ML100970495
| ML100970495 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/07/2010 |
| From: | Mark Franke NRC/RGN-II/DRS/EB3 |
| To: | Mccartney E Carolina Power & Light Co |
| References | |
| IR-10-008 | |
| Download: ML100970495 (53) | |
See also: IR 05000261/2010008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
SAM NUNN ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW, SUITE 23T85
ATLANTA, GEORGIA 30303-8931
April 07, 2010
Carolina Power and Light Company
ATTN: Mr. Eric McCartney
Vice President - Robinson Plant
H. B. Robinson Steam Electric Plant, Unit 2
3851 West Entrance Road
Hartsville, SC 29550
SUBJECT: H.B. ROBINSON STEAM ELECTRIC PLANT - NRC POST-APPROVAL SITE
INSPECTION FOR LICENSE RENEWAL INSPECTION REPORT
Dear Mr. McCartney:
On February 26, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed a Post-
Approval Site Inspection for License Renewal at your H.B. Robinson Steam Electric Plant,
Unit 2. The enclosed report documents the inspection findings, which were discussed on
February 26, 2010, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter,
its enclosure, and your response (if any), will be available electronically for public inspection in
the NRC Public Document Room or from the Publicly Available Records System (PARS)
component of NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Mark Franke, Chief
Engineering Branch 3
Division of Reactor Safety
Docket No. 50-261
License No. DPR-23
Enclosure: Inspection Report 05000261/2010008
w/Attachment: Supplemental Information
cc w/encl: see Page 2
CP&L 2
cc w/encl: David T. Conley
Eric McCartney Associate General Counsel
Vice President Legal Dept.
H. B. Robinson Steam Electric Plant Unit 2 Progress Energy Service Company, LLC
Carolina Power & Light Company Electronic Mail Distribution
Electronic Mail Distribution
John H. O'Neill, Jr.
R. J. Duncan, II Shaw, Pittman, Potts & Trowbridge
Vice President 2300 N. Street, NW
Nuclear Operations Washington, DC 20037-1128
Carolina Power & Light Company
Electronic Mail Distribution Susan E. Jenkins
Director, Division of Waste Management
Brian C. McCabe Bureau of Land and Waste Management
Manager, Nuclear Regulatory Affairs S.C. Department of Health and
Progress Energy Carolinas, Inc. Environmental Control
Electronic Mail Distribution Electronic Mail Distribution
Christos Kamilaris Scott Saunders
Director Plant General Manager
Fleet Support Services Carolina Power & Light Company
Carolina Power & Light Company Electronic Mail Distribution
Electronic Mail Distribution
Robert P. Gruber
Curt A. Castell Executive Director
Supervisor Public Staff - NCUC
Licensing/Regulatory Programs 4326 Mail Service Center
Carolina Power & Light Company Raleigh, NC 27699-4326
Electronic Mail Distribution
W. Lee Cox, III
B. C. White Section Chief
Manager Radiation Protection Section
Support Services - Nuclear N.C. Department of Environmental
Carolina Power & Light Company Commerce & Natural Resources
Electronic Mail Distribution Electronic Mail Distribution
S. D. West Public Service Commission
Superintendent Security State of South Carolina
H. B. Robinson Steam Electric Plant P.O. Box 11649
Progress Energy Columbia, SC 29211
Electronic Mail Distribution
R. Mike Gandy
Joseph W. Donahue Division of Radioactive Waste Mgmt.
Vice President S.C. Department of Health and
Nuclear Oversight Environmental Control
Carolina Power and Light Company Electronic Mail Distribution
Electronic Mail Distribution
(cc w/encl contd - See page 3)
CP&L 3
(cc w/encl contd)
Chairman
North Carolina Utilities Commission
Electronic Mail Distribution
Senior Resident Inspector
U.S. Nuclear Regulatory Commission
H. B. Robinson Steam Electric Plant
2112 Old Camden Rd
Hartsville, SC 29550
________________ X SUNSI REVIEW COMPLETE
OFFICE RII:DRS RII:DRS RII:DCI RII:DRS RII:DRS RII:DRP RII:DRP RII:DRS
SIGNATURE JER6 LFL CAJ ECM2 REW1 GJK2 by email RXM1 MEF1
NAME JRivera-Ortiz LLake CJulian by email EMichel RWilliams GKolcum RMusser MFranke
DATE 04/05/10 04/01/10 04/07/10 04/01/10 04/05/10 04/05/10 04/06/10 04/07/10
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO YES NO
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No: 50-261
License No: DPR-23
Report No: 05000261/2010008
Licensee: Carolina Power & Light Company
Facility: H.B. Robinson Steam Electric Plant, Unit 2
Location: 3581 West Entrance Road
Hartsville, SC 29550
Dates: February 2, 2010 - February 26, 2010
Inspectors: Joel Rivera-Ortiz, Senior Reactor Inspector (Lead)
Caudle Julian, Senior Construction Inspector
Eric Michel, Senior Reactor Inspector
Louis Lake, Senior Reactor Inspector
Gregory Kolcum, Resident Inspector - Brunswick
Robert Williams, Reactor Inspector
Accompanying Jonathan Kent, Construction Inspector Trainee
Staff:
Approved by: Mark Franke, Chief
Engineering Branch 3
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000261/2010008; 02/08/2010 - 02/26/2010; H.B. Robinson Steam Electric Plant, Unit 2;
Post Approval Site Inspection for License Renewal.
The report covers a team inspection conducted by six regional inspectors in accordance with
NRC Manual Chapter 2516 and NRC Inspection Procedure 71003.
The inspectors determined that commitments, license conditions, and regulatory requirements
associated with the issuance of the renewed operating license were either being met or, where
commitment actions had not been completed, that the licensee had generated tasks in their
Action Request system to track their completion before the period of extended operation.
The team identified one Unresolved Item and eight observations, for which corrective actions
were initiated.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is
described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
A. NRC-Identified and Self-Revealed Findings
None
B. Licensee-Identified Violations
None
Enclosure
REPORT DETAILS
4. OTHER ACTIVITIES
4OA5 Other Activities
.1 Post-Approval Site Inspection for License Renewal - IP 71003
a. Inspection Scope
(1) Implementation of License Conditions and Commitments, including Aging Management
Programs and Time-Limited Aging Analyses
The inspectors reviewed supporting documents including implementing procedures,
work orders, inspection reports, engineering evaluations, condition reports, and
completed surveillance records; conducted interviews with licensee staff; performed
visual inspection of structures, systems, and components (SSCs); and observed a
sample of licensee activities related to license renewal commitments to verify the
licensee completed the necessary actions to comply with the license conditions
stipulated in the renewed facility operating license. The inspectors verified that the
licensee met the commitments associated with the Aging Management Programs
(AMPs) and time-limited aging analyses (TLAAs) described in NUREG-1785, Safety
Evaluation Report (SER) Related to the License Renewal of H.B. Robinson Steam
Electric Plant, Unit 2, in accordance with Title 10 of the Code of Federal Regulations
(CFR) Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power
Plants. For each AMP and TLAA, the inspectors verified that future activities due prior
to the period of extended operation (i.e. July 31st, 2010) were implemented as described
in the Updated Final Safety Analysis Report (UFSAR) supplement submitted pursuant to
10 CFR 54.21(d). For those license renewal action items that were not completed at the
time of this inspection, the team verified that there was reasonable assurance that such
action items were on track for completion prior to the period of extended operation.
The inspectors reviewed licensee actions that were completed (or scheduled) to meet
the commitment items discussed below, which are referenced to Appendix A of the SER.
Specific documents reviewed are listed in the report attachment.
Item 1 - Quality Assurance Program
Commitment Item 1 specified that the existing Quality Assurance Program will be
credited for license renewal. The inspectors reviewed a copy of the current NRC
approved Quality Assurance Program and verified that it contained adequate information
to meet this license renewal commitment.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 1.
Item 2 - 10 CFR 54.37(b) Requirements
Commitment Item 2 specified that upon issuance of the renewed license guidance will
be incorporated into the administrative control procedures that manage the Robinson
Enclosure
4
Nuclear Plants (RNPs) configuration control process to ensure that the requirements of
10 CFR 54.37(b) are met.
The inspectors reviewed the licensing basis and procedures for configuration control to
verify that the licensee implemented the guidance described in the commitment. The
inspectors also reviewed three licensee evaluations performed to identify new in-scope
SSCs since the renewed operating license was issued. The inspectors interviewed the
responsible plant personnel regarding these documents, especially on the methodology
used to identify any new SSCs in scope of license renewal. Additionally, the inspectors
reviewed scheduled tasks in the licensee Action Request (AR) system to verify that the
licensee continuously conduct a review of newly identified SSCs concurrent with the
FSAR update required by 10 CFR 50.71(e).
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 2.
Item 3 - NUREG-1801 GALL Report
Commitment Item 3 specified that prior to the period of extended operation a statement
will be incorporated into the UFSAR license renewal supplement to document
consistency of RNPs AMPs with programs defined in NUREG-1801, Generic Aging
Lessons Learned (GALL) Report. For RNPs programs that are consistent with
NUREG-1801, the program description will be revised to state This program is
consistent with the corresponding program described in the GALL Report.
The inspectors reviewed the current version of the UFSAR to verify that this commitment
was implemented in accordance with the license renewal application (LRA) and the
corresponding SER. At the time of this inspection, this commitment item was partially
completed and additional tasks were pending to be implemented prior to the period of
extended operation. The inspectors conducted interviews with plant personnel in charge
of the UFSAR and reviewed the licensees AR system to verify that this commitment
item was adequately tracked to completion.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 3.
Item 4 - ASME Section XI, Subsection IWB, IWC, and IWD Program
Commitment Item 4 specified that the existing American Society of Mechanical
Engineers Boiler and Pressure Vessel Code (ASME BPVC),Section XI Inservice
Inspection, Subsections IWB, IWC, and IWD aging management program will be part of
the Inservice Inspection (ISI) program. The program provides identification of signs of
degradation, and establishment of corrective actions for condition monitoring of reactor
coolant pressure retaining piping and components within the scope of license renewal.
The inspections will be implemented in accordance with 10 CFR 50.55(a).
The inspectors reviewed the program basis documents, implementing procedures, non-
destructive examination (NDE) records, and related AR records; and interviewed the
Enclosure
5
responsible plant personnel regarding these documents to verify that the program was
implemented as stated in the commitment. The inspectors verified that the licensee
incorporated the statement This program is consistent with the corresponding program
described in the GALL Report into the UFSAR, as required with the clarifications
described in request for additional information (RAI) B.1-1 (d).
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 4.
Item 5 - Water Chemistry Program
Commitment Item 5 specified that the existing Water Chemistry Program will be credited
for license renewal. The inspectors reviewed four current procedures implementing the
Water Chemistry Program and verified that they contained adequate information to meet
this license renewal commitment.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 5.
Item 6 - Reactor Head Closure Studs Program
Commitment Item 6 specified that the existing Reactor Head Closure Studs aging
management program will provide for condition monitoring and preventive activities to
manage stud cracking. The program is implemented through station procedures based
on the examination and inspection requirements specified in ASME Section XI, Table
IWB-2500-1. While RNP is not committed to Regulatory Guide 1.65, "Materials and
Inspection for Reactor Vessel Closure Studs," the preventive measures are consistent
with the regulatory guide. The program is consistent with the ten elements of aging
management program XI.M3, "Reactor Head Closure Studs" specified in NUREG-1801.
The inspectors reviewed the program basis documents, implementing procedures, NDE
records, and related AR records; and interviewed the responsible plant personnel
regarding these documents to verify that the program was implemented as stated in the
commitment. The inspectors also verified that the licensee incorporated the statement
This program is consistent with the corresponding program described in the GALL
Report into the UFSAR, as required with the clarifications described in RAI B.1-1.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 6.
Item 7 - Steam Generator Tube Integrity Program
Commitment Item 7 specified that the existing Steam Generator (SG) Tube Integrity
aging management program will be credited for aging management of the steam
generator tube bundle, tube plugs, tube support plate and anti-vibration bars in the
steam generators at RNP.
Enclosure
6
The program is implemented through station procedures based on the examination and
inspection requirements specified in the SG Tube Integrity Program. The program
specifies inspection scope, frequency, and acceptance criteria for the plugging and
repair of flawed SG tubes in accordance with plant technical specifications and the
guidance of Nuclear Energy Institute (NEI) 97-06, Steam Generator Program
Guidelines. In response to RAI B.2.4-3, RNP will continue to evaluate and implement
new guidance provided by future revisions of NEI 97-06. The program is continually
updated based on industry experience and self-assessment programs.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, NDE records, and related AR records; and interviewed the responsible plant
personnel regarding these documents to verify that the program was implemented as
stated in the commitment. The inspectors also verified that the licensee incorporated the
statement This program is consistent with the corresponding program described in the
GALL Report into the UFSAR, as required with the clarifications described in RAI B.1-1
(d).
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 7.
Item 8 - Closed-Cycle Cooling Water System Program
Commitment Item 8 specified that the existing Closed-Cycle Cooling Water System will
be credited for license renewal and that no changes are required.
The inspectors reviewed the licensing basis, Closed-Cycle Cooling Water System
program basis document, implementing procedures, chemistry results, and related AR
records; and interviewed the responsible plant personnel regarding these documents to
verify that the program was implemented as stated in the commitment.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 8.
Item 9 - ASME Section XI, Subsection IWF Program
Commitment Item 9 specified that the existing ASME BPVC,Section XI, Subsection IWF
Program will be credited for aging management of Class 1, 2, and 3 component supports
(including piping supports) for loss of material due to general corrosion. The existing
program is a condition monitoring program that provides for the implementation of ASME
Code Section XI, Subsection IWF, in accordance with the provisions of 10 CFR 50.55a.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, and related AR records to verify that the program was implemented as
stated in the commitment. The inspectors verified that program documents were
administratively updated to reflect their applicability to license renewal commitments.
Additionally, the inspectors interviewed the responsible plant personnel regarding these
documents and verified that no outstanding tasks remained open for this commitment.
Enclosure
7
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 9.
Item 10 - 10 CFR 50, Appendix J Program
Commitment Item 10 specified that the existing 10 CFR 50, Appendix J Program will be
credited for license renewal with no planned changes. The existing program detects
degradation of the containment pressure boundary through inspections of accessible
surfaces of the containment and monitoring of leakage rates through containment
liner/welds, penetrations, fittings and access openings. This program directs the
performance of Type A, B and C leak rate tests and meets the requirements of Option A
of 10 CFR 50, Appendix J, Section III for Type B and C tests and Option B of 10 CFR
50, Appendix J, Section III for Type A tests. This program is implemented in accordance
with 10 CFR 50, Appendix J, Regulatory Guide 1.163, Performance-Based Containment
Leak-Test Program and NEI 94-01, Industry Guideline for Implementing Performance-
Based Option of 10 CFR Part 50, Appendix J, Revision 0.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, and related AR records to verify that the program was implemented as
stated in the commitment. The inspectors verified that program documents were
administratively updated to reflect their applicability to license renewal commitments.
Additionally, the inspectors interviewed the responsible plant personnel regarding these
documents, verified that no outstanding tasks remained open for this commitment and
reviewed recent local leak rate test (LLRT) results.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 10.
Item 11 - Flux Thimble Eddy Current Inspection Program
Commitment Item 11 specified that the existing Flux Thimble Eddy Current Inspection
Program will be credited for license renewal with no planned changes. The existing Flux
Thimble Eddy Current Inspection Program determines the amount of wear on the flux
thimbles and whether the amount of wear expected to occur during the next inspection
interval will cause the total amount of wear to exceed the ASME standards specified for
the examination. The Flux Thimble Eddy Current Inspection Program was implemented
to satisfy NRC Bulletin 88-09 requirements that a thimble tube wear inspection
procedure be established and maintained for Westinghouse-supplied reactors that use
bottom mounted flux thimble tube instrumentation.
The inspectors reviewed program implementing procedure EST-108, Flux Thimble Eddy
Current Inspection (Specified Refueling Outages), Revision 8 and verified that it
contained adequate information to meet this license renewal commitment. Additionally,
the inspectors examined records of the last thimble tube eddy current inspection
conducted in September 2005. Based on past positive results, RNP has currently
extended the frequency of inspection to every third refueling outage.
Enclosure
8
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 11.
Item 12 - Fire Protection Program
Commitment Item 12 specified that prior to the period of extended operation the existing
Fire Protection Program will be credited and will be enhanced to note that concrete
surface inspections performed under structures monitoring procedures are credited for
inspection of fire barrier walls, ceilings, and floors. The required enhancement was
originally added to the System Walkdown Procedure, TMM-104. The inspectors found
that the enhancement was being moved to the Structural Inspection Procedure, EGR-
NGGC-0351. The licensee was tracking this action through Procedure Revision
Request (PRR) 353128 and AR item 365673-09.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation. The inspectors reviewed the existing procedures and draft proposed
procedures to verify that the program was implemented as stated in the commitment.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 12.
Item 13 - Boric Acid Corrosion Program
Commitment Item 13 specified that prior to the period of extended operation the scope of
the Boric Acid Corrosion Control Program (BACCP) will be expanded to ensure that the
mechanical, structural and electrical components in scope for license renewal are
addressed and to identify additional areas in which components are susceptible to
exposure from boric acid. The existing BACCP manages the aging effects for
susceptible materials of structures and components exposed to the effects of borated
water leaks. The program consists of visual inspections of external surfaces potentially
exposed to borated water leakage, timely discovery of leak path and removal of boric
acid residues, damage assessment, and follow-up inspections for adequacy of corrective
actions. This program is implemented in response to NRC Generic Letter 88-05, Boric
Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR
Plants.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, program assessments, and related AR records to verify that the program
was implemented as stated in the commitment. The inspectors verified that program
documents were administratively updated to reflect their applicability to license renewal
commitments, interviewed the responsible plant personnel regarding these documents,
and verified that no outstanding tasks remained open for this commitment and that the
required procedural updates listed in the commitment were implemented.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 13.
Enclosure
9
Item 14 - Flow-Accelerated Corrosion Program
Commitment Item 14 specified that prior to the period of extended operation the Flow-
Accelerated Corrosion (FAC) Program will be modified to: (1) include additional
components potentially susceptible to flow-accelerated corrosion and/or erosion, and (2)
clarify when condition reports shall be initiated. In its response to RAI B.3.3-2b, the
licensee stated that the components to be added to the program as a result of the aging
management review (AMR) were the steam nozzles, feedwater nozzles, SG nozzle
thermal sleeves, and temperature elements (thermowells). The licensee also stated that
the program will be enhanced to inspect for erosion wear in locations deemed to be
susceptible by the system engineer. In addition, the licensee stated that the FAC
program will be revised to add a section dedicated specifically to valves. An additional
requirement will be added to program procedures to require material alloy analysis for
potentially susceptible valves. For corrective actions, the FAC Program procedure will
be revised to state that a condition report shall be initiated in accordance with the
Corrective Action Program for through-wall failures, or when actual wall thickness is
found to be substantially less than the expected value.
The inspectors reviewed the licensing basis, program basis documents, AR records, and
implementing procedures; and interviewed the responsible plant personnel regarding
these documents to verify that the program was implemented as stated in the
commitment. The inspectors verified that the licensee implemented the program
changes in accordance the LRA and the corresponding SER.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 14.
Item 15 - Bolting Integrity Program
Commitment Item 15 specified that prior to the period of extended operation the
administrative controls of the Bolting Integrity Program will be modified to prohibit the
use of molybdenum disulfide compounds in high-strength bolting applications. In
addition, the commitment stated that an inspection and evaluation will be performed on
high-strength bolting used on CVC-381, reactor coolant pump seal water return isolation
valve, to address susceptibility to cracking. The existing Bolting Integrity Program will be
credited for license renewal and consists of the preventive and condition monitoring of
pressure retaining bolted joints for piping and components for age-related degradation to
discover and correct conditions that could lead to a loss of intended function. The
existing program activities consist of visual inspections for degradation and leakage that
are implemented through various station procedures, preventive maintenance and
routine observation activities.
The inspectors reviewed the licensing basis, the Bolting Integrity Program basis
documentation, implementing procedures, planned and completed work orders, related
corrective action documents, and interviewed responsible program personnel regarding
Enclosure
10
these documents to verify that the program was implemented as stated in the
commitment.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 15.
Item 16 - Open Cycle Cooling Water System Program
Commitment Item 16 specified that prior to the period of extended operation the existing
Open-Cycle Cooling Water System program will be credited for license renewal and the
program will be enhanced by scheduling an activity in the site Preventive Maintenance
Program to replace cooling coils in the emergency core cooling system room coolers
with a material resistant to erosion/corrosion on a prescribed frequency.
The inspectors reviewed the licensing basis, the Open-Cycle Cooling Water System
program basis document, planned and completed work orders, AR records, and
inspection procedures to verify that the program was implemented as stated in the
commitment.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 16.
Item 17 - Inspection of Overhead Heavy Load and Light Load Handling
Commitment Item 17 specified that prior to the period of extended operation the
administrative controls for the inspection of overhead heavy load and light load handling
will be enhanced to: (1) include requirements for inspecting the turbine gantry crane in
addition to other cranes that require inspection, (2) note that cranes are to be inspected
using the attribute inspection checklist for structures, and (3) revise the attribute
inspection checklist for structures to include GALL terminology such as wear. The
existing program manages the effects wear on the rail systems and the effects of
general corrosion on the following cranes: the polar crane, the spent fuel cask crane, the
spent fuel bridge crane and the turbine gantry crane. The listed cranes are inspected
using guidance from NUREG-0612, Control of Heavy Loads at Nuclear Power Plants
and to satisfy American National Standard Institute (ANSI) B30.2, Overhead and Gantry
Cranes requirements for inspection attributes such as steel member corrosion,
damaged members or connections, and missing parts amongst others.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, previous inspection reports, and related AR records to verify that the
program was implemented as stated in the commitment. The inspectors verified that
program documents were administratively updated to reflect their applicability to license
renewal commitments. Additionally, the inspectors interviewed the responsible plant
personnel regarding this program, verified that the above listed license renewal cranes
Enclosure
11
were properly scoped to comply with the maintenance rule requirements provided in 10
CFR 50.65, verified that the inspection frequencies were properly translated into
procedures and that the required procedural updates were implemented.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 17.
Item 18 - Fire Water System Program
Commitment Item 18 specified that the existing Fire Water System Program will be
credited and will be enhanced for license renewal. The Fire Protection Sprinkler
Systems will be modified to include the following: (1) for sprinkler heads in service for 50
years either sprinkler head replacement or sampling field service testing of heads in
accordance with National Fire Protection requirements and, (2) prior to the period of
extended operation, either full flow testing of portions of fire protection wet pipe sprinkler
systems through the system cross mains, which are not routinely subject to flow, at the
greatest flow and pressure allowed by the design of the systems or alternatively
inspections or ultrasonic (UT) testing of a representative sample of these systems.
Results from initial tests or inspections, reflecting 40 years of service, will be used to
determine the scope and subsequent test/inspection intervals. The intervals are not
expected to exceed 10 years.
Commitment Item 18 also specified that prior to the period of extended operation UT
inspections will be performed on a representative sampling of the above ground fire
protection piping (Fire Protection Suppression Piping) normally containing water. Each
sampling will include different sections of piping. Alternatively, internal inspections may
be conducted on a representative sampling of these piping systems. Results from initial
tests or inspections, reflecting 40 years of service, will be used to determine the scope
and subsequent test/inspection intervals. The intervals are not expected to exceed 10
years.
Furthermore, Commitment Item 18 specified that for Halon/Carbon Dioxide Fire
Suppression Systems, the NRC staff guidance with respect to Halon/Carbon Dioxide fire
suppression systems will be implemented prior to the period of extended operation. The
guidance is documented in a letter from C. Grimes (NRC) to A. Nelson (NEI) and D.
Lochbaum (Union of Concerned Scientists): Proposed Staff Guidance on Management
of Fire Protection Systems for License Renewal, dated January 28, 2002.
The inspectors found that the licensee has performed various inspections and additional
inspections are scheduled to be completed prior to the period of extended operation.
Among the completed inspections, Work Order (WO) 1120123 previously cut into the
main piping to the component cooling water (CCW) sprinkler system to allow a new
branch line to be installed. Licensee engineering staff performed an internal inspection
of the removed piping and the condition was documented as satisfactory. In addition, an
internal inspection of the Fuel Handling Building piping has already been completed
under WO 706919-02.
The inspectors also noted that the following inspection activities were scheduled to meet
this commitment: (a) Work Order 1549734 will replace the sprinkler heads in the CCW
Pump Room which are the oldest set of inservice sprinkler heads. Other WOs have
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been prepared to replace newer sprinkler heads as they approach the 50 year age, (b)
WO 1519261 will perform an UT thickness examination on various piping segments
based on the inservice date of the affected systems. The UT inspections of the above
ground segments of Fire Water piping include a sampling at five locations within the
power block, (c) WO 1605254 will perform UT inspections on a section of the Auxiliary
Building supply piping and hose station supply piping near hose station FH-78 on pipe
line 2-FP-18, and (d) Turbine Building piping and Auxiliary Building/CV piping will be
inspected under the Transformer Replacement Project during refueling outage (RO)-26.
The transformer deluge piping represents original plant piping and will be inspected and
replaced. Periodic inspections will be established under Preventive Maintenance
Requests (PMRs) 348790 and 348792.
The proposed Staff guidance of January 28, 2002 gave the Staffs position that a valve
lineup inspection, charging pressure inspection, and automatic mode of operation
verification are operational activities and are not aging management related. NUREG-
1801, GALL Report, was revised by the NRC in September of 2005 to remove the
Halon/Carbon Dioxide system inspections for charging pressure, valve lineups, and
automatic mode of operation. The inspectors found that RNPs practices conform to that
guidance.
The licensee has numerous fire water piping inspections to be completed prior to the
period of extended operation. These items appeared to be identified and scheduled to
be accomplished in the remaining time period before the start of the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 18.
Item 19 - Buried Piping and Tanks Surveillance Program
Commitment Item 19 specified that prior to the period of extended operation a review will
be conducted to determine the need to update administrative controls for the Buried
Piping and Surveillance program to ensure consistency with National Association of
Corrosion Engineers (NACE) Standard RP-0169-96. In particular, the cathodic
protection program and additional leak testing measures for underground piping are to
be evaluated.
The inspectors reviewed the licensing basis, implementing procedures, related work
orders, contractor surveys, associated engineering change package, and related ARs;
and interviewed the responsible plant personnel regarding these documents. The
inspectors verified that the licensees cathodic protection program incorporated the
requirements of NACE Standard SP-0169-2007. The inspectors also verified the
licensee had conducted an adequate evaluation to ensure consistency between RP-
0169-96, and the most recently published version, SP-0169-2007.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
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13
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 19.
Item 20 - Above Ground Carbon Steel Tanks Program
Commitment Item 20 specified that the existing Above-Ground Carbon Steel Tanks
program will be credited for license renewal with enhancements. Prior to the period of
extended operation administrative controls for the Above Ground Carbon Steel Tanks
Program will be revised to indicate that the external surfaces of the fuel oil tanks are to
be inspected periodically and to incorporate corrective action requirements.
The inspectors reviewed the licensing basis, the Above-Ground Carbon Steel Tanks
program basis documentation, implementing procedures, scheduled and completed
work orders, related ARs, engineering changes, and evaluations to verify that the
program was implemented as stated in the commitment. The inspectors also conducted
a plant walkdown to observe the present condition of the above ground tanks. The
inspectors identified a discrepancy associated with the operating procedure for the
Alternate Fuel Oil Storage Tank. This issue is discussed in details in the Findings and
Observation section of this inspection report.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, the administrative controls in place to track pending actions,
and the corrective actions initiated for the inspectors observations, the inspectors
determined that there was reasonable assurance that the licensee would complete the
necessary actions to meet Commitment Item 20.
Item 21 - Fuel Oil Chemistry Program
Commitment Item 21 specified that prior to the period of extended operation the
administrative controls for the fuel oil chemistry program will be enhanced to improve
sampling and de-watering of selected storage tanks, formalize existing practices for
periodically draining and filling the diesel fuel oil storage tank (FOST), formalize bacteria
testing for fuel oil samples from various tanks, and incorporate quarterly trending of fuel
oil chemistry parameters.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, and related AR records; and interviewed the responsible plant personnel
regarding these documents. The inspectors verified that the licensee appropriately
modified their procedures to improve the sampling and de-watering of identified fuel oil
storage tanks in their monthly surveillance procedure; formalized existing practices for
draining and filling the diesel FOST at an interval not to exceed 10 years; initiated
actions to formalize bacteria testing; and ensured fuel oil chemistry will be trended
quarterly by the appropriate system engineer.
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At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 21.
Item 22 - Reactor Vessel Surveillance Program
Commitment Item 22 specified that prior to the period of extended operation the
administrative controls for the Reactor Vessel Surveillance Program will be revised to
require surveillance test samples to be stored in lieu of optional disposal. The Reactor
Vessel Surveillance Program administrative controls are implemented through Section
5.3.1.6 of the UFSAR, Material Surveillance.
The inspectors reviewed the licensing basis, program basis documents, AR records, and
implementing procedures; and interviewed the responsible plant personnel regarding
these documents. The inspectors verified that the licensee implemented the
commitment in the applicable section of the UFSAR in accordance the LRA and the
corresponding SER.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 22.
Item 23 - Buried Piping and Tanks Inspection Program
Commitment Item 23 specified that prior to the period of extended operation the Buried
Piping and Tanks Inspection program will be enhanced to: (1) require that an appropriate
as-found pipe coating and material condition inspection is performed whenever buried
piping within the scope of this program is exposed, (2) add precautions to ensure backfill
with material that is free of gravel or other sharp or hard material that can damage the
coating, (3) require that the coating inspection be performed by qualified personnel to
assess its condition, and (4) require that a coating engineer assist in evaluation of any
coating degradation noted during the inspection.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures; and interviewed the responsible plant personnel regarding these
documents. The inspectors verified that the licensee modified their excavation and
backfill procedure (MNT-NGGC-0024) to inspect buried piping as the piping is exposed,
ensured that backfill material selection does not include gravel or other hard material,
verified qualified personnel perform coating inspections, and that a coating engineer will
assist in evaluating coating degradation.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 23.
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Item 24 - ASME Section XI, Subsection IWE Program
Commitment Item 24 specified that prior to the period of extended operation the
administrative controls for the ASME BPVC,Section XI, Subsection IWE Program will be
enhanced to specify the requirements for conducting reexaminations and to document
that repairs meet the specified acceptance standards. The existing program conducts
periodic visual, surface and volumetric inspections of the steel containment components
to detect signs of degradation, assess any damage and correct deficiencies. The
program provides for the implementation of ASME Code Section XI, Subsection IWE, in
accordance with the provisions of 10 CFR 50.55a. Containment pressure retaining seals
and gaskets were excluded from this program based upon a relief request granted by
the NRC. This request states that VT-3 examinations of seals and gaskets required by
Table IWE-2500-1, Category E-D, Items E5.10 and E5.20 are not required to be
performed. Instead, 10 CFR 50, Appendix J, Type B testing is used for the seals and
gaskets. The licensee also identified One-time Inspection Programs for completing the
inspection of inaccessible portions of the containment liner and the moisture barrier
inside the containment at the liner plate/floor concrete interface.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, and related AR records to verify that the program was implemented as
stated in the commitment. The inspectors verified that program documents were
administratively updated to reflect their applicability to license renewal commitments.
The inspectors reviewed a sample of engineering evaluations for the metal containment
liner thickness and ensured that any areas of less than the minimum required thickness
were properly dispositioned and repaired, if necessary. Additionally, the inspectors
interviewed the responsible plant personnel regarding this program and verified that no
outstanding tasks remained open for this commitment.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 24.
Item 25 - ASME Section XI, Subsection IWL Program
Commitment Item 25 specified that the ASME BPVC,Section XI, Subsection IWL
Program will be enhanced to: (1) require supervisors to notify civil/structural design
engineering of the location and extent of proposed excavations of foundation concrete,
(2) require inspection of below-grade concrete when excavated for any reason to
monitor for potential effects, and (3) inspect above-grade accessible concrete and
include trending requirements for structures based on aggressive ground water. The
existing program is a condition monitoring program that provides for the implementation
of the ASME Code Section XI, Subsection IWL, in accordance with the provisions of 10
CFR 50.55a with the exception that the grouted tendon system used in the RNPs
containment is outside the scope of Subsection IWL.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, and related AR records to verify that the program was implemented as
stated in the commitment. The inspectors verified that program documents were
administratively updated to reflect their applicability to license renewal commitments,
interviewed the responsible plant personnel regarding this program and verified that the
required procedural updates listed in the commitment were implemented.
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Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 25.
Item 26 - Structures Monitoring Program
Commitment Item 26 specified that prior to the period of extended operation the
administrative controls for the Structures Monitoring Program will be enhanced to: (1)
include buildings, structures and their associated acceptance criteria, in scope for
license renewal but outside the scope of Maintenance Rule, (2) identify interfaces
between structures monitoring inspections of concrete surfaces and the Fire Protection
Program requirements for barriers, (3) state clearly the boundary definition between
systems and structures, (4) revise administrative controls to provide inspection criteria
for portions of systems covered by structures monitoring and require a condition report
be initiated for all inspection attributes found to be unacceptable, (5) expand system
walkdown inspection criteria to include observation of adjacent components, (6) inspect
above-grade accessible concrete, (7) revise personnel responsibilities to include: (a)
providing assistance in evaluating structural deficiencies when requested by the
Responsible Engineer, (b) inspecting excavated concrete, and (c) notifying
civil/structural design engineering of the location and extent of proposed excavations,
and (8) to include trending requirements for structures based on aggressive ground
water and lake water. The existing program consists of periodic inspection and
monitoring of the condition of structures and structure component supports to ensure
that aging degradation leading to the loss of intended functions will be detected and that
the extent of degradation will be determined. The inspection criteria are based on
American Concrete Institute (ACI) 349.3R-96, American Society of Civil Engineers
(ASCE) 11-90, Institute of Nuclear Power Operations (INPO) Good Practice Document
85-033, NEI 96-03 and Nuclear Management and Resources Council (NUMARC) 93-01.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, and related AR records. The inspectors verified that program documents
were administratively updated to reflect their applicability to license renewal
commitments, interviewed the responsible plant personnel regarding this program and
verified that the required procedural updates listed in the commitment were
implemented. Additionally, the inspectors accompanied plant personnel during a
structures monitoring walkdown of sections of the auxiliary feedwater (AFW) system.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 26.
Item 27 - Dam Inspection Program
Commitment Item 27 specified that prior to the period of extended operation the
administrative controls for the Dam Inspection Program system monitoring will be
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enhanced to: (1) identify the Recommended Guidelines for Safety Inspection of Dams
as the required management program document for the dam, (2) require the responsible
system engineer to review the inspection report and initiate corrective actions for any
unacceptable attributes, (3) include Recommended Guidelines for Safety Inspections of
Dams as the applicable inspection guidance in the inspection procedure for RNP, (4)
inspect above-grade accessible concrete, (5) inspect submerged spillway concrete on a
frequency not to exceed ten years, and (6) include trending requirements for structures
based on aggressive ground and lake water. The existing Dam Inspection Program
manages aging effects for the Lake Robinson Dam and its associated concrete and steel
structures. This program is currently implemented by an independent inspection using
the Federal Energy Regulatory Commission (FERC)/U.S. Army Corps of Engineers
Recommended Guidelines for Safety Inspection of Dams.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, prior inspection results, and related AR records. The inspectors verified that
program documents were administratively updated to reflect their applicability to license
renewal commitments, interviewed the responsible plant personnel regarding this
program and verified that the required procedural updates listed in the commitment were
implemented.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 27.
Item 28 - Systems Monitoring Program
Commitment Item 28 specified that prior to the period of extended operation the
administrative controls of the existing Systems Monitoring Program will be enhanced to:
(1) include aging effects identified in the AMRs, (2) identify inspection criteria in checklist
form, (3) include guidance for inspecting connected piping/components, (4) require that
the extent of degradation be recorded and that appropriate corrective action(s) be taken,
(5) add a section specifically addressing corrective actions, and (6) ensure Loss of
Material due to Wear is specifically included as an aging effect/mechanism identified in
the system walkdown checklist. The first five items were included in the LRA while the
sixth item was a commitment included in the licensees response to RAI B.3.17-1.
The inspectors reviewed the licensing basis, current program procedures, reviewed a
sample of documented results of system walkdowns, and discussed the program with
licensee representatives to verify that the program was implemented as stated in the
commitment. The inspectors identified three examples where the licensee did not fully
implement certain attributes of the commitment. These issues are discussed in the
Findings and Observations section of this inspection report.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and corrective actions generated for the observations
identified by the team, the inspectors determined that there was reasonable assurance
that the licensee would complete the necessary actions to meet Commitment Item 28.
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Item 29 - Preventive Maintenance Program
Commitment Item 29 specified that prior to the period of extended operation the existing
Preventive Maintenance (PM) Program will be enhanced to: (1) include aging
effects/mechanisms identified in the AMRs, and (2) incorporate specific aging
management activities identified in the AMRs into the program.
The inspectors reviewed the licensing basis and implementing procedures to verify that
the program was implemented as stated in the commitment. The inspectors verified that
the program procedures contained adequate information to meet this commitment item.
In 2008 the licensee performed a self assessment of license renewal implementation
and concluded that the preventive maintenance program needed enhancement.
Corrective action document NCR 365671 was initiated to document that PM and model
work orders were not specific enough for the aging mechanism to be inspected. Action
tasks have been identified to enhance various PMs and all have due dates in July 2010
before the period of extended operation. The inspectors counted 22 open work items to
be completed for enhancement of procedures and PM activities.
The inspectors noted that the licensee has numerous procedure revisions pending
completion to implement enhancements related to this license renewal commitment.
These items appeared to be identified and scheduled to be accomplished in the
remaining time period before the start of the period of extended operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 29.
Item 30 - Metal Fatigue of Reactor Coolant Pressure Boundary (Fatigue Monitoring
Program) and Item 43 - TLAA: Metal Fatigue
Commitment Items 30 and 43 specified that prior to the period of extended operation the
Fatigue Monitoring Program (FMP) load/unload transient limit will be reduced to provide
the margin needed for consideration of reactor water environmental effects. In its
response to RAI B.3.19-3, the licensee stated that the FMP will account for
environmental effects prior to the period of extended operation. As stated in section
3.0.3.1 of the SER, environmental fatigue calculations were performed for the seven
locations specified in NUREG/CR-6260 and for the seven locations inside the
pressurizer using the Fen methodology contained in NUREG/CR-6583 for carbon/low-
alloy steel material and in NUREG/CR-5704 for stainless steel material. The number of
load/unload cycles used as an input to one of the environmental fatigue calculations was
reduced from 29,000 to 19,000, and the licensee planned to reduce the FMP limit for
load/unload cycles accordingly, thereby incorporating the environmental fatigue
calculations into the FMP.
Commitment Item 43 also specified that based upon the most recent fatigue analysis
performed for the three AFW-to-feedwater (FW) line connections downstream of the
steam-driven pump, transient limits have been reduced in the RNPs FMP. These
reduced limits are based upon inputs used in the analysis and are more conservative
Enclosure
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than the original limits. The reduced limits will remain in effect until the connections are
further analyzed, repaired, or replaced to assure the connections remain within their
design basis through the period of extended operation.
Section 4.3.2.3 of the SER, Environmentally Assisted Fatigue Evaluation and
Commitment Item 43 also states that the pressurizer surge line components for which
the environmentally assisted fatigue (EAF)-adjusted cumulative usage factor (CUF)
would exceed 1.0 during the period of extended operation will be managed using one or
more of the following options: (1) further refinement of the fatigue analyses to maintain
the EAF-adjusted CUF below 1.0, (2) repair of the affected locations, (3) replacement of
the affected locations, or (4) management of the effects of fatigue through the use of an
augmented ISI program that has been reviewed and approved by the NRC.
The inspectors reviewed the licensing basis, program basis documents, AR records,
implementing procedures and environmental fatigue evaluations for the pressurizer; and
interviewed the responsible plant personnel regarding these documents. The inspectors
verified that the licensee implemented the load/unload transient limits in the
implementing procedures; including the transient limits for the AFW-to-FW line
connections, in accordance the LRA and the corresponding SER. In addition, the
inspectors verified which option the licensee selected to manage environmentally
assisted fatigue in the pressurizer surge line. The inspectors noted that the licensee
opted for further refinement of the pressurizer surge line fatigue analysis to maintain the
EAF-adjusted CUF below 1.0.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Items 30 and 43.
Item 31 - Nickel-Alloy Nozzles and Penetrations Program
Commitment Item 31 specified that the Nickel-Alloy Nozzles and Penetrations Program
is a new program that will incorporate the following: (1) evaluations of indications will be
performed under the ASME BPVC,Section XI program, (2) corrective actions for
augmented inspections will be performed in accordance with repair and replacement
procedures equivalent to those requirements in ASME BPVC,Section XI, (3) RNP will
maintain its involvement in industry initiatives and will systematically assess for
implementation applicable programmatic enhancements, that are agreed upon between
the NRC and the nuclear power industry to monitor for, detect, evaluate, and correct
cracking in the vessel head penetration (VHP) nozzles, specifically as the actions relate
to ensuring the integrity of VHP nozzles in the RNP upper reactor vessel head during the
extended period of operation, and (4) RNP will submit, for review and approval, its
inspection plan for the Nickel-Alloy Nozzles and Penetrations Program, as it will be
implemented from the licensees participation in industry initiatives, prior to July 31,
2009.
The inspectors reviewed the licensing basis, program basis documents, AR records,
implementing procedures; and interviewed the responsible plant personnel regarding
these documents. The inspectors verified that the licensee implemented the
commitment items related to the evaluation of indications, the corrective actions for
augmented inspections, and continuous involvement in industry initiatives into the
implementing procedures. In addition, the inspectors verified that the licensee submitted
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the inspection plan for NRC review and approval in accordance with the LRA and the
corresponding SER. The inspectors identified a discrepancy in the aforementioned
inspection plan with regard the schedule of non-visual examinations for the VHP
nozzles. The inspectors also noted a discrepancy with regard the referenced regulatory
requirements for the inspection of upper VHP nozzles. Both issues are discussed in
details in the Findings and Observations section of this inspection report.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and corrective actions initiated to address the inspectors
observations, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 31.
Item 32 - Thermal Aging Embrittlement and Cast Austenitic Stainless Steel Program
Commitment Item 32 specified that prior to the period of extended operation the licensee
will implement the Thermal Aging Embrittlement and Cast Austenitic Stainless Steel
(CASS) Program, which is applied to CASS components within Class 1 boundaries of
the reactor coolant system (RCS) and connected systems where operating temperature
exceeds the threshold criterion. This program will be credited for managing loss of
fracture toughness due to thermal embrittlement of the CASS materials. Specifically, the
program covers primary coolant loop piping, valves, and pump casings. This program is
implemented through the examination requirements in Table IWB-2500-1 of the ASME
The inspectors reviewed the licensing basis, program basis documents, AR records,
implementing procedures; and interviewed the responsible plant personnel regarding
these documents. The inspectors verified that the licensee implemented the
examination requirements of Table IWB-2500-1 in the implementing procedures,
including the ISI Inspection Plan for the current Interval in accordance the LRA and the
corresponding SER. The inspectors found a discrepancy in the implementing
procedures for this commitment with regard the description of components within the
scope of the program. This issue is discussed in details in the Findings and
Observations section of this inspection report.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the corrective actions initiated for the inspectors
observations, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 32.
Item 33 - Pressurized Water Reactor Vessel Internals Program
Commitment Item 33 specified that the Pressurized Water Reactor Vessel Internals
Program (PWR VIP) will be instituted as a new program which will require the licensee
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to: (1) continue participation in industry programs to investigate aging effects and
determine the appropriate AMP activities to address baffle and former assembly issues,
and to address change in dimensions due to void swelling; (2) as appropriate, evaluate
and implement the results of Westinghouse Owners Group (WOG) and Electric Power
Research Institute/Materials Reliability Program (EPRI/MRP) research projects as they
are completed; and (3) implement an augmented inspection during the license renewal
term. Augmented inspections, based on required program enhancements resulting from
industry programs, will become part of the ASME Code,Section XI program. Corrective
actions for augmented inspections will be developed using repair and replacement
procedures equivalent to those requirements in ASME Code,Section XI. The licensee
will submit, for review and approval, its inspection plan for the PWR VIP, as it will be
implemented from the licensees participation in industry initiatives, 24 months prior to
the augmented inspection.
The inspectors reviewed the licensing basis, program basis documents, implementing
procedures, and related AR records; and interviewed the responsible plant personnel
regarding these documents to verify that the program was implemented as stated in the
commitment. Specifically, the inspectors reviewed ADM-NGGC-0012, Reactor Coolant
System Material Integrity Management Program, Revision 2 and verified the
commitment to continue participation in industry programs, as well as the commitment to
implement appropriate results of WOG and EPRI/MRP research projects. The
inspectors also reviewed documentation and interviewed responsible personnel to
evaluate the licensees plans to implement an augmented inspection program as part of
the ASME Section XI program, including the requirement to conduct repair and
replacement activities in accordance with Section XI repair/replacement activities. The
inspectors also verified the PWR VIP inspection plan, based on documents MRP-227
and MRP-228, was submitted to the NRC 24 months prior to this inspection.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 33.
Item 34 - One-Time Inspection Program
Commitment 34 specified that prior to the period of extended operation the One Time
Inspection Program AMP will require one-time inspections of selected plant equipment to
be performed to verify that current plant AMPs are effective in managing the effects of
aging prior to the period of extended operation. The One-Time inspection program
provides for examinations of representative materials in environments that are not
expected to experience aging effects. The licensee established separate one-time
inspection programs covering the following specific SSCs listed in the SER for this
commitment.
(a) CCW heat exchanger tubing - Inspection of CCW heat exchanger tubing will be
performed to assure that potential degradation due to erosion is managed.
During RO-25, the B CCW heat exchanger was re-tubed. A population of the
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existing tubes were pulled and measured to obtain the as-found condition of the
tube wall. From this inspection, the licensee determined that the remaining CCW
heat exchanger A will be re-tubed in RO-26. In addition preventative
maintenance activities have been established to perform eddy current testing for
both heat exchangers on a maximum of 6 year frequency.
(b) Steam and Power Conversion Systems - Representative locations in
miscellaneous piping in steam and power conversion systems protected by the
Water Chemistry Program will be inspected. The licensee performed 21
inspections of steam and power conversion systems in 2004 during RO-22. An
additional 13 inspections are scheduled for RO-26. The inspection locations
were selected based on material and environments that would represent leading
indicators of aged related degradation.
(c) Small Bore RCS piping - The small bore RCS and connected piping will be
inspected to verify the effectiveness of the water chemistry system. The licensee
selected the components based on accessibility exposure levels, nondestructive
examination techniques, and locations identified in NRC Information Notice 97-
46, Unisolable Crack in High-Pressure Injection Piping. A total of 131 welds are
within the inspection scope. Seven welds were ultrasonically examined during
RO-25 and an additional 20 examinations are planned for RO-26 in 2010.
(d) Emergency Diesel Generator (EDG) Exhaust Silencers - EDG exhaust silencers
were inspected and cleaned in 2006. The results of the inspection were
satisfactory. In lieu of performing periodic inspections, the licensee established a
plan for preventive maintenance and replacement of the silencers in RO-26.
(e) Inaccessible Areas of Containment Liner Plate and Moisture Barrier -
Inaccessible areas of the containment liner plate and moisture barrier were
inspected during RO-22. Although only a portion of the moisture barrier was
degraded, the moisture barrier was removed and replaced. Inspection of the
moisture barrier is routinely examined as part of the Section XI IWE Program.
(f) Diesel Fire Pump Fuel Oil Tank - Internal inspections and ultrasonic
examinations were satisfactorily completed in November of 2006.
(g) Steam generator feed ring/J-nozzles - The steam generator feed water ring and
J nozzles were satisfactorily examined as follows: SG-A in September 1999, SG-
B in 2007, and SG-C in October 2002. The SG feed water rings and J nozzles
are routinely examined as part of the SG Tube Integrity Program.
The inspectors reviewed the program basis document, implementing procedures,
inspection results, and related AR records; and interviewed the responsible plant
personnel regarding these documents to verify that the program was implemented as
stated in the commitment. The inspectors verified that the licensee had documented the
results of the one-time inspections and had followed up appropriately when aging effects
were identified.
The inspectors determined that the licensee had performed a substantial portion of the
inspections, and the remaining inspections, required by this commitment, were
scheduled to be completed prior to the period of extended operation.
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Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 34.
Item 35 - Selective Leaching of Materials Program
Commitment Item 35 specified that prior to the period of extended operation the
Selective Leaching of Materials Program will be a new program to determine the
properties of selected components that may be susceptible to selective leaching. The
program will ascertain whether loss of material is occurring and whether the process will
affect the ability of the components to perform their intended function for the period of
extended operation.
The inspectors found that this program was being implemented by conducting one-time
visual inspections of a sample of materials susceptible to selective leaching of materials
prior to the period of extended operation. The scope of the visual inspections included
susceptible components that are exposed to chemically treated water, demineralized
water, raw water, ground water, and moist ventilation and gas environments. The
inspectors observed the licensee perform an inspection of the interior of a fire water
control valve FR 412 for selective leaching. The inspection was performed adequately
and no indication of selective leaching was observed.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 35.
Item 36 - Non-Environmentally Qualified Insulated Cables and Connections Program
Commitment Item 36 specified that the Non-Environmentally Qualified (Non-EQ)
Insulated Cables and Connections Program will be a new program and involves
inspecting accessible power and instrument and control cables at least once every 10
years. This Commitment Item also states that prior to the period of extended operation
the licensee will define the technical basis for selecting a sample of cables to be
inspected. The sample locations consider cables inside and outside containment, as
well as any known adverse localized environments. The licensee defined an adverse
localized environment as a condition in a limited plant area that is significantly more
severe than the specified service condition for the electrical cable or connection. The
Non-EQ Insulated Cables and Connections Program will be credited for aging
management of cables and connections that are not included in the RNPs EQ Program.
The Non-EQ insulated cables and connections managed by this program include those
used for power, instrumentation, control, and communication, including cables sensitive
to reduction in insulation resistance such as radiation monitoring and nuclear
instrumentation. The program involves periodic visual inspections of accessible cables
and connections installed in adverse localized environments to detect embrittlement,
Enclosure
24
cracking, melting, discoloration, or swelling that could lead to reduced insulation
resistance or electrical failure.
The inspectors reviewed the licensing basis, the program basis document for the Non-
EQ Insulated Cables and Connections AMP, implementing procedures and records of
walkdowns for determining adverse localized environments, and visual inspections for
cables to verify that the program was implemented as stated in the commitment. The
inspectors also reviewed corrective action documents, which addressed and identified
cable issues and their corresponding corrective actions.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 36.
Item 37 - Aging Management Program for Non-EQ Electrical Cables Used in
Instrumentation Circuits
Commitment Item 37 specified that prior to the period of extended operation the AMP for
Non-EQ Electrical Cables Used in Instrumentation Circuits will be a new program to
manage aging of cables used in the containment vessel high-range radiation monitoring
instrumentation circuits at least once every 10 years. In this aging management
program, calibration results or findings of surveillance testing programs are used to
identify the potential existence of aging degradation. Exposure of electrical cables to
adverse localized environments caused by heat, radiation, or moisture can result in
reduced insulation resistance.
The inspectors reviewed the licensing basis, the program basis document for the Non-
EQ Electrical Cables Used in Instrumentation Circuits AMP, implementing procedures,
planned and completed work orders, and related AR records to verify that the program
was implemented as stated in the commitment. The inspectors verified that all the
above programmatic activities were satisfactory implemented.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 37.
Item 38 - Aging Management Program for Neutron Flux Instrumentation Circuits
Commitment Item 38 specified that prior to the period of extended operation the AMP for
Neutron Flux Instrumentation Circuits will be a new program that will employ insulation
resistance or other testing to identify the potential existence of aging degradation of
cables in neutron monitoring circuits at least once every 10 years. This program applies
to the cables used for the Source Range, Intermediate Range, Power Range, and
Gamma-Metrics circuits of the Excore Nuclear Instrumentation System. In this aging
management program, an appropriate test, such as insulation resistance tests, time
Enclosure
25
domain reflectometry tests, or I/V (current/voltage) testing will be used to identify the
potential existence of a reduction in cable insulation resistance.
The inspectors reviewed the licensing basis, the program basis document for Neutron
Flux Instrumentation Circuits AMP, implementing procedures, planned and completed
work orders, and related AR records to verify that the program was implemented as
stated in the commitment.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 38.
Item 39 - Aging Management Program for Fuse Holders
Commitment Item 39 specified that prior to the period of extended operation the AMP for
Fuse Holders will be a new program that focuses on the metallic clamp (or clip) portion
of the fuse holder at least once every 10 years. The parameters monitored include
thermal fatigue in the form of high resistance caused by ohmic heating, thermal cycling
or electrical transients, mechanical fatigue caused by frequent manipulation of the fuse
itself or vibration, chemical contamination, corrosion, and oxidation. The program
utilizes thermography or other appropriate testing to identify the potential existence of
aging degradation such as high contact resistance. The program applies to fuse holders
located outside of active devices. Fuse holders inside an active component, such as
switchgear, power supplies, inverters, battery chargers, control panels, and circuit
boards, are considered to be parts of the larger assembly. Since piece parts and
subcomponents in such an enclosure are inspected regularly and maintained as part of
the plants normal maintenance and surveillance activities, they are not within the scope
of this program.
The inspectors reviewed the licensing basis, the program basis document, implementing
procedures, planned and completed work orders, and related AR records to verify that
the program was implemented as stated in the commitment.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 39.
Item 40 - Aging Management Program for Bus Duct
Commitment Item 40 specified that prior to the period of extended operation the AMP for
Bus Ducts will be a new program that focuses on periodically inspecting the iso-phase
bus duct, as well as all non-segregated 4.16 KV and 480 V bus ducts at least once every
10 years. The program will check a sampling of bolted connections of bus ducts. The
sample of accessible bolted connections will be checked for loose connections by using
thermography or by measuring connection resistance using a low-range ohmmeter.
Visual inspections of the bus ducts for signs of cracks, corrosion, foreign debris,
excessive dust buildup, evidence of water intrusion or discoloration, which may indicate
overheating, will also be performed to identify the potential existence of aging
degradation. Industry experience has shown that the bus ducts exposed to appreciable
ohmic or ambient heating during operation may experience loosening of bolted
Enclosure
26
connections related to repeat cycling of connected loads or the ambient temperature
environment.
The inspectors reviewed the licensing basis, the program basis document, implementing
procedures, planned and completed work orders, and related AR records to verify that
the program was implemented as stated in the commitment.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Item 40.
Item 41 - Environmental Qualification of Electric Equipment Program
Commitment Item 41 specified that the existing Environmental Qualification of Electric
Equipment Program will be credited and prior to the period of extended operation, the
EQ Documentation Packages (EQDP) will be revised to incorporate increased radiation
values resulting from power uprate. EQ program activities establish, demonstrate and
document the level of qualification, qualified configuration, maintenance, surveillance
and replacement requirements necessary to meet 10 CFR 50.49.
The inspectors reviewed the licensing basis document, current program procedures and
a sample of various existing EQDPs to verify that the program was implemented as
stated in the commitment. The inspectors observed that all of the EQDPs reviewed had
been adequately updated to reflect power uprate and the period of extended operation.
Based on the review of the timeliness and adequacy of the licensees actions and
assessment for the program, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 41.
Item 42 - TLAA: Reactor Vessel Neutron Embrittlement
Commitment Item 42 specified that the TLAA for Reactor Vessel Neutron Embrittlement
is an existing analysis that will be credited for the period of extended operation. As part
of the LRA review process, the NRC staff reviewed TLAAs for (1) upper-shelf energy, (2)
pressurized thermal shock, and (3) heatup and cooldown (pressure-temperature limits)
curves and low temperature over pressure (LTOP) setpoints to ensure that the reactor
vessel has adequate fracture toughness to prevent brittle failure during normal and off-
normal operating conditions. The NRR staff also reviewed these TLAAs to determine if
the licensee had demonstrated that the TLAAs for parameters related to structural
integrity had been adequately projected to the end of the period of extended operation
for RNP, as required by 10 CFR 54.21(c)(1)(ii). As stated in the SER, the NRC staff
concluded that the licensee provided an acceptable demonstration, pursuant to 10 CFR
54.21(c)(1)(ii), that, for the RV neutron embrittlement TLAA, the analyses have been
projected to the end of the period of extended operation.
Enclosure
27
The inspectors reviewed the licensing basis documents, portions of the TLAAs, and
interviewed the responsible plant personnel regarding these documents to verify that the
analysis was consistent with the LRA and the corresponding SER.
Based on the review of licensee actions completed at the time of this inspection and the
timeliness of those actions, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 42.
Item 43 - TLAA: Metal Fatigue
See discussion for Commitment Item 30 above.
Item 44 - TLAA: Environmental Qualification
Commitment Item 44 specified that in accordance with the requirements of the
Environmental Qualification Program, any component that is not qualified through the
period of extended operation will be refurbished or replaced prior to exceeding its
qualified life. Prior to the period of extended operation, certain motor-operated valve
(MOV) actuators will either be reevaluated to demonstrate acceptable wear cycle
qualifications or they will be replaced.
The inspectors reviewed the current procedure EST-012, Engineering Periodic
Verification of EQ Component Replacements with Qualified Life Less then 60 years,
Revision 4. The inspectors reviewed a sample of EQDPs for components within the
scope of 10 CFR 50.49. The inspectors verified that these EQDPs were updated to
include environmental conditions associated with extended power uprate implementation
along with an extended operating period of 60 years. The inspectors also verified that
where EQDPs concluded that a qualified life of 60 years could not be achieved; PMs had
been created to replace components before end of the qualified life.
The inspectors reviewed Engineering Change (EC) 72274, Reevaluate EQ Limitorque
MOV Number of Strokes/Cycles for 60 Years Plant Life, Revision 0. That EC
documented the basis for concluding that installed MOVs would be capable of continued
service for the 60 years plant life.
Based on the review of the timeliness and adequacy of the licensees actions and
assessment for the program, the inspectors determined that the licensee completed the
necessary actions to meet Commitment Item 44.
Item 45 and 46 - TLAA: Containment Tendon Loss of Prestress
Commitment Items 45 and 46 specified that testing (at integrated leak rate test pressure)
similar to the Structural Integrity Test performed in 1992 will be scheduled to coincide
with the Appendix J containment integrated leak rate testing (ILRT) conducted during the
period of extended operation. The monitoring criteria for these tests will be limited to
deformations and cracking associated with the vertical prestressed tendons, and will not
include radial monitoring. Guidelines for performing the IWL examinations for these
tests will include additional emphasis on looking for a pattern of horizontal cracks and
additional cracking in the discontinuity areas. Additionally, information from the
licensees response to RAI 4.5-1 will be incorporated into Section 3.8.1.4.7 of their
Enclosure
28
The inspectors reviewed the licensing basis, program basis documents, design
calculations, and related AR records to verify that the commitment was implemented as
stated in the SER. The inspectors found that the licensee scheduled the development of
implementing procedures for this program to occur 18 months prior to the first scheduled
Appendix J containment ILRT. The inspectors verified that the Appendix J program
documents were administratively updated to reflect their applicability to license renewal
commitments and interviewed the responsible plant personnel regarding this program.
At the time of this inspection, this commitment item was partially completed and
additional tasks were pending to be implemented prior to the period of extended
operation.
Based on the review of licensee actions completed at the time of this inspection, the
timeliness of those actions, and the administrative controls in place to track pending
actions, the inspectors determined that there was reasonable assurance that the
licensee would complete the necessary actions to meet Commitment Items 45 and 46.
Item 47 - TLAA: Aging of Boraflex in Spent Fuel Pool
Commitment Item 47 specified that prior to the period of extended operation the Boraflex
Monitoring Program will be modified to: (1) include neutron attenuation testing, called
blackness testing, to determine gap formation in Boraflex panels; (2) include trending the
results for silica levels by using the EPRI RACKLIFE predictive code or equivalent, and
(3) include measurements of boron areal density by techniques such as the BADGER
device. Additionally, the commitment states that RNP requested, by letter dated May 28,
2003, Serial: RNP-RA/03-0038, an amendment to the Technical Specifications to
eliminate the need to credit Boraflex neutron absorbing material for reactivity control.
The Boraflex Monitoring Program will be eliminated upon NRC approval of this
amendment or upon implementation of another option (such as re-racking the spent fuel
pool) which eliminates the need to credit Boraflex for reactivity control.
The NRC issued Amendment 198, Elimination of Neutron Absorption Credit for
Boraflex, to Facility Operating License Number DPR-23 for the H.B. Robinson Steam
Electric Plant, Unit No. 2. This amendment changed the Technical Specifications in
response to a request dated May 28, 2003, as supplemented on October 8, 2003. The
amendment eliminated the need to credit Boraflex neutron-absorbing material for
reactivity control in the spent fuel storage pool. The licensee proposed to take credit for
a combination of soluble boron and controlled fuel loading patterns in the spent fuel pool
to maintain the required subcriticality margins. The programs for monitoring the
condition of the Boraflex and the silica content in the water were also eliminated in
Technical Specification 3.7.13, Fuel Storage Pool Boron Concentration.
Based on the review of the timeliness and adequacy of the licensees actions, the
inspectors determined that the licensee completed the necessary actions to meet
Commitment Item 47.
(2) License Renewal Commitment Changes
As part of the review of the commitments identified in Appendix A of the SER, the
inspectors reviewed license renewal commitment change documents to verify the
Enclosure
29
licensee followed the guidance in NEI 99-04, Guidelines for Managing NRC
Commitment Changes, for any change to the commitments, including their elimination.
The inspectors verified that the licensee properly evaluated, reported, and approved
where necessary, changes to license renewal commitments listed in the UFSAR in
accordance with 10 CFR 50.59.
The inspectors also reviewed the licensees procedures for commitment revision to
ensure that future changes to (or elimination of) license commitments would follow the
guidance in NEI 99-04, and would properly evaluate, report, and approve changes to
license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59.
The inspectors did not identify any examples where commitment changes were not
consistent with the guidance in NEI 99-04.
(3) Newly Identified SSCs
After the renewed license is issued, the FSAR update required by 10 CFR 50.71(e) must
include any SSCs newly indentified that would have been subject to an aging
management review or time-limited analysis in accordance with 10 CFR 54.21. The
FSAR update must describe how the effects of aging are managed such that the
intended function(s) in 10 CFR 54.4(b) will be effectively maintained during the period of
extended operation.
The inspectors discussed the identification of new SSCs under the purview of 10 CFR
54.37(b), with the licensees license renewal staff. The licensee personnel indicated that
no components had been identified that should have been within the scope of its license
renewal program due to discovering components in the plant that were not accurately
reflected in the database used to originally generate the application for a renewed
license. Additionally, the inspectors reviewed a sample of modifications implemented
since the LRA was submitted to the NRC until the date the renewed operating license
was issued to identify any potential new SSCs that should had been subject to aging
management review at the time the NRC was reviewing the LRA. The inspectors also
reviewed the licensees evaluation of Regulatory Issue Summary 2007-16 to verify that
the newly SSCs identified in that generic communication were considered in the scope
of RNPs license renewal.
The inspectors determined that the licensee took appropriate actions to assure newly
identified structures, systems, and components were properly identified and evaluated
for management of aging affects. The inspection team did not identify any potential new
SSCs that were subject to the provisions of 10 CFR 54.37(b).
The inspectors also contacted the Office of Nuclear Reactor Regulation, Division of
License Renewal (NRR/DLR) staff for information on any applicable generic NRC
communications naming newly identified systems, structures, and components. The
NRR/DLR staff advised the inspectors that besides Regulatory Issue Summary 2007-16,
the NRC has not specified additional SSCs that the licensee must evaluate and include
as applicable in its next UFSAR update in accordance with 10 CFR 54.37(b).
Enclosure
30
(4) Description of AMPs and TLAAs in the UFSAR Supplement
As part of the review of AMPs and TLAAs approved by the NRC in the SER, the
inspectors reviewed their UFSAR descriptions to confirm the implemented programs
were consistent with the SER. The inspectors also verified that changes caused by the
inclusion of newly identified SSCs were included in the UFSAR supplement. With the
exception of one example described in the Findings and Observations section of this
inspection report, the inspectors did not identify inconsistencies between the AMPs or
TLAAs approved in the SER and the UFSAR supplement.
The inspectors also verified that the UFSAR supplement submitted pursuant 10 CFR
54.21(d) was included in the next update to the UFSAR following the issuance of the
renewed license as required by license condition 3.K of the Renewed Facility Operating
License Number DPR-23. Additionally, the inspectors reviewed changes made to the
programs and activities in the UFSAR supplement from the date the renewed license
was issued to the next scheduled UFSAR update to verify that changes were evaluated
against the criteria in 10 CFR 50.59. The inspectors found that the aforementioned
supplement was included in the UFSAR as required and changes to the programs and
activities were evaluated in accordance with 10 CFR 50.59.
b. Findings and Observations
(1) Introduction: The inspectors identified an Unresolved Item related to the Emergency
Operations Facility/Technical Support Center (EOF/TSC) Diesel Generator Main Storage
Tank (buried diesel fuel oil tank), for which additional information and discussion was
needed to determine if a performance deficiency existed, if the performance deficiency
was more than minor, or if the issue of concern constituted a violation of NRC
requirements.
Description: The inspectors noted that Table 2.3-25 of the LRA lists the components in
the Fuel Oil System that require aging management review. This table shows that the
results of the AMR for the EOF/TSC Main Storage Tank are documented in Table 3.3-1
and Table 3.3-2 of the LRA.
Table 3.3-1 specifies that aging management for the diesel fuel oil tanks made of carbon
steel in the diesel fuel oil system and the EDG system will be implemented through the
Fuel Oil Chemistry Program.
Table 3.3-2 specifies that the EOF/TSC Main Storage Tank is a buried tank made of
fiberglass reinforced polyester. The licensee stated in this table that no aging effects
or AMP applies to this tank. Additionally, section B.3.12 of the LRA, Buried Piping and
Tanks Inspection Program states that this AMP does not contain buried tanks. In RAI
B.3.12-1, the NRR staff requested confirmation that no buried tanks were covered under
the Buried Piping and Tanks Inspection Program. In its response to this RAI dated April
28, 2003, the licensee stated that the program does not contain buried tanks.
During the review of AMR documents for LR commitments, the inspectors identified that
the EOF/TSC Main Storage Tank is made of carbon steel covered with 1/8 nominal
exterior coating of fiberglass reinforced polyester. The inspectors noted that the
description of the tank in Table 3.3-2 did not include carbon steel.
Enclosure
31
The inspectors questioned the licensee with regard to the basis for excluding this buried
tank from the scope of the Buried Piping and Tanks Inspection Program. According to
the licensee, the combination of tank material and environment (i.e. buried carbon steel
tank covered with fiberglass reinforced polyester) is not specifically addressed in Table
VII.H1 of the GALL Report and therefore the licensee treated this tank as a component
that is different from the GALL Report.
The inspection team remained concerned whether the exclusion of the EOF/TSC Main
Storage Tank from the Buried Piping and Tanks Inspection Program was appropriate
and whether the AMP selected by the licensee to manage aging on the tanks surfaces
was adequate. This issue required further review. Therefore, this issue will be tracked
as an unresolved item (URI 5000261/2010008-01).
(2) Observation for Commitment Item 20, Above Ground Carbon Steel Tanks: Based on
discussions with the licensee staff the inspectors found that the Alternate Fuel Oil
Storage Tank was excluded from the license renewal scope by dedicating this tank to a
function that did not require aging management in accordance with 10 CFR 54.
However, the inspectors identified that the operating procedure for this tank (OP-909)
contradicted this purpose by allowing the tank to be used for an additional function
during maintenance activities. The licensee stated that this contradiction was the result
of an inadequate procedure revision. The licensee initiated NCR 00380767 to correct
the aforementioned operating procedure.
(3) Observation for Commitment Item 28, Systems Monitoring Program: Enhancement
number 6 of the Commitment states that "loss of material due to wear" will be specifically
included as an aging effect/mechanism in the system walkdown checklist. The
inspectors noted that this enhancement was not included in the UFSAR section 18.1.25,
Systems Monitoring Program. Following discussions with the licensee staff, the
inspectors found that absence of this item in the UFSAR was an error. When the FSAR
was updated to include the license Renewal Commitments, the list of commitments used
from the LRA was used rather than the complete list from Appendix A of the NRC SER.
The licensee initiated NCR 382852 to document this deficiency in their corrective action
program.
Additionally, section 3.K of the renewed license states The Updated Final Safety
Analysis Report supplement, as revised, shall be included in the next scheduled update
to the Updated Final Safety Analysis Report required by 10 CFR 50.71(e)(4) following
issuance of this renewed license. This requirement was not completely accomplished,
in that enhancement number 6 of Commitment Item 28 was not included in the UFSAR.
(4) Observation for Commitment Item 28, Systems Monitoring Program: Enhancement
number 6 of the Commitment states that "loss of material due to wear" will be specifically
included as an aging effect/mechanism in the system walkdown checklist. This
commitment item was implemented in site procedure TMM-104, System Walkdown
Procedure, Revision 22. Specifically, the enhancement was implemented as loss of
material due to wear (AR 84967) in section 2.a of Attachment 10.2 - System Inspection
Checklist for Quarterly Walkdowns. The Action Request number in parenthesis is
intended to flag the line item in the implementing procedure as a license renewal
commitment to prevent inadvertent deletion during future revisions. However, procedure
TMM-104 was replaced with corporate wide procedure EGR-NGGC-0026, System
Walkdown Procedure, Revision 0 and this particular enhancement was not included in
Enclosure
32
the corporate procedure. The licensee initiated NCR 382858 to document this
deficiency in their corrective action program.
(5) Observation for Commitment Item 28, Systems Monitoring Program: Enhancement
number 5 of the Commitment states that a section specifically addressing corrective
actions will be added to the licensees system walkdown procedure. The inspectors
noted that procedure TMM-104, System Walkdown Procedure, Revision 22 contained
section 8.4 titled Corrective Actions (AR 84967, AR 84947, AR 84964) to implement
enhancement five. However, procedure TMM-104 was replaced with corporate wide
procedure EGR-NGGC-0026, System Walkdown Procedure, Revision 0 and this
particular enhancement was deleted from the new corporate procedure. The new
corporate procedure still addresses corrective actions in certain procedure steps.
However, the inspectors concluded that implementation of this enhancement in the new
corporate procedure did not fully meet the commitment in that the procedure did not
include a section specifically addressing corrective actions. The licensee included this
issue in NCR 382858 to document this deficiency in their corrective action program.
(6) Observation for Commitment Item 31, RVH Nickel Alloy Program: The inspection plan
required by this commitment item was submitted to NRR under licensee letter RNP-
RA/09-0067. This letter states that the Code Case N-729-1 non-visual inspection of the
upper VHPs is scheduled for RO-27. However, the inspectors identified that the ISI plan
shows this inspection as scheduled for RO-29 in 2014. The licensee initiated NCR
380373 to address this discrepancy and found that the inspection date submitted on the
letter to the NRC was based on the original Alloy 600 upper VHPs. The licensee
replaced the upper reactor vessel head in 2005, which was made of Alloy 690 VHPs. It
appeared that licensee personnel may not have updated their schedule when they
submitted the letter to the NRC. The inspectors determined that the inspection schedule
shown on the licensees ISI plan met the requirements of Code Case N-729-1.
(7) Observation for Commitment Item 31, RVH Nickel Alloy Program: The inspectors noted
that the UFSAR section on Nickel Alloy Nozzles references NRC Order EA-03-009 as
the regulatory requirement driving the inspection of upper VHP nozzles. The NRC Order
for the examination of upper VHP nozzles has been superseded by 10CFR 50.55a, with
the incorporation of Code Case N-729-1. The inspectors found that neither the UFSAR
nor the commitment has been revised to reflect the new regulatory requirements.
However, the inspectors determined that the licensees ISI plan showed an adequate
implementation of the Code Case N-729-1 requirements with regard the schedule of
visual and non-visual inspections. The licensee initiated NCR 0380367 to address this
issue.
(8) Observation for Commitment Item 32, Thermal Aging and CASS Program: The
inspectors noted that the implementing procedures do not contain a program description
that was fully consistent with the LRA, the UFSAR, and the SER. The SER states that
the Thermal Aging and CASS Program applies to cast austenitic stainless steels in RCS
"piping, valves, and pump casings." However, the implementing procedures state that
the program applies to Class 1 cast austenitic stainless steels in RCS "piping, valves,
and fittings." The inspectors questioned whether this created the vulnerability for
missing the CASS pump casing inspections stipulated in the license renewal
commitment. The licensee generated NCR 381872 to correct the implementing
procedures. Although this discrepancy existed in the implementing procedures, the
Enclosure
33
inspectors found that the current ISI Plan included the inspections of Class 1 CASS
pump casings as stated in the commitment.
(9) Observation on Tracking of License Renewal Tasks: The inspectors noted that the
implementation of license renewal commitments was tracked through a series of Nuclear
Tasks Management (NTM) items in the licensees AR system. Each commitment had an
NTM with one or more assignments to track the complete implementation of the
commitment item. Additional tasks such as procedure revisions, preventive
maintenance request, and work orders were created to implement each of the NTMs
tracking the commitments. However, all these tasks had not been cross-referenced to
the main NTM tracking the commitment item. The inspectors questioned whether this
created the vulnerability for closing a commitment while other associated actions are still
pending.
The inspectors found that the failure to cross-reference the license renewal commitment
items was not consistent with License Renewal Program procedure EGR-NGGC-0501,
which specifically requires that license renewal NTMs be cross-referenced with
associated tasks. The licensee generated NCR 380471 to address this issue. The
licensee established the required cross-reference between NTMs and associated tasks
before the end of this inspection.
c. Overall Conclusions
The inspectors determined that the licensee had completed, or was on track to
complete, the necessary tasks to meet the license renewal commitments, license
conditions, and regulatory requirements associated with the issuance of the renewed
operating license at the H.B. Robinson Steam Electric Plant Unit 2. Some commitments
had pending actions remaining, for which task items existed in the Action Request
system to track their completion. Based on the review of completed actions to meet
license renewal commitments, the corrective actions initiated for the observations
discussed above, and the administrative controls in place to track pending license
renewal actions, the inspectors determined that there was reasonable assurance that
the licensee would complete the remaining actions to meet the license renewal
commitments prior to the period of extended operation.
4OA6 Management Meetings
Exit Meeting Summary
On 02/26/2010, the inspectors presented the inspection results to the Mr. Eric
McCartney and other members of the licensee staff. The licensee acknowledged the
issues presented. The inspectors confirmed that none of the potential report input
discussed was considered proprietary. Proprietary material received during the
inspection was returned to the licensee.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
T. Bardauskas, Site License Renewal Manager
M. Heath, Corporate License Renewal Manager
G. Sanders, Licensing Engineer
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened
05000261/2010008-01 URI Aging Management Program for exterior
surface of EOF/TSC Main Storage Tank
(Section 4OA5.1)
Closed
None
Discussed
None
Attachment
2
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list does
not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that
selected sections of portions of the documents were evaluated as part of the overall inspection
effort. Inclusion of a document on this list does not imply NRC acceptance or endorsement of
the document or any part of it.
Commitment Item 1
AR 00084897, LR Commitment #1
NGGM-PM-0007, Quality Assurance Program Manual, Revision 16
Commitment Item 2
AP-044, Procedure Process Enhancements, Revision 23
AR 363977, SA 305571 D1: License Renewal Process for UFSAR Updates
EGR-NGGC-0005, Engineering Change, Revision 29
EGR-NGGC-0514, License Renewal Implementation Procedure, Revision 0
Model WO 01674547, Perform Review Required by 10CFR 54.37(b) (License Renewal)
NTM 00092130, LR Commitment #2 Requirements Met of 10 CFR 54.37(b)
PMQR 00088958, Perform Review Required by 10CFR 54.37(b) (License Renewal)
PRO-NGGC-0204, Procedure Review and Approval, Revision 16
REG-NGGC-0010, 10 CFR 50.59 and Selected Regulatory Reviews, Revision 12
RNP-L/LR-0009, UFSAR Updates for Post Renewed License - Newly Identified SSCs, Revision
0
RNP-L/LR-0009, UFSAR Updates for Post Renewed License - Newly Identified SSCs, Revision
1
RNP-L/LR-0009, UFSAR Updates for Post Renewed License - Newly Identified SSCs, Revision
2
Commitment Item 3
AR 00092135-01, Commitment 3 and License Condition 3.K, UFSAR Supplement
Commitment Item 4
AR 00084907, Incorporate changes into procedures to indicate credit for R AMP
NRC Request for Additional Information RAI B.1-1
PLP-025, Revision 20, Inservice Inspection Programs
RNP-L/LR-0606, Aging Management Program ASME Section XI, Subsections IWB, IWC, and
IWD Inservice Inspection Program
Robinson Nuclear Plant License Renewal Application, Appendix B, Section B.2.1, ASME
Section XI, Subsection IWB, IWC, and IWD Program
TMM-015, Inservice Repair and Replacement
TMM-020, revision 17, Inservice Pressure Testing Program
TMM-038, Revision 14, Inservice Inspection Program
Commitment Item 5
AR 00084912, LR Commitment #5
CP-001 Chemistry Monitoring Program, Revision 96
CP-005 Secondary Chemistry Corrective Action Program, Revision 34
CP-200 Chemistry Program Implementation, Revision 16
OM-001-13 Plant Chemistry, Revision 13
RNP-L/LR-0600, Aging Management Program Water Chemistry Program, Revision 11
Attachment
3
Commitment Item 6
AR 00084913, LR Commitment #6 Reactor Head Closure Studs Program
MRP-003, Revision 35, Reactor Vessel Stud Removal and Installation
NRC Request for Additional Information RAI B.1-1
NRC Request for Additional Information RAI B.1-1
PLP-025, Revision 20, Inservice Inspection Program
RNP-L/LR-0619, Aging Management program Reactor Head Stud Program
Robinson Nuclear Plant License Renewal Application, Appendix B, Section B.2.1, Reactor Head
Closure Studs Program.
TMM-038, Revision 15, Inservice Examination Program
Commitment Item 7
AR 00084915, LRA Commitment #7, Steam Generator Tube Integrity Program
AR 00185319, Perform procedure technical review
ERG-NGGC-0208, Revision 7, Steam Generator Integrity Program
NRC Request for Additional Information RAI B.1-1
Plant Technical Specifications, 5.5.9, Steam Generator Program
RNP-L/LR-0604, Revision 1, Aging Management Program Steam Generator Tube Integrity
Program
Robinson Nuclear Plant License Renewal Application, Appendix B, Section B.2.4 Steam
Generator Tube Integrity Program
TMM-112, Revision 18, team Generator Inspection (Refueling Outage).
TMM-112-1, Revision 6, Steam Generator Eddy Current Analysis Guidelines
Commitment Item 8
0ST-910, Dedicated Shutdown Diesel Generator (Monthly)
AR 00084897, LR Commitment #8
AR 00210085, Three tubes plugged in the B CCW Heat Exchanger
AR 00221280, Three tubes plugged in the A CCW Heat Exchanger
AR 00246999, Small Pieces of Concrete Found in the B CCW HX
AR 00339413, Increase in CCW system Leakage
CP-001, Chemistry Monitoring Program
CP-200, Chemistry Program Implementation
OST-405, TSC/EOF/PAP Diesel Generator (Semiannual)
OST-406, TSC/EOF/PAP Diesel Generator (monthly except when OST-405 is scheduled)
OST-409-1, EDG A Fast Speed Start
OST-409-2, EDG B Fast Speed Start
OST-410, Emergency Diesel Generator A (Twenty-Four Hour Load Test)
OST-411, Emergency Diesel Generator B (Twenty-Four Hour Load Test)
OST-908, Component Cooling System Component Test
PM-025, EOF/TSC Emergency Diesel Generator Inspection Number 1
PM-108, Dedicated Shutdown Diesel Twenty Four (24) Month Inspection
PMR 00016866-01, Cleaning and Inspection of A CCW Heat Exchanger
PMR 00016866-02, Clean and Repair the Coating on the Tube Sheet and Housing On A CCW
PMR 00016866-03, Eddy Current Test A CCW Heat Exchanger
PMR 00016867-01, Cleaning and Inspection of B CCW Heat Exchanger
PMR 00016867-02, Cleaning and Inspection of B CCW Heat Exchanger
PMR 00016867-03, Eddy Current Test B CCW Heat Exchanger
RNP-L/LR-0627, Aging Management Program Closed Cycle Cooling Water System, Revision 2
WO 00054467, Cleaning and Inspection of A CCW Heat Exchanger
Attachment
4
WO 00054468, Clean and Repair the Coating on the Tube Sheet and Housing on A CCW
WO 00054470, Cleaning and Inspection of B CCW Heat Exchanger
WO 00058469, Cleaning and Inspection of B CCW Heat Exchanger
WO 01073453, Eddy Current Test A CCW Heat Exchanger
WO 01073544, Eddy Current Test B CCW Heat Exchanger
Commitment Item 9
AR 00084918, LR Commitment Item 9, ASME Section XI, Subsection IWF
PLP-025, Inservice Inspection Programs, Revision 20
RNP-L/LR-0618, Aging Management Program ASME Section XI, Subsection IWF Program,
Revision 3
TMM-015, Inservice Repair and Replacement, Revision 34
TMM-038, Inservice Examination Program, Revision 14
Commitment Item 10
AR 00084919, LR Commitment Item 10, 10CFR Appendix J Program
EGR-NGGC-0015, Containment Inspection Program, Revision 3
EST-062 Procedure Performance Results, 7/29/09
EST-062, Local Leak Rate Test of Containment Instrument Air Header Isolation Valves
(Refueling Shutdown, Not to Exceed 2 Years), Revision 17
EST-064, Containment Isolation Valve Local Leakage Rate Survey (Refueling Interval Not to
Exceed 2 Years), Revision 12
EST-064, Attachment 10.2, Containment Isolation Valve Local Leakage Rate Survey, 7/29/09
PLP-025, Inservice Inspection Programs, Revision 20
RNP-L/LR-0615, Aging Management Program 10 CFR Part 50, Appendix J Program, Revision
1
TMM-005, 10CFR50, Appendix J Testing Program, Revision 28
Commitment Item 11
EST-108 Flux Thimble Eddy Current Inspection (Specified Refueling Outages) Revision 8
Eddy Current Inspection Results from September 2005
RNP-L/LR-0609, Aging Management Program Flux Thimble Eddy Current Inspection Program,
Revision 1
Commitment Item 12
AR 00084923-01, LR Commitment #12
EGR-NGGC-0351 Condition Monitoring of Structures, Revision 15 - draft revision under PPR
353128
FP-013 Fire Protection Systems Surveillance Requirements Revision 10
RNP-L/LR-0612, Aging Management Program Fire Protection Program, Revision 5
TMM-104, System Walkdown Procedure, Revision 21
WO 1038781 replace flex hoses reserve CO2 bank 2009.
WO 1038782 replace flex hoses main CO2 bank 2009.
WO 1038786 replace flex hoses for the cable vault pilot control valves 2009.
WO 303032 replace all the flex hoses on the Cable Vault C02 System 6195 2004
Commitment Item 13
AR 00084924, LR Commitment Item 13, BACCP
AR 00068113, Boric Acid Corrosion Control Program Assessment
EGR-NGGC-0207, Boric Acid Corrosion Control, Revision 3
EST-083-1, Inservice Inspection Pressure Retaining VT-2 Bolting Examinations of the Reactor
Coolant System (Refueling Shutdown Interval), Revision 5
Attachment
5
EST-083-2, Inservice Inspection Pressure Testing of the Reactor Coolant System (Refueling
Shutdown Interval), Revision 5
OST-051, Reactor Coolant System Leakage Evaluation (Every 72 Hours during Steady State
Operation and Within 12 Hours after Reaching Steady State Operation), Revision 41
OST-052, RCS Leakage Test and Examination Prior To Startup Following an Opening of the
Primary System (Refueling and/or Startup Interval), Revision 23
OST-51, Attachment 10.2, Leakage Evaluation Calculation Sheet, Revision 41, 2/19/10
RNP-L/LR-0601, Aging Management Program Boric Acid Corrosion Control Program, Revision
5
TMM-104, System Walkdown Procedure, Revision 22
Commitment Item 14
EGR-NGGC-0202, Flow Accelerated Corrosion Monitoring Program, Revision 10
Flow Accelerated Corrosion (FAC) Program Document System Elimination Analysis, Revision 5,
January, 2010
AR 00084931, Commitment in RNP-RA/03-0031 Flow-Accelerated Corrosion Program
RNP-L/LR-0603, Aging Management Program Flow Accelerated Corrosion Program, Revision 5
Commitment Item 15
1039252, Disassemble, repair, and reassemble CVC-381
AR 00084833-2, LR Commitment #15
AR 84933-02, Inspection of high strength bolting used in valve CVC-381
MMM-016, Torquing Procedure
RNP-L/LR-0625, Aging Management Program Bolting Integrity Program, Revision 2
Commitment Item 16
AR 00084935, LR Commitment #16
AR320264, Change processes not followed for license renewal commitment
CM-201, Safety Related and Non-Safety Related Heat Exchanger Maintenance
CP-001, Chemistry Monitoring Program
CP-009, Chlorination
EC 49207, Cooling coil replacement in HVH-6A/B, HVH-7A/B, and HVH-8A/B
EST-116, Service Water Piping Inspection
OST-151-1, Safety Injection System Components Test - Pump A
OST-151-2, Safety Injection System Component Test - Pump B
OST-201-1, MDAFW System Component Test - Train A
OST-201-2, MDAFW System Component Test - Train B
PMR 17986, Assist Contractor With Performing Eddy Current on HVH-6B
PMR 17985, Assist Contractor With Performing Eddy Current on HVH-6A
PMR 17987, Assist Contractor With Performing Eddy Current on HVH-7A
PMR 17988, Assist Contractor With Performing Eddy Current on HVH-7B
PMR 17989, Assist Contractor With Performing Eddy Current on HVH-8A
PMR 17990, Assist Contractor With Performing Eddy Current on HVH-8B
PMR 190631, SI, RHR and AFW room cooler heat exchangers must be eddy current tested
RNP-L/LR-0602, Aging Management Program Open Cycle Cooling Water System Program,
Revision 7
Commitment Item 17
AR 00084937-01, License Renewal Commitment Item 17, Inspection of Overhead Heavy Loads
and Light Loads Handling
AR 00220518, Turbine crane gear wear
Attachment
6
AR 00347161, Spent fuel cask crane flex couplings not in PM program
EGR-NGGC-0351, Condition Monitoring of Structures, Revision 15
RNP-L/LR-0628, Aging Management Program Inspection of Overhead Heavy Load and Light
Load Handling Systems Program, Revision 2
TMM-104, System Walkdown Procedure, Revision 22
TMM-104, System Walkdown Report - 4th Quarter 2008
TMM-104, System Walkdown Report - Inspection July 2008
TMM-104, System Walkdown Report - Inspection July 2008
TMM-104, System Walkdown Report - RO-025 Inspection Sept-Nov 2008
Commitment Item 18
AR 00084942-1, LR Commitment #18
PMR 348790
PMR 348792
RNP-L/LR-0611, Aging Management Program Fire Water System Program, Revision 7
WO 1519261
WO 1605254
Commitment Item 19
AR 00373580, Independent Vendor Assessment of Cathodic Protection System
AR 84944-02, Buried Piping and Tank Surveillance Program (Cathodic Protection System)
License Renewal Commitment Implementation
Evaluation / Adjustment Survey Cathodic Protection Systems Units No. 1 and 2 Underground
Fuel System Piping H.B. Robinson Plant, Progress Energy Hartsville, South Carolina,
Prepared by CORRPRO Companies, October, 2009
NACE RP0169-1996, Standard Practice, Control of External Corrosion on Underground or
Submerged Metallic Piping Systems
NACE SP0169-2007, Standard Practice, Control of External Corrosion on Underground or
Submerged Metallic Piping Systems
NCR 374152, Attachment 4, Equipment Reliability Form
PM-403, Cathodic Protection System Rectifier Inspection and Cleaning, Revision 11
PM-417, Cathodic Protection System Soil to Structure Potential Measurement Test, Revision 9
PM-467, Fuel Oil Transfer Pressure Test, Revision 8
Resurvey Report Cathodic Protection System Units No. 1 and 2 Underground Fuel System
Piping H.B. Robinson Plant, Progress Energy Hartsville, South Carolina, January, 2009
Work Order Package 01399645-14, Install EC 65116
Work Order Package 01480838-01, Perform Cathodic Protection System Inspection (PM-417)
Commitment Item 20
AR 00084947-01, LR Commitment #20
EGR-NGGC-0026, System Walkdown Procedure
PMR 8735701, EDG fuel storage tank
PMR 1729203, DSD fuel storage tank
PMR 368289, Security diesel day tank
PMR 368829, Unit 1 fuel storage tanks
PMR 8600001, Fire pump fuel tank
RNP-L/LR-0630, Aging Management Program Above Ground Carbon Steel Tanks Program,
Revision 4
Attachment
7
TMM-104, System Walkdown Procedure
Commitment Item 21
AR 380897, OST-405 TSC/EOF/PAP Diesel Generator (Semiannual)
CP-00, Chemistry Monitoring Program, Revision 97
CP-039, Bacteria in Fuel Oil, Revision 0
CP-116, Chemistry Data Tracking and Trending Program, Revision 13
AR 00084951, Commitment in RNP-RA/03-0031 Fuel Oil Chemistry Program
OST-023, Monthly Surveillances, Revision 26
RNP-L/LR-0631, Aging Management Program Fuel Oil Chemistry Program, Revision 4
Commitment Item 22
H.B. Robinson Steam Electric Plant Unit 2 - Updated Final Safety Analysis Report, Revision 22,
Section 5.3.1.6, Material Surveillance
Model WO 00053419, FSAR 5.3 Perform Reactor Vessel Surveillance Capsule Testing
AR 00084955, Commitment 22 and License Condition 3.L, RV Surveillance Program
PMID 13444, FSAR 5.3 Perform Reactor Vessel Surveillance Capsule Testing
RNP-L/LR-0613, Aging Management Program Reactor Vessel Surveillance Program, Revision
2
WCAP-15805, Analysis of Capsule X from the Carolina Power & Light Company H.B. Robinson
Unit 2 Reactor Vessel Radiation Surveillance Program, March 2002
Commitment Item 23
AR 00084959-01, LR Commitment #1
EGR-NGGC-0209, Buried Piping Program, Revision 0
EGR-NGGC-0351, Structures Monitoring Program, Revision 14
MNT-NGGC-024, Excavation and Backfill, Revision 0
RNP-L/LR-0634, Aging Management Program Buried Piping and Tanks Inspection Program,
Revision 4
Commitment Item 24
NGG RNP IWE/IWL Program Health Report, 12/31/2009
AR 00084960-01, LR Commitment Item 24, ASME Section XI, Subsection IWE
CM-764, Inspection and Repair of CV Liner and Insulation, Revision 8
EC-47701, CV Liner Thickness Acceptance Criteria, Revision 6
EC-72699, Evaluation of Containment Building Liner, Insulation, Sheathing, and Coatings,
Revision 0
EGR-NGCC-0351, Condition Monitoring of Structures, Revision 15
EST-064, Containment Isolation Valve Local Leakage Rate Survey (Refueling Interval Not to
Exceed 2 Years), Revision 12
EST-150, Containment Inspection (IWE/IWL), Revision 9
PLP-025, Inservice Inspection Programs, Revision 20
RNP-L/LR-0616, Aging Management Program ASME Section XI, Subsection IWE, Revision 1
TMM-015, Inservice Repair and Replacement, Revision 34
TMM-124, Inservice IWE/IWL Program, Revision 9
Commitment Item 25
AR 00084961-01, LR Commitment Item 25, ASME Section XI, Subsection IWL Program
EST-150, Containment Inspection (IWE/IWL), Revision 9
Attachment
8
MMM-051, Plant Excavation, Backfill, Core Drilling, and Cutting Concrete/Masonry, Revision
15
MNT-NGGC-0024, Excavation and Backfill, Revision 0
PLP-025, Inservice Inspection Program, Revision 20
RNP-L/LR-0617, Aging Management Program ASME Section XI, Subsection IWL, Revision 3
TMM-015, Inservice Repair and Replacement, Revision 34
TMM-104, System Walkdown Procedure, Revision 22
TMM-124, Inservice IWE/IWL Program, Revision 9
Commitment Item 26
AR 00084964-02, LR Commitment Item 26, Structures Monitoring Program
AR 00365673-16, Adequate progress has not been made on the license renewal commitment
for the structural monitoring program
EGR-NGCC-0351, Condition Monitoring of Structures, Revision 15
Inspection Attributes for Structural Monitoring Program: Air Compressor Enclosure, 1/22/10
Inspection Attributes for Structural Monitoring Program: Diesel Fire Pump FO Tank & Control
Panel; Manholes M-50A & M-50B, 1/22/10
Inspection Attributes for Structural Monitoring Program: DSDG Enclosure, Tank, Charger,
Cooler 1/22/10
MNT-NGGC-0024, Excavation and Backfill, Revision 0
RNP-L/LR-0608, Aging Management Program Structures Monitoring Program, Revision 3
Commitment Item 27
AR 00084965-01, LR Commitment Item 27, Dam Inspection Program
AR 00245643-20, Based on the material condition of the Lake Robinson Dam Spillway Tainter
Gates recorded during a recent system walkdown, corrective maintenance is required to insure
that the functionality and/or structural integrity is not compromised.
EGR-NGCC-0351, Condition Monitoring of Structures, Revision 15
Progress Energy Carolinas H.B. Robinson Steam Electric Plant Cooling Lake Dam and Ash
Pond Dike Hartsville, South Carolina Mactec Project No. 6468-05-0992(05) Five-Year
Independent Consultant Inspection, 12/20/05
Report of 2008 Limited (Annual) Field Inspection Cooling Lake Dam and Ash Pond Dam H.B.
Robinson Steam Electric Plant Hartsville, South Carolina Mactec Project 6468-08-2087(05),
11/11/08
RNP-L/LR-0636, Aging Management Program Recommended Guidelines for Safety Inspection
of Dams, Revision 5
Work Order #00852383, Lake Robinson Dam Inspection & Report
Commitment Item 28
AR 00084967, LR Commitment #28
EGR-NGGC-0026 System Walkdown Procedure, Revision 0
TMM-104, System Walkdown Procedure, Revision 22
Commitment Item 29
AR 00084999, LR Commitment #29
AR/NCR 365671 PM and model work orders not specific to aging mechanism
EGR-NGGC-0512 Licensing renewal Aging Management Activities, Revision 4
RNP-L/LR-0642 Aging Management program for Preventive Maintenance Program
Commitment Items 30 and 43
AR 00092151, Commitment in RNP-RA/03-0074 TLAA Metal Fatigue
Attachment
9
AR 00085003, LR Commitment No. 30 Fatigue Monitoring Program
PLP-109, Cycle and Transient Monitoring, Revision 9
RNP-M/MECH-1593, Feedwater (FW) Branch Connection Reinforcement Pad Plate Design &
Fatigue CUF Calculation for H.B. Robinson - Unit 2, Revision 1
RNP-M/MECH-1594, Stress and Fatigue Analysis for AFW to FW Tie-In Thermal Fatigue
Concerns, Revision 1
RNP-L/LR-0502, Thermal Fatigue TLAA Review for H.B. Robinson - Unit 2, Revision 4
RNP-L/LR-0605, Aging Management Program for Metal Fatigue of Reactor Coolant Pressure
Boundary (Fatigue Monitoring Program), Revision 4
WCAP-16694-P, Environmental Fatigue Evaluations for H.B. Robinson Unit 2 Pressurizer and
Surge Line, April 2007 (Westinghouse Proprietary Class 2 Document)
Commitment Item 31
ADM-NGGC-0112, Reactor Coolant System Material Integrity Management Program, Revision
2
Fourth Ten-Year Interval Inservice Inspection Plan, Section E-11, Volume 190
Fourth Ten-Year Interval Inservice Inspection Program, Volume 180
AR 00085005, Commitment in RNP-RA/03-0074 Nickel-Alloy Nozzles & Penetrations
PLP-025, Inservice Inspection Programs, Revision 20
RNP-L/LR-0620, Aging Management Program Nickel-Alloy Nozzles and Penetrations Program,
Revision 2
RNP-RA/09-0067, Nickel Alloy Nozzles and Penetrations Program Inspection Plan, 07/29/09
TMM-015, Inservice Repair and Replacement, Revision 34
TMM-020, Inservice Pressure Testing Program, Revision 18
TMM-038, Inservice Examination Program, Revision 15
Commitment Item 32
H.B. Robinson Steam Electric Plant, Unit No. 2, Fourth Ten-Year Interval Inservice Inspection
Program, Revision 13
H.B. Robinson Steam Electric Plant, Unit No. 2, Fourth Ten-Year Interval Inservice Inspection
Plan, Revision 16
AR 00085006, Commitment in RNP-RA/03-0031 Cast Austenitic Stainless Steel
PLP-025, Inservice Inspection Programs, Revision 20
RNP-L/LR-0621, Aging Management Program Thermal Aging Embrittlement of Cast Austenitic
Stainless Steel (CASS) Program, Revision 2
TMM-038, Inservice Examination Program, Revision 15
Commitment Item 33
AR 00085009-01, LR Commitment #33
ADM-NGGC-0112, Reactor Coolant System Material Integrity Management Program, Revision
2
Letter Serial RNP-RA/09-0081, From H.B. Robinson Steam Electric Plant, Unit No. 2, To
USNRC, Subj: Reactor Vessel Internals Aging Management Program Inspection Plan, Sep 24,
2009
RNP-L/LR-0614, Aging Management Program PWR Vessel Internals Program, Revision 2
SD-058, Robinson Nuclear Training, Operations Training, Reactor Vessel and Internals System,
Revision 6
WCAP-17077-NP, PWR Vessel Internals Program Plan for Aging Management of Reactor
Internals at Robinson Nuclear Plant, July 2009
Attachment
10
Commitment Item 34
AR00085012, LR Commitment Item 34
NRC Information Notice 97-46, Unisolable Crack in High-Pressure Injection Piping
RNP-L/LR-0632, Aging Management Program One Time Inspection Program, Revision 6
Robinson Nuclear Plant License Renewal Application, Appendix B, Section B.4.4, One Time
Inspection Program.
WO 0083077, Perform as-found Tube Measurements for License Renewal
WO 01537084, Perform and inspect valves and piping in condensate system for LR
Commitment prior to period of extended operation.
WO 01537087, Perform and inspect valves and piping in feed water system for LR Commitment
prior to period of extended operation.
WO 01537098, Perform and inspect valves and piping in auxiliary feed water system for LR
Commitment prior to period of extended operation.
WO 01537102, Perform and inspect valves and piping in steam generator blow down system for
LR Commitment prior to period of extended operation.
Commitment Item 35
RNP-L/LR-0633, Selective Leaching of Materials Program
AR 00085018, LR Commitment Item 35
WO 388899 Inspection of MDAFWP lube oil cooler 1/29/04
WO 410468 Inspection of SDAFWP lube oil heat exchanger 9/20/04
WO 652567 Inspection & replace service water valve SW-6 4/20/07
WO 759603 Inspect V6-33E SW booster pump A 4/20/07
WO 615770 Replace SW-8 SW D pump discharge 10/14/08
WO 1122995 Inspect valve V6-16C turbine building isolation 10/28/08
WO 1016122 Inspect valve DG-9A DG A jacket water HX tube side drain
WO 355999 Inspect valve FP-75 EDFP relief valve
WO 608534 Tie in new line 10-FP-374 to 10-FP-358 5/5/05
WO 831096 Replace potable water line cable spread/battery room 2/25/09
Commitment Item 36
AR00085019, LR Commitment Item 36
AR 366618, List required by EGR-NGGC-0108 not available
AR311293-04, Self Assessment RNP Cable Aging Management Program
EGR-NGGC-0507, Cable Aging Management Program
EPRI Technical Report 1003317, Cable System Aging Management (April 2002)
EPRI Technical Report 1003663, Integrated Cable System Aging Management Guidance -
Low Voltage Cable (January 2003)
EPRI Technical Report 1007933, Aging Assessment Field Guide (December 2003)
EPRI Technical Report 109619, Guideline for the Management of Adverse Localized
Equipment Environments (June 1999)
PMR 11777, Walkdown Non-Eq cable in the Turbine Building
PMR 18064, Walkdown Non-Eq cable in the Aux Building
PMR 72802, Walkdown Non-Eq cable in CV
RNP-L/LR-0390, Aging Management Review of Electrical Commodities for License Renewal,
Revision 4
WO 01126106-01, inspect cables in R025 in CV
WO 01126106-02 inspect cables in R025 in Aux Bldg
WO 01126106-03, inspect cables in R025 in Turbine Bldg
WO 01447552-01, Lighting panel intake structure
WO 01447565-01, Lighting panel outside charging pump room
Attachment
11
WO 01447567-01, Lighting panel 24A spent fuel pit
WO 01447569-01, Lighting panel spent fuel pit
WO 01447572-01, Lighting panel hot machine shop
WO 01447573-01, Lighting panel turbine area mezzanine floor
WO 01447576-01, Lighting panel turbine area ground floor
WO 01541004, Engineering Inspection of Pressurizer Relief Valve Wiring
Commitment Item 37
AR00092137-01, LR Commitment Item 37
LP-256, Containment High Range Radiation Monitor (AREA) RMS 32A & 32B
PRR 287488
RNP-L/LR-0390, Aging Management Review of Electrical Commodities for License Renewal,
Revision 4
WO 01410926, R31A & B review calibration results for age degradation
WO 082332-01, R-32A & B Review calibration results for age degradation
Commitment Item 38
AR 316141, Unexpected degradation of NIS Power Range N-42, N-43, and N-44 detectors
AR 92139-02, Aging Management Program for Neutron Flux Instrumentation
PM-496, Source Range Cable/Connector/Detector Condition Monitoring (Shutdown)
PM-497, Intermediate Range Cable/Connector/Detector Condition Monitoring (Shutdown)
PM-498, Power Range Cable/Connector/Detector Condition Monitoring (Shutdown)
PMR 10603-02, N-31
PMR 10604-02, N-32
PMR 14160-04, N-35
PMR 14161-04, N-36
PMR 14163-03, N-41
PMR 14164-03, N-42
PMR 14165-03, N-43
PMR 14166-03, N-44
PMR 79175-01, NE-51
PMR 79176-01, NE-52
RNP-L/LR-0390, Aging Management Review of Electrical Commodities for License Renewal,
Revision 4
WO 01038843-01, Condition monitoring N-31
WO 01038846-01, Condition monitoring N-32
WO 01038875-01, Condition monitoring N-41
WO 01038876-01, Condition monitoring N-35
WO 01038877-01, Condition monitoring N-36
WO 01038879-01, Condition monitoring N-42
WO 01038880-01, Condition monitoring N-43
WO 01038882-01, Condition monitoring N-44
WO 01286606-01, Condition monitoring NE-51
WO 01286866-01, Condition monitoring NE-52
Commitment Item 39
AR00092145-01, LR Commitment Item 39
PMR 80661, Perform thermography on DSDG fuse
RNP-L/LR-0390, Aging Management Review of Electrical Commodities for License Renewal,
Revision 4
WO 01351332-01, Perform thermography on DSDG fuse
Attachment
12
Commitment Item 40
AR00092147-01, LR Commitment Item 40
AR 302117, E1 non-segregated bus degradation
EC 72328, License Renewal Commitment Number 40, Aging Management Program for Bus
Duct
PM-013, 480V Nonseg Bus Duct Inspection
PM-128, Main Generator Isophase Bus Duct Inspection
PM-143, Auxiliary Transformer Bus Duct Inspection
PM-144, Startup Transformer Bus Duct Inspection
PMID 11457, Generator bus duct
PMID 14146, Thermography - plant transformers
PMID 86588-01, Perform Thermal Imaging on EDG A Nonseg Bus Duct
PMID 86590-01, Perform Thermal Imaging on EDG B Nonseg Bus Duct
PMID 88097-01, Perform Thermal Imaging on MG Set A and B Bus Work
PMID 88098-01, Perform Thermal Imaging on DS Bus Work And Nonseg Bus
PMID 88099-01, Perform Thermal Imaging on System 5175 Non Segregated Bus
PMID 88100-01, Perform Thermal Imaging on Bus Duct Buses E1 & E2 Tie
PMR 264977
PMR 318169
PMR 318518
PMR 321962
PMR 321967
PMR 322527
PMR 322538
PMR 322648
PMR 322649
PMR 322654
PMR 374675
RNP-L/LR-0390, Aging Management Review of Electrical Commodities for License Renewal,
Revision 4
WO 01130871-01, Inspect isophase bus de -Ionizing Baffle
WO 1039856-01
WO 1152123
WO 1152124, Remove 480V Bus Duct Panels And Perform Inspection
WO 1455216
WO 1496235
WO 1588504-01, Perform Thermography, Plant Transformers
WO 1588504-01, Thermography, Plant Transformers
WO 1625326-01,
WO 1636173-01, Perform Thermal Imaging on DS Bus Work And Nonseg Bus
WO 1636174-01, Perform Thermal Imaging On System 5175 Non Segregated Bus
WO 1636312-01, Perform Thermal Imaging On MG Set A and B Bus Work
WO 59553-02, Perform Inspection Of Generator Isolated Phase Bus Duct
WO 59747, Perform Meggaring Of Generator Isolated Phase Bus Duct
Attachment
13
WO1152136, Remove 480V Bus Duct Panels And Perform Inspection
Commitment Item 41 and 44
AR00092148-01, LR Commitment Item 41
AR00092152-01, LR Commitment Item 44
Engineering Change 72274, Reevaluate EQ Limitorque MOV Number of Strokes/Cycles for 60
Years Plant Life, Revision 0
EQDP - 2.0 - Limitorque MOV actuators outside CV, Revision 10
EQDP - 2.1 - Limitorque MOV actuators outside CV, Revision 9
EQDP - 37.0 - Minco RTDs for RVLIS, Revision 6
EST-012 Engineering Periodic Verification of EQ Component Replacements with Qualified Life
Less then 60 years, Revision 4.
Commitment Item 42
WCAP-15828, Evaluation of Pressurized Thermal Shock for H.B. Robinson Unit 2, Revision 0
Engineering Change 51708R2, RCS Operating Limits
Commitment Item 45 and 46
AR00092154-01, LR Commitment Item 45 TLAA Containment Tendon Loss of Pre-stress
AR00092155, LR Commitment Item 46
EST-064, Containment Isolation Valve Local Leakage Rate Survey (Refueling Interval Not to
Exceed 2 Years, Revision 12
EST-085, Containment Integrated Leak Rate Test, Revision 16
PMID 10563-02, License renewal commitment structural integrity test
RNP-C-CONT-1004, Calculation for Prestress Tendon Loading, Revision 0
RNP-L/LR-0506, Prestressed Steel Tendons Time-Limited Aging Analysis Review, Revision 1
Commitment Item 47
AR00092156, LR Commitment Item 47
Amendment 198, Elimination of Neutron Absorption Credit for Boraflex, to Facility Operating
License No. DPR-23 for the H.B. Robinson Steam Electric Plant, Unit No. 2
Other Documents
AP-007, Generic Procedure Writers Instructions, Revision 24
AR 247243, RIS 2007-16 - Implementation of 10 CFR 54.37(b) for holders of Renewed
Licenses
EGR-NGGC-0201, NGG Standard Procedure Writers Guide, Revision 19
EGR-NGGC-0501, Nuclear Plant License Renewal Program, Revision 13
EGR-NGGC-0512, License Renewal Aging Management Activities, Revision 5
List of Engineering Changes Categorized as MODIFIED between 06/01/2002 and 05/01/2004
H.B. Robinson Steam Electric Plant Unit 2 - Updated Final Safety Analysis Report, Revision 19,
Chapter 18, Aging Management Programs and Activities
H.B. Robinson Steam Electric Plant Unit 2 - Updated Final Safety Analysis Report, Revision 20,
Chapter 18, Aging Management Programs and Activities
H.B. Robinson Steam Electric Plant Unit 2 - Updated Final Safety Analysis Report, Revision 21,
Chapter 18, Aging Management Programs and Activities
H.B. Robinson Steam Electric Plant Unit 2 - Updated Final Safety Analysis Report, Revision 22,
Chapter 18, Aging Management Programs and Activities
NCR 00380367, FSAR Chapter 18 Update for Vessel Head Inspections
NCR 00380376, MMM-016 Clarification to Define "High Strength" Bolting
NCR 00380471, Tracking of Open License Renewal Commitments
Attachment
14
NCR 00380649, License Renewal Commitments for FAC Program
NCR 00380767, Discrepancy in OP-909 Concerning LR Commitment for AFOST
NCR 00381173, PLP-037 Requirements for NIS Maintenance
NCR 00381872, Difference in Words between LR Commitment and Procedures
NCR 00382852, License Renewal Commitment Not Fully Described in the UFSAR
NCR 00382858, Part of License Renewal Commitment Lost in Procedure Revision
NRC 00380373, Letter RNP-RA/09-0067 was Identified with a Discrepancy
NUREG-1785, Safety Evaluation Report (SER) Related to the License Renewal of H.B.
Robinson Steam Electric Plant, Unit 2
PRO-NGGC-0204, Procedure Review and Approval, Revision 16
RNP-RA/04-0143, H.B. Robinson Steam Electric Plant Unit 2 - Submittal of Updated Final
Safety Analysis Report, Revision 19, 11/24/2004
RNP-RA/06-0036, H.B. Robinson Steam Electric Plant Unit 2 - Submittal of Updated Final
Safety Analysis Report, Revision 20, 04/17/2006
RNP-RA/08-0015, H.B. Robinson Steam Electric Plant Unit 2 - Submittal of Updated Final
Safety Analysis Report, Revision 21, 06/22/2008
RNP-RA/09-0039, H.B. Robinson Steam Electric Plant Unit 2 - Submittal of Updated Final
Safety Analysis Report, Revision 22, 05/06/2009
Attachment
15
LIST OF ACRONYMS USED
ACI American Concrete Institute
ADAMS Agencywide Document Access Management System
AMP Aging Management Program
AMR Aging Management Review
ANSI American National Standard Institute
AR Action Request
ASCE American Society of Civil Engineers
ASME American Society of Mechanical Engineers
BACCP Boric Acid Corrosion Control Program
BPVC Boiler and Pressure Vessel Code
CASS Cast Austenitic Stainless Steel
CCW Component Cooling Water
CFR Code of Federal Regulations
CUF Cumulative Usage Factor
EAF Environmentally Assisted Fatigue
EC Engineering Change
EDG Emergency Diesel Generator
EOF Emergency Operations Facility
EPRI Electric Power Research Institute
EQ Environmental Qualification or Environmentally Qualified
EQDP Environmental Qualification Documentation Package
FAC Flow-Accelerated Corrosion
FERC Federal Energy Regulatory Commission
FMP Fatigue Monitoring Program
FOST Fuel Oil Storage Tank
GALL NUREG-1801 Generic Aging Lessons Learned
ILRT Integrated Leak Rate Test
IMC Inspection Manual Chapter
INPO Institute of Nuclear Power Operations
IP Inspection Procedure
IR Inspection Report
ISI Inservice Inspection
LLRT Local Leak Rate Test
LRA License Renewal Application
LTOP Low Temperature Over-Pressure
MOV Motor-Operated Valve
NACE National Association of Corrosion Engineers
NCR Nuclear Condition Report
NDE Non-Destructive Examination
NEI Nuclear Energy Institute
NRC U.S. Nuclear Regulatory Commission
NUMARC Nuclear Management and Resources Council
PARS Publicly Available Records
PRR Procedure Revision Request
RAI Request for Additional Information
RNP Robinson Nuclear Plant
RO Refueling Outage
Attachment
16
SER Safety Evaluation Report
SSC Structures, Systems, and Component
TLAA Time Limited Aging Analysis
UFSAR Updated Final Safety Analysis Report
URI Unresolved Item
UT Ultrasonic Testing
VHP Vessel Head Penetration
WO Work Order
Attachment