ML101660452
| ML101660452 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 09/03/2010 |
| From: | Bennett Brady License Renewal Projects Branch 1 |
| To: | Joyce T Public Service Enterprise Group |
| Cunanan, A DLR/RPB1 415-3897 | |
| References | |
| TAC ME1832 | |
| Download: ML101660452 (86) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 3, 2010 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236 Hancocks Bridge, NJ 08038
SUBJECT:
AUDIT REPORT REGARDING THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO. ME1832)
Dear Mr. Joyce:
By letter dated August 18, 2009, Public Service Enterprise Group Nuclear, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License NPF-57 for Hope Creek Generating Station. On February 19, 2010, the U.S. Nuclear Regulatory Commission audit team completed the onsite audit of aging management programs. The audit report is enclosed.
If you have any questions, please contact me by telephone at 301-415-2981 or bye-mail at bennett.brady@nrc.gov.
Sincerely, Bennett M. Brady, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-354
Enclosure:
As stated cc w/encl: Distribution via Listserv
September 3, 2010 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC P.O. Box 236 Hancocks Bridge, NJ 08038
SUBJECT:
AUDIT REPORT REGARDING THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO. ME1832)
Dear Mr. Joyce:
By letter dated AL\gust 18, 2009, Public Service Enterprise Group Nuclear, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54) for renewal of Operating License NPF-57 for Hope Creek Generating Station. On February 19, 2010, the U.S. Nuclear Regulatory Commission audit team completed the onsite audit of aging management programs. The audit report is enclosed.
If you have any questions, please contact me by telephone at 301-415-2981 or bye-mail at bennett.brady@nrc.gov.
Sincerely, IRA!
Bennett M. Brady, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No.: 50-354
Enclosure:
As stated cc w/encl: Distribution via Listserv DISTRIBUTION: See next page ADAMS Accession Number ML101660452 OFFICE PM:DLR:RPB1 LA:DLR BC:DLR:RPB1 PM:DLR:RPB1 NAME BBrady IKing BPham BBrady DATE 08112/10 07/07/10 08/30/10 09/03/10 OFFICIAL RECORD COpy
Letter to T. Joyce from B. Brady dated September 3, 2010
SUBJECT:
AUDIT REPORT REGARDING THE HOPE CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO. ME1832)
DISTRIBUTION:
HARD COPY:
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RdsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDIrRapb Resource RidsOgcMailCenter Resource BPham BBrady ACunanan SCuadrado CEccleston REnnis CSanders BHarris, OGC ABurritt, RI RConte, RI MModes, RI DTifft, RI NMcNamara, RI
u.s. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION - DIVISION OF LICENSE RENEWAL AGING MANAGEMENT AUDIT REPORT Docket No.: 50-354 License No.: NPF-57 Licensee: PSEG Nuclear llC Facility: Hope Creek Generating Station location: Alloways Creek Road Hancocks Bridge, New Jersey 08038 Dates: February 8-19, 2010 Reviewers: D. Ashley, Sr. Project Manager, Division of License Renewal (DlR)
D. Pelton, Branch Chief, DlR R. Auluck, Branch Chief, DlR D. Brittner, Reactor Engineer, DlR D. Nguyen, Electrical Engineer, DlR C. Doutt, Sr. Electrical Engineer, DlR R. Li, Electrical Engineer, DlR A. Sheik, Sr. Structural Engineer, DlR W. Holston, Mechanical Engineer, DlR M. Banic, Engineer, DlR P. Purtscher, Engineer, DCI E. Murphy, Engineer, DCI J. Davis, Advanced Technologies and laboratories (ATl)
W. Pavanich, ATl R. Jackson, ATl E. Patel, ATl D. Naus, Oak Ridge National laboratory (ORNl)
J. Baker, ORNl B. Oland, ORNl K. Axler, Center for Nuclear Waste Regulatory AnalYSis (CNWRA)
J. Mancillas, CNWRA R. Kazban, CNWRA
Approved By: Jerry Dozier, Chief Aging Management of Reactor Systems and Guidance Update Branch Division of License Renewal Office of Nuclear Reactor Regulation Rajender Auluck, Chief Aging Management of Structures, Electrical, and Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation David L. Pelton, Chief Aging Management of Plant Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation
Introduction An onsite audit was conducted by the U.S. Nuclear Regulatory Commission (NRC) project team at the Hope Creek Generating Station (HCGS) on February 19, 2010. The purpose of this audit was to examine the applicant's aging management programs (AMPs) for the Hope Creek plant and to verify the applicant's claim of consistency with the corresponding NUREG-1801, "Generic Aging Lessons Learned (GALL) Report" AMPs. Exceptions to the GALL Report AMP elements are evaluated separately as part of the NRC staff's review of the license renewal application (LRA) and documented in the staff's Safety Evaluation Report (SER).
The "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR), NUREG-1800, Revision 1, provides the staff guidance for reviewing an LRA.
The SRP-LR allows an applicant to reference in its LRA the AMPs described in the GALL Report. If an applicant credits an AMP for being consistent with a GALL Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL Report program. The applicant's determination should be documented in an auditable form and maintained onsite.
During this audit, the staff audited program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria), and program element 10, (operating experience), of the applicant's AMPs. These AMPs were claimed by the applicant to be consistent with the GALL Report. The staff compared the applicant's AMPs to the equivalent elements of the associated AMP described in the GALL Report, unless otherwise indicated in this audit report. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) were audited by another NRC project team during the Scoping and Screening Methodology Audit and are evaluated separately. In addition, the staff verified the conditions at the plant were bounded by the conditions for which the GALL Report program was evaluated.
The staff also examined the applicant's program bases documents and related references for these AMPs and interviewed HCGS representatives to obtain additional clarification related to the AMPs.
- 2 LRA AMP B.2.1.1 ASME Section Xllnservice Inspection, Subsections IWB, IWe, and IWD In the HCGS LRA, the applicant states that AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, is an existing program that is consistent with the program elements in GALL Report AMP XI.M1. "ASME Section Xllnservice Inspection, Subsections IWB, IWC, and IWD." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending. and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the LRA Appendix Section A.2.1.1, Updated Final Safety Analysis Report (UFSAR)
Supplement. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit.
Issues identified but not resolved in this report are addressed in the SER During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "Class 1," "weld," "examination,"
"lSI," "inspection," "indication," "crack," "flaw," and "internal."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.M1 Salem and Hope Creek Program Basis Document - ASME Revision 1 Section Xllnservice Inspection, Subsections IWB, IWC, and 7/21/2009 IWD NIA Hope Creek Operating Experience Summary for: No Revision No.
Notifications 20341161,20211152,20143826,20141810, Not dated 20143882,20143892,20139838,20342133,20113511; Computer generated reports related to these notifications.
i HOP03.G03 Hope Creek -Inservice Inspection Program Plan for Third 10 Revision 0 Year Inspection Interval 9/12/2007 ERA-AA-330 Conduct of Inservice Inspection Activities Revision 7 ERA-AA-330-0 1 Section XI Pressure Testing Revision 6 ERA-AA-330-02 Inservice Inspection of Section XI Welds and Components Revision 6 ER-SH-330-0009 PSEG Nuclear Repair Program Manual for the Control of Rand Revision 1 10/1/2008 NR Certificates of Authorization Based on its review of the listed documents and interview with the applicant, the staff confirmed that the applicant's plant configuration is such that all components specified in applicable ASME Code Section XI, Subsections IWB, IWC, and IWD, examination categories can be inspected and that none have been excluded 'from inspection based on consideration of the burden upon the licensee that could result if requirements to inspect the component were imposed on the facility. This is consistent with the scope of program described in GALL AMP XI.M1, Element 1.
-3 During the audit of program elements 1-6, the staff found that:
Elements 1, 2, 3, 5, and 6 (scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria) of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether element 4 (detection of aging effects) of the LRA AMP is consistent with the corresponding element of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element number 4 is consistent with the corresponding element of the GALL Report AMP, the staff indicated that it would consider issuing an RAI for the following subject:
In element 4 of the LRA AMP the program basis document states that for the current inservice inspection interval risk informed inservice inspection (RI-ISI) alternative requirements apply to Categories B-F, B-J, C-F-1 and C-F-2 piping welds; and the description of the AMP in LRA Section B.2.1.1 states, "The Hope Creek ASME Section XI program also includes a Risk-Informed Inservice Inspection (RI-ISI) program." In the GALL Report AMP, the recommendations in element 4 are based on ASME Code Section XI requirements for examinations as specified for the various component examination categories in IWB-2500, IWC-2500 and IWD-2500. It is not clear to the staff that the statements in the HCGS program basis document and in the LRA are consistent with the recommendations in the GALL Report because it is not clear whether the statements in the LRA AMP and in LRA Section B.2.1.1 refer to only the current lSI interval. which does not carry forward into the period of extended operation, or whether the statements mean that the applicant is proposing in the LRA to continue implementation of alternate methods during the period of extended operation.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of
- 4 LRA program elements 1-6 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.2 Water Chemistry In the HCGS LRA, the applicant states that AMP B2.1.2, "Water Chemistry," is an existing program with exceptions that is consistent with the program elements in GALL Report AMP XI.M2, "Water Chemistry." To verify this claim of consistency the staff audited the LRA AMP.
This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.2. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The first exception affects LRA program element 1 (scope) and element 3 (parameters monitored or inspected). In the GALL Report AMP, these program elements recommend that hydrogen peroxide be monitored to mitigate the degradation of structural materials.
Alternatively, this program element in the LRA states that the electrochemical corrosion potential (ECP) will be monitored to mitigate the degradation of structural materials.
The second exception affects LRA program element 1 (scope) and element 3 (parameters monitored or inspected). In the GALL Report AMP, this program element recommends that dissolved oxygen is monitored and controlled below levels known to result in loss of material or cracking. Alternatively, this program element in the LRA states that dissolved oxygen is not monitored in the condensate storage tank water, demineralized water storage tank water, spend fuel pool water, and torus water.
The third exception affects LRA program element 1 (scope) and element 3 (parameters monitored or inspected). In the GALL Report AMP, this program element recommends that pH is maintained in accordance with established guidance. Alternatively, this program element in the LRA states pH is not monitored for torus water.
The fourth exception affects LRA program element 1 (scope) and element 4 (detection of aging effects). In the GALL Report AMP, this program element recommends that the aging of standby liquid control (SBLC) system components subject to sodium pentaborate environment relies on control of SBLC poison storage tank water chemistry. Alternatively, this program element in the LRA states that the makeup water to the tank is monitored in lieu of the sodium pentaborate solution in the storage tank.
- 5 During its audit, the staff conducted walkdowns, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "chemistry,"
"corrosion," "pH," "dissolved oxygen," and "cracking."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.M2 Water Chemistry Revision 2 11119/2009 BWRVIP-130 BWR Vessel and Intemals Project BWR Water Chemistry No Revision No.
Guidelines 10/2004 EPRI TR 1008192 BWRVIP-190 BWR Vessel and Internals Project BWR Water Chemistry No Revision No.
Guidelines EPRI TR-1016579 10/2008 CY-AS-120-100 Reactor Water Chemistry Revision 8 Not dated I HC.CH-TI.ZZ-0012 Chemistry Sampling Frequencies, Specifications and Revision 56 !
Surveillances Not dated CR Number 203400 R14 P220 LLRT-1GSHV-4980/4958 OVER No Revision No.
10/16/2007 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of program element 1 (scope),
element 3 (parameters monitored or inspected), and element 4 (monitoring and trending) of the LRA AMP associated with the exceptions were not evaluated during this audit. Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.
During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
-6 The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 8.2.1.3 Reactor Head Closure Studs In the HCGS LRA, the applicant states that AMP B.2.1.3, "Reactor Head Closure Studs," is an existing program that is consistent with the program elements in GALL Report AMP XI.M3, "Reactor Head Closure Studs." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope of program, preventive actions, parameters monitored/inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.3. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "head stud," "head bolt,"
"examination," "closure studs," "torque," "preload," "lubricant," "galling," and "tensioner."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.M3 Salem and Hope Creek Program Basis Document for Revision 2 Reactor Head Closure Studs 12/9/2009 i
Summary No. Hope Creek Component History Report for RPV Closure Nuts No Revision No. !
12/4/2008 Summary No. 100881 Hope Creek Component History Report for RPV Closure No Revision No.
Washers 112/4/2008 Work Order Work Order for Examination, Evaluation and Acceptance or I No Revision No.
70042508 Repair of Hope Creek RPV Head Castle Nut #66 12/14/2004 HC.MD-FR.KE Hope Creek Procedure: Reactor Pressure Vessel Assembly Revision 14 0036(0) 3/30/2009
-7 Document Title Revision I Date Product V075440 Material Safety Data Sheet for NEV-SZ NUCLEAR NG-8 from No Revision No.
Bostik Findle 9/17/2004 i Item No. 51269 Material Safety Data Sheet for N-5000 High Purity Anti-Seize No Revision No.
r-::---:---:-:,.,..---=-:--=- from Loctite 8/19/2004 Product Name: DAG ial Safety Data Sheet for DAG 156 Graphite in Isopropanol 156 cheson Colloids Com an CICP Number: 0100 Material Safety Data Sheet for Neolube No.1 from Huron vision No.
0102 Industries, Inc. =02=---_ _----.J Based on its review of the listed documents and interview with the applicant, the staff confirmed that the applicant does not use thread coatings or lubricants containing molybdenum disulfide (MoS z) on the reactor head closure studs. Although it is not specifically referenced in GALL AMP XI.M3; NUREG-1339, "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants," includes recommendations that thread lubricants containing MoS z not be used because its use increases the likelihood of cracking due to stress corrosion in high strength bolts. The staff finds the applicant's restrictions with regard to use of MOz to be consistent with GALL AMP XI.M3, Element 2, which states that preventive actions include use of acceptable surface treatments and stable lubricants.
During the audit of program elements 1-6, the staff found that:
Elements 1, 2, 3, 5, and 6 (scope of program, preventive actions, parameters monitored/inspected, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether element 4 (detection of aging effects) of the LRA AMP was consistent with the corresponding element of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element number 4 is consistent with the corresponding element of the GALL Report AMP, the staff indicated that it would consider issuing an RAI for the following subject:
In its review of element 4 of the LRA AMP, the staff found that the applicant performs volumetric (not volumetric and surface) examination of reactor head closure studs when they are removed from the reactor vessel flange. In the GALL Report AMP, element 4 states that Examination Category B-G-1 for pressure-retaining bolting greater than 2 inches diameter in reactor vessel specifies surface and volumetric examination of studs when they are removed from the reactor vessel. It is not clear to the staff that these statements are consistent because the applicant does not routinely perform surface examinations of reactor vessel head closure studs when they are removed from the vessel flange.
During the audit of program element 10 (operating experience). the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and
- 8 The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1-6 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant. is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.4 BWR Vessel 10 Attachment Welds In the HCGS LRA, the applicant states that AMP B.2.1.4, "BWR Vessel 10 Attachment Welds,"
is an existing program that is consistent with the program elements in GALL Report AMP XI.M4, "BWR Vessel 10 Attachment Welds." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.4. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "cracking," "SCC," "jet pump,"
"weld," "indication," and "flaw."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date GALL AMP XI.M4 BWR Vessel ID Attachment Welds Revision 1 2001
-9 Document Title Revision I Date HCGS LRAA2.1.4 BWR Vessel 10 Attachment Welds No Revision No.
8/18/2009 HCGS LRA B2.1.4 BWR Vessel 10 Attachment Welds No Revision No.
8/18/2009 HC-PBD-AMP-XI.M4 BWR Vessel 10 Attachment Welds Program Basis Revision 2 Oocument 12/10/09
. BWRVIP-48-A BWR Vessel and Internals Project Vessel 10 June 2004 Attachment Weld Inspection and Flaw Evaluation Guide Not dated ER-AB-331 BWR Internals Program Management Revision 7 Not dated ER-AB-331-1001 BWR Internals Program Revision 3 Not dated ER-M-330-002 Inservice Inspection of Section XI Welds and Revision 7 Components Not dated
! OU-M-122 Qualification and Certification of Nondestructive Exam Revision 2 Personnel Not dated During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le.* no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant. is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP. as implemented by the applicant, is sufficient to detect and manage aging; and
- 10 Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.5 BWR Feedwater Nozzle In the HCGS LRA, the applicant states that AMP B.2.1.5, "BWR Feedwater Nozzle," is an existing program that is consistent with the program elements in GALL Report AMP XI.M5, "BWR Feedwater Nozzle." To verify this claim of consistency the staff audited the LRA AMP.
This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.5. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "nozzle," "flaw," "cracking," and "indication."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date Notification No. Evaluate N5A N2G & N2H for welding flaws found during lSI No Revision No.
20411563 outside Section XI exam area 4/22/2009 Notification No. Indication found in N2K nozzle to safe end weld No Revision No.
20211152 1/14/2004 HC-PBD-AMP-XI. M5 BWR Feedwater Nozzle Program Basis Document Revision 2 12/10/2009 HC-PBD-AMP-XI.M5 Outage lSI Summary Report 2004 (RF12) No Revision No.
4/26/2005 HC-PBD-AMP-XI.M5 Outage lSI Summary Report 1998 (RF7) No Revision No.
3/12/1998 NUREG-0619 BWR Feedwater Nozzle and CRD Return Line Nozzle Nov. 1980 Cracking Not dated BWROG GE-NE-523 Alternative BWR Feedwater Nozzle Inspection Requirements Revision 1 A71-0594-A 5/2000
. Letter to NRC Results of BWR Feedwater Nozzle examinations HCGS No Revision No.
Docket 50-354 10/4/1988 N/A HCGS lSI Program Plan Third Ten-year Inspection Interval No Revision No.
12/20/1986 ER-AA-330-002 Procedure Inservice Inspection of Section XI Welds & Revision 6 Components Not dated
- 11 During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP.
as implemented by the applicant. is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.6 BWR CRD Return Line Nozzle In the HCGS LRA, the applicant states that AMP B.2.1.6, "BWR Control Rod Drive Return Line Nozzle," is an existing program that is consistent with the program elements in GALL Report AMP XI.M6, "BWR Control Rod Drive Return Line Nozzle." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.B. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
- 12 During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "cracking," "SCC," "nozzle,"
"indication," and "flaw."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Tille Revision I Date GALL AMP XLM6 BWR Control Rod Drive Return Line Nozzle Revision 1 2001 HCGS LRA A2.1.6 BWR Control Rod Drive Return Line Nozzle No Revision No.
811812009 HCGS LRA B2.1.6 BWR Control Rod Drive Return Line Nozzle No Revision No.
8/18/2009 HC-PBD-AMP-XI.M6 BWR Control Rod Drive Return Line Nozzle Basis Document Revision 2 12/10/2009 NUREG-0619 BWR Feedwater Nozzle and Control Rod Drive Return Line No Revision No.
Nozzle Cracking Nov. 1980 I NRC IN 2004-08 Reactor Coolant Pressure Boundary Leakage Attributable to No Revision No.
Propagation of Cracking in Reactor Vessel Nozzle Welds 4/22/2004 Notification No. Evaluate N5A N2G & N2H for welding flaws found during lSI No Revision No.
20411563 outside Section XI exarn area 4/22/2009 Notification No. Indication found in N2K nozzle to safe end weld No Revision No.
i 20211152 1/1412004 During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
- 13 The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.7 BWR Stress Corrosion Cracking In the HCGS LRA, the applicant states that AMP B.2.1.7, "BWR Stress Corrosion Cracking," is an existing program that is consistent with the program elements in GALL Report AMP XI.M7, "BWR Stress Corrosion Cracking." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1. 7. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "cracking," "SCC," "indication,"
and "flaw."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database ..
Relevant Documents Reviewed Document Title Revision I Date GALL AMP XI.M7 BWR Stress Corrosion Cracking Revision 1 2001
- HCGS LRAA2.1.7 BWR Stress Corrosion Cracking No Revision No.
8/18/2009 HCGS LRA B2.1.7 BWR Stress Corrosion Cracking No Revision No.
8/18/2009 HC-PBD-AMP-XI. M7 BWR Stress Corrosion Cracking Program Basis Document Revision 2 12/8/2009
-14 Document Title Revision I Date Notification No. Indication found in N2K nozzle to safe end weld No Revision No.
20211152 1/14/2004 Notification No. SIL 624 Stress Corrosion Cracking No Revision No.
.2025554 4/6/2000 Notification No. SIL 462 R1 Hand Hole Cracking No Revision No.
20060956 3/29/2001 GL 88-01 NRC Position on IGSCC in BWR Austenitic Stainless Steel No Revision No.
Piping 1/25/1988 NIA Print out from Site database on Hydrogen Injection Availability No Revision No.
from Current and Previous refueling cycles Not dated OU-M-122 Qualification and Certification of Nondestructive Exam Revision 2 Personnel Not dated During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant. is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore. acