Revision 1 Holders. 09/2005
Document Title Revision / Date
- 2. L08-0644 License Renewal management Program Description of the Fuse Revision 1 Holder program 12/01/2008
- 3. L07-0300 Electrical Integrated Plant Assessment Revision 1 12/01/2008
- 4. CAP-NGGC-0202 Operating Experience Program Revision 12 Date - N/A
- 5. CAP-NGGC-0200 Corrective Action Program Revision 27 Date - N/A
- 6. AI-605A Predictive Maintenance Program Revision 6 Date - N/A The staff conducted its audit of LRA program elements 1 - 6 without considering aspects of program element 3 of the LRA AMP which are associated with the exception. Aspects of these elements not associated with the exception were evaluated and are described below.
During the audit, the staff found that:
Aspects of the elements not associated with the exception were evaluated during the audit, and the staff found that elements, 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP XI.E5.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the LRA FSAR Supplement.
The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that LRA program elements 1 - 6 not associated with the exception are consistent with corresponding program elements in the GALL Report AMP XI.E5.
verified that the operating experience is sufficient to indicate that LRA AMP B.2.35, as implemented by the applicant, is sufficient to detect and manage aging.
verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.2.36, Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program In the CR-3 LRA, the applicant states that AMP B.2.36, Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program is a new program with exceptions that is consistent with the program elements in GALL Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. The applicant committed to implementing this program prior to the period of extended operation in the LRA transmittal letter dated December 16, 2008. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 -
6 and 10 and the description of the program as contained in the LRA Appendix A, Final Safety Analysis Report Supplement Section A.1.1.36. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The first exception affects LRA program element 1. In the GALL Report AMP, this program element recommends that connections associated with cables in scope of license renewal are part of this program, regardless of their association with active or passive components.
Alternatively, this program element in the LRA states that, CR-3 has applied the clarification provided in proposed LR-ISG-2007-02 dated August 29, 2007, that revises the scope to include only external cable connections terminating at an active device such as a motor, motor control center, switchgear, or of a passive device such as a fuse cabinet. Wiring connections internal to an active assembly installed by manufacturers are considered a part of the active assembly; and therefore, are not within the scope of this program.
The second exception affects LRA program element 4. In the GALL Report AMP, this program element specifies that electrical connections within the scope of license renewal will be tested at least once every 10 years. Testing may include thermography, contact resistance testing, or other appropriate testing methods. Alternatively, this program element in the LRA states that, consistent with the test frequency flexibility provided in proposed LR-ISG-2007-02 dated August 29, 2007, this element will be implemented as a one-time inspection on a representative sample of non-EQ cable connections within the scope of Licensee Renewal prior to the period of extended operation. Inspections methods may include thermography, contact resistance testing, or other appropriate testing methods. This one-time inspection verifies that the loosening of connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation is not an aging effect that requires a periodic aging management program.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: cable, connection, bolt, loose, electrical, corrosion, and thermography.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. NUREG 1801 Generic Aging Lessons Learned (GALL) Report Chapter XI, t Vol. 2, Programs (AMPS), AMP XI.E6, Electrical Cable Connections Not Revision 1 Subject to 10 CFR 50.49 Environmental Qualification 09/2005 Requirements.
- 2. L07-0300 Electrical Integrated Plant Assessment Revision 1 12/01/2008
- 3. CAP-NGGC-0202 Operating Experience Program Revision 12 Date - N/A
- 4. L08-0646 License Renewal Aging Management Program Description of the Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program
- 5. CAP-NGGC-0200 Corrective Action Program Revision 27 Date - N/A
- 6. AI-605A Predictive Maintenance Program Revision 6 Date - N/A The staff conducted its audit of LRA program elements 1 - 6 without considering aspects of program elements 1 and 4 of the LRA AMP which are associated with the exceptions. Aspects of these elements not associated with the exceptions were evaluated and are described below.
During the audit, the staff found that:
elements 1 - 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided for the licensees program as modified by LR-ISG-2007-02, and, therefore, acceptable.
Based on this audit the staff:
verified that LRA program elements 1 - 6 not associated with the exceptions are consistent with corresponding program elements in the GALL Report AMP.
verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.
verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.3.1, Reactor Coolant Pressure Boundary Fatigue Monitoring Program In the CR-3 LRA, the applicant states that AMP B.3.1 Reactor Coolant Pressure Boundary Fatigue Monitoring Program is an existing program that is consistent with the program elements in GALL Report AMP X.M1, Metal Fatigue of Reactor Coolant Pressure Boundary.
To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 and 10 and the description of the program as contained in the FSAR Supplement in LRA Section A.1.1.39. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords: fatigue, dissolved oxygen, insurge, and 88-11.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. L08-0604 License Renewal Aging Management Program Description of Revision 1 the Reactor Coolant Pressure Boundary Fatigue Monitoring 11/11/2008 Program
- 2. CAP-NGGC-0202 Operating Experience Program Revision 15 (Ref. 5.7 of L08-0604) (Doc. not dated)
- 3. CAP-NGGC-0200 Corrective Action Program Revision 27 (Ref. 5.12 of L08-0604) (Doc. not dated)
SP-296 Documentation of Allowable Operating Transient Cycles Revision 21 (Ref. 5.17 of L08-0604) (Doc. not dated) 4a. SP-422 RC System Heatup and Cooldown Surveillance Revision 38 (Ref. 5.20 of L08-0604) (Doc. not dated) 4b. Log of transient data RC System Heatup and Cooldown Surveillance Log (Worksheet) Note 1 capture
- 5. AR 168963168963
Subject:
NEI 03-08 :Good Practice - Fatigue Licensing Basis No Rev. Number (MRP-149) Printed: 06/21/08
- 6. AR 173002173002
Subject:
NEI 03-08 :Good Practice - Fatigue Licensing Basis No Rev. Number (MRP-148) Printed: 06/21/08 Items 7 through 11 are stress and fatigue analyses Note 2 supporting TLAA for the pressurizer nozzle and the surge line hot leg nozzle.
- 7. 32-9043113-000 Crystal River Unit 3 Pressurizer Surge Nozzle Weld Overlay Revision 0 Analysis 7/27/2007
- 8. 32-9043113-001 Crystal River Unit 3 Pressurizer Surge Nozzle Weld Overlay Revision 1 Analysis 9/24/2007
- 9. 32-9043131-001 Crystal River Unit 3 Pressurizer Surge Nozzle Weld Overlay Revision 0 Crack Growth Evaluation 9/24/2007
- 10. CR 2007-5956 No title Note 2
Document Title Revision / Date
- 11. 32-9067002-000 Crystal River Unit 3 Hot Leg Surge Nozzle Weld Overlay Repair Revision 0 Residual Stress Analysis 11/27/2007 Note 1: Transient data log (worksheet), randomly selected and reviewed, between 1980 and 2005.
Note 2: Both the pressurizer surge nozzle and the surge line hot leg nozzle received a full structural weld overlay using PWSCC-resistant Alloy 52M. AREVA performed both the overlay material deposition and the associated analytical work. The pressurizer surge nozzle overlay weld passed UT examination. However, the overlay weld of the surge line hot leg nozzle was subsequently removed (ground off) due to indications/flaws detected during UT examination. A condition report, CR 2007-5956, dated 11/28/2007 (Document Item 10 in the list), was issued to document the corrective actions taken for the defected weld overlay. The condition report is now closed. AREVA performed reconciliation analysis (2D FE modeling) to demonstrate that the structural condition of the repaired surge line hot leg nozzle bounds that of the original nozzle because the nozzle wall is now thickened, gained from the left-in weld material after grinding. The reconciliation analysis of the repaired surge line hot leg nozzle can be found in Document 11 listed in the above table. The applicant indicated that a project to reapply the weld overlay for the surge line hot leg nozzle was scheduled for the forthcoming refueling outage.
During the audit of program elements 1 - 6, the staff found that elements 1, 3, 4, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; elements 2 and 5 of the LRA AMP were not strictly consistent with the corresponding elements of the GALL Report AMP but that sufficient information was available to allow the staff to determine that these elements of the LRA AMP are equivalent to the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 2 and 5 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAIs for the following subjects:
In element 2 of the LRA AMP it states that appropriate cyclic alarm limits are specified to ensure that the fatigue usage factors are maintained within the design limit including the consideration of the effect of the reactor water environment. While this statement appears consistent with the GALL Report guidelines, it is not clear to the staff whether the alarm limit feature has already been implemented in the RCPBFMP program because no corresponding license renewal commitment is stated in the LRA.
In element 5 of the LRA AMP it states that the program scope includes all fatigue usage locations within the RCPB, including NUREG/CR-6260 locations that have been analyzed for environmental effects. While this statement appears consistent with the GALL Report guidelines, it is not clear to the staff whether the monitoring feature for the NUREG/CR-6260 locations has already been implemented in the RCPBFMP program because no corresponding license renewal commitment is stated in the LRA.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the following subjects:
During the onsite audit, the staff learned there was an unacceptable weld overlay application incident in the surge line hot leg nozzle not discussed in the LRA. See Note 2 above for more details. The unacceptable overlay was not included in the OE and no discussion of its impact on the AMP and TLAA was discussed.
The onsite basis document (L08-0604) states that high cycle fatigue due to vibration is not germane to fatigue management program focused on tracking cycles and transients related to low cycle fatigue and concluded that the OEs on cracking in STP 2, Hope Creek, and St. Lucie 2 are not applicable to CR-3. The AMP should include high cycle fatigue effects since high cycle fatigue can also raise safety concerns, especially when high-cycle fatigue due to flow-induced vibrations is addressed in LRA Section 4.3.1.2 for the RVI components.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement (LRA Section A.1.1.39). The staff found this description to be consistent with the description provided in the GALL Report AMP X.M1 and, therefore, acceptable.
Based on this audit the staff:
verified that most of the LRA program elements 1 - 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 2 and 5 for which additional information or additional evaluation is required before consistency can be determined; identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; verified that the description provided in the FSAR Supplement is an adequate description of the program.
LRA AMP B.3.2, Environmental Qualification (EQ) Program In the CR-3 LRA, the applicant states that AMP B.3.2, Environmental Qualification (EQ)
Program is an existing program that is consistent with the program elements in GALL Report AMP X.E1, Environmental Qualification (EQ) of Electrical Components. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 - 6 10 and the description of the program as contained in the LRA Appendix A, Final safety Analysis Report Supplement, Section A.1.2.3. Program elements 7 - 9 were audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicants staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants operating experience database using the keywords: EQ, Qualification, Environmental, Electrical, Cable, Component, and Program.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. NUREG 1801 Generic Aging Lessons Learned (GALL) Report Chapter X, Vol. 2, Time-Limited Aging Analysis Evaluation of Aging Management Revision 1 Programs Under 10 CFR 54.21(c)(1)(iii), AMP X.E1, 09/2005 Environmental Qualification of Electric Components.
- 2. L08-0647 License Renewal Aging Management Program Description Of Revision 1 The Environmental Qualification Program 12/01/2008
- 3. L07-0500 Time Limited Aging Analysis Identification Revision 1 11/20/2008
- 4. Regulatory Guide 1.89 Environmental Qualification of Certain Electric Equipment Revision 1 Important to Safety for Nuclear Power Plants June 1984
- 5. CES AR 14401 CR3 Environmental Qualification Program - Self-Assessment Revision N/A Report 04/12/2005
- 6. N/A Crystal River 3 Program Health Report Revision N/A January 2008 During the audit of program elements 1 - 6, the staff found that:
elements 1 - 6 were consistent with the corresponding elements of the GALL Report AMP X.E1.
During the audit of program element 10 the staff found that:
the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff);
the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP,
as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
verified that LRA program elements 1 - 6 are consistent with corresponding program elements in the GALL Report AMP.
verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging.
verified that the description provided in the FSAR Supplement is an adequate description of the program.
Plant Specific Operating Experience Review The purpose of an Independent Search of an applicants OE database is to determine the adequacy of the license renewal applicants (LRA) use of OE to inform the aging management programs (AMPs) for its extended period of operation.
Plant OE plays an important role in license renewal and figures prominently in an LRA, as stated in the OIG report OIG-07-A-15 dated September 6, 2007. The NRCs SRP-LR provides guidance to the NRC staff on assessing the 10 program elements for each AMP submitted in a LRA. OE is listed as one of these elements, and defined in brief in the GALL Report.
The on-site specific and industry OE is also an important part of two other AMP elements:
specifically, detection of aging effects and monitoring and trending. The SRP-LR also calls attention to the importance of the applicants specific OE in relation to scoping and screening, aging management review, and time-limited aging analysis activities.
For the aging management audit of the CR-3 LRA, two dedicated audit team members, with plant experience, conducted an independent search of the applicants plant-specific OE database to provide the staff team members with relevant and appropriate OE, and the associated corrective actions performed. The total number of specific OE items searched and extracted from the applicants database was in excess of twenty one thousand OE report items screened and approximately two thousand that were distributed to various staff members for review. The use of key search words was required to search the applicants nuclear condition reports (NCRs), an element of the applicants plant database, PassPort action tracking module. These database searches were independent of the applicants input contained in the LRA, and allowed for independent sampling and independent verification of the applicants specified OE used to inform the applicants AMPs.
The results were further screened by the staff while reviewing individual AMPs for relevance and adequacy and used to help in some cases develop further RAIs and to obtain more
information regarding a particular AMP reviewed. Due to the applicants restricted use of their NCR data, a dedicated CR-3 plant staff member with experience in using the database computer system was available and assisted in the staffs independent search of the site OE relevant to license renewal.
The CR-3 NCRs reviewed extended back to the year 2000, the audit staff also performed walkdowns, breakout sessions, and drafted RAIs on site during the audit period. These reviews resulted in RAIs that will be formally submitted to the applicant. The staff in performing this independent review of the applicants NCR documents resulted in an extensive sampling of the applicants relevant OE and provides reasonable assurance that relevant OE for informing the proposed AMPs for use during the period off extended operation and been properly used by the applicant for CR-3.
CR-3 Material/Environment Sample Audit The applicant for the proposed CR-3 license renewal determined specific component material and environment(s) used for the AMPs by performing an integrated plant assessment (IPA) in accordance with requirements of 10 CFR 54.21(a). The IPA first involved: (1) identification of the plant systems, structures and components that are within scope, in accordance with 10 CFR 54.4, Scope, of license renewal and (2) determined which specific components require an aging management review (AMR) referred to as Screening. The screening process identified in-scope passive components subject to an AMR. Short-lived passive components, which could be excluded from an AMR on the basis of a qualified life or a specified replacement time period, were also identified and removed from any further aging evaluation considerations.
To validate the CR-3 plant-specific in-scope component material and environment(s) selected by the applicant subject to an AMR during the proposed extended operating period, the staff performed an independent on-site audit during the week of July 13, 2009. Due to the extensive number of actual components subject to an AMR the staff developed a statistical method to sample the CR-3 material and environment combinations for the component information submitted by the applicant as part of the LRA. A random sample of thirty five components and their environments were selected in advance for the on-site audit and these specific line items were provided to the applicant prior to the audit to ensure that references could be provided for inspection and validation.
The staff performed an on location material/environment verification by walkdown and by review of CR-3 plant-specific reference documentation. These reference documents included the CR-3 FSAR, plant system and design drawings, plant design specifications, plant system descriptions, component vendor manuals, vendor correspondence and purchase order information. The staff was able to visually inspect nineteen of the thirty five items randomly selected for this audit. These items represented all components that could be readily accessed by walkdown inside and outside of the physical plant. Examples of component walkdowns included; emergency diesel generator, decay heat closed cycle cooling system, spent fuel coolant system, emergency feedwater system, instrument air system; and various components in the control complex and auxiliary buildings.
During the staff review of the thirty five selected items, thirty four items were verified by the staff to be correct in the LRA application. The staff noted in its walkdown and in subsequent document searches of the applicants references, drawings and material specifications, vendor
manuals, that the "instrument air dryers in LRA Table 3.3.2-28 were not correct in regards to material environment description regarding an as-found instrument air dryer that was carbon steel and contained dried air as an internal environment. The applicant had listed Stainless Steel with a dried air environment in its table. The review of the vendor manuals for this air dryer listed alumina silicate desiccant contained inside, which was not listed in the LRA table.
As a result of these findings, an RAI may be issued to clear up questions brought about by this materials and environmental audit.
The 35 sample components had been selected randomly. The staff assigned sequential numbers to all component groups (i.e., line items) in the CR-3 LRA tables. A random number generator was then used to select the 35 sample components. The staff then developed tables of the information in the LRA for these specific components. The staff also collected information from the LRA for similar components in the same system but possibly made of different material and in a different environment. This random selection of these components permitted the staff to estimate the accuracy of CR-3s in-scope component material and environment information.
Based on the results of the survey, the staff estimates that the CR-3 LRA information on component material and environment is 97 percent accurate and we are 95 percent certain that the information is greater than 92 percent accurate.
CR-3 Sample of Component Information
- Random System or Component Material Environment Other Material Other Environments Number Structure Commodity Sequential Number Correct NRC Comments 1 1492 Penetration Piping, piping Stainless Steel Air - Indoor Aluminum or Dried Air (Inside), Air YES FSAR Cooling components, and piping Uncontrolled Aluminum Alloys, indoor, Uncontrolled System elements (Outside) Carbon or Low (inside)
Alloy Steel, Cooper and Copper Alloys, Gray Cast 2 4299 Main Main Feedwater Pump Carbon or Low Closed Cycle Copper and Air Indoor YES Walk-Down &
Feedwater Turbine and Booster Alloy Steel Cooling Water Copper Alloys Uncontrolled, Drawings Turbine Lube Pump Lube Oil Cooler (Inside) Lubricating Oil (Inside)
Oil System Components 3 3681 Station Piping, piping Elastomers Air - Indoor Aluminum or Dried Air (Inside),Raw YES Walk-Down &
Drains components, and piping Uncontrolled Aluminum Alloys, Water (inside) Drawings System elements (Outside) Carbon or Low Alloy Steel, Stainless Steel, Gray Cast 4 1006 Reactor Reactor Coolant Pump; Carbon or Low Lubricating Oil none Air Indoor Uncontrolled YES FSAR Coolant Oil Lift Pumps Alloy Steel (Inside) (Outside)
System 5 1228 Air Handling EFP-3 Diesel Engine Carbon or Low Diesel Exhaust Stainless Steel Air Indoor Uncontrolled YES Walk-Down &
Ventilation Exhaust Expansion Alloy Steel (Inside) (Outside) Drawings and Cooling Joints and Silencers System 6 5089 Reactor Seals, Gaskets, and Elastomer Air - Indoor None None YES Site Drawings Building Moisture Barriers 7 1311 Control Control Complex Copper and Closed Cycle None Air Indoor Uncontrolled YES Walk-Down &
Complex Normal and Emergency Copper Alloys Cooling Water (Outside) Drawings Ventilation Cooling Coil Tubes (Inside)
System 8 1953 Appendix R Flow restricting Stainless Steel Closed Cycle None Air Indoor Uncontrolled YES Walk-Down &
Chilled elements Cooling Water (Outside) Drawings Water (Inside)
System
CR-3 Sample of Component Information 9 2916 Instrument Instrument Air Dryers Stainless Steel Dried Air Cooper or Low Air Indoor Uncontrolled NO Walk-Down &
Air System (Inside) Alloy Steel, (Outside) Drawings Copper and Copper Alloys 10 1664 Reactor Ducting and components Carbon or Low Air - Indoor None Air Indoor Uncontrolled YES FSAR Building Alloy Steel Uncontrolled (Outside)
Recirculation (Inside)
System 11 5418 Control Concrete: Above Grade Reinforced Air - Indoor none Air - Outdoor YES Walk-Down &
Complex Concrete Drawings 12 322 Reactor Reactor Vessel Internals; Nickel Base Reactor Coolant Stainless Steel None YES FSAR Coolant Lower Internals Alloys (Outside)
System Assembly-to-Core Barrel Bolts 13 388 Reactor Reactor Vessel Internals; Stainless Steel Reactor Coolant None None YES FSAR Coolant Lower Grid Rib Section (Outside)
System 14 190 Reactor Reactor Vessel Internals; Stainless Steel Reactor Coolant none None YES FSAR Coolant Upper Grid Rib Section (Outside)
System 15 783 Reactor Pressurizer; Level Nickel Base Reactor Coolant None Air Indoor Uncontrolled YES FSAR Coolant Sensing Nozzles Alloys (Inside) (Inside)
System 16 3533 Station Air Piping, piping Aluminum or Air - Outdoor Carbon or Low Air Indoor Uncontrolled YES Walk-Down &
components, piping Aluminum (Outside) Alloy Steel, (Inside), Air Indoor Drawings elements, and tanks Alloys Copper and Uncontrolled (Outside),
Copper Alloys, Dried Air (Inside), Raw Fiber Glass or Water (Inside)
Fiber Reinforced Plastic 17 4340 Main Steam Containment Isolation Carbon or Low Treated Water Stainless Steel Air - Indoor YES FSAR System Piping and Components Alloy Steel (Inside) Uncontrolled (Outside),
Steam (Inside),
18 5196 Auxiliary Cranes Carbon Steel Air - Indoor YES Walk-Down &
Building Drawings
CR-3 Sample of Component Information 19 2627 Demineralize Flow restricting Stainless Steel Treated Water None Air - Indoor YES Walk-Down &
d Water elements (Inside) Uncontrolled (Outside) Drawings System 20 4167 Spent Fuel Spent Fuel Coolant Galvanized Air - Indoor Carbon or Low Raw Water (Inside), Air YES FSAR Coolant Pump Air Supply Steel Uncontrolled Alloy Steel, - Indoor Uncontrolled Pump Cooling Coil (Inside) Copper and (Outside), Closed Cycle Cooling Components Copper Alloys Cooling Water (Inside)
System 21 4076 Decay Heat Decay Heat Closed Carbon or Low Air - Indoor Copper and Raw Water (Inside), YES FSAR Closed Cycle Cycle Pump Air Supply Alloy Steel Uncontrolled Copper Alloys, Closed Cycle Cooling Pump Cooling Coil (Outside) Galvanized Steel Water, Air - Indoor Cooling Components Uncontrolled (Inside)
System 22 5986 Switchyard Concrete: Above Grade YES Walk-Down &
for Crystal Drawings River Site 23 256 Reactor Reactor Vessel Internals; Stainless Steel Reactor Coolant None None YES FSAR Coolant CRGT Rod Guide (Outside)
System Sectors 24 586 Reactor RCPB Piping; Surge Stainless Steel Reactor Coolant None Air - Indoor YES FSAR Coolant Line (Inside) Uncontrolled (Outside)
System 25 5764 Fire Service Concrete: Above Grade Reinforced Air - Outdoor YES Walk-Down &
Pumphouse Concrete Drawings 26 2561 Diesel Piping, piping Copper and Lubricating Oil Aluminum or Air - Indoor YES Walk-Down &
Generator components, and piping Copper Alloys (Inside) Aluminum Alloys, Uncontrolled (Outside), Drawings Lube Oil elements Carbon or Low Closed Cycle Cooling System Alloy Steel, Glass, Water, Cray Cast Iron, Stainless Steel 27 4365 Main Steam Piping, piping Aluminum or Dried Air Carbon or Low Air - Indoor YES FSAR System components, piping Aluminum (Inside) Alloy Steel, Uncontrolled (Outside),
elements, and tanks Alloys Copper and Dry Gas (Inside), Steam Copper Alloys, (Inside), Treated Water Stainless Steel (Inside)
CR-3 Sample of Component Information 28 3483 Auxiliary Ducting and components Carbon or Low Air - Indoor Galvanized Steel Air - Indoor YES Walk-Down &
Building Alloy Steel Uncontrolled Uncontrolled (Inside) Drawings Supply (Outside)
System 29 1598 Emergency EFP-3 Diesel Engine Carbon or Low Air - Outdoor None Air - Indoor YES Walk-Down &
Feedwater Exhaust; Piping, piping Alloy Steel (Outside) Uncontrolled (Outside), Drawings Pump components, and piping Air Outdoor (Inside),
Building elements Diesel Exhaust (Inside)
Ventilation System 30 5616 Diesel Floor Drains Carbon Steel Air - Indoor Stainless Steel Air - Outdoor YES Walk-Down &
Generator Drawings Building 31 5895 Intermediate Supports for ASME Carbon Steel Air - Indoor Florogold None YES FSAR Building Class 1, 2, 3 Piping &
Components 32 2166 Decay Heat Makeup Pump Lube Oil Copper and Lubricating Oil Carbon or Low Air - Indoor YES FSAR Closed Cycle Cooler Components Copper Alloys (Outside) Alloy Steel, Gray Uncontrolled (Outside),
Cooling Cast Iron Lubricating Oil (Inside),
System Closed Cycle Cooling Water (Inside) 33 5550 Circulating Supports for Non- Carbon Steel Air - Outdoor Galvanized Carbon None YES Walk-Down &
Water Intake ASME Piping & Steel Drawings Structure Components 34 6093 Turbine Concrete: Above Grade Reinforced Air - Indoor None Air - Outdoor YES Walk-Down &
Building Concrete Drawings 35 1573 Appendix R Closure bolting Bolting Air - Indoor None None YES Walk-Down &
Control (Carbon or Uncontrolled Drawings Complex Low Alloy (Outside)
Dedicated Steel /
Cooling Stainless Steel)
Supply System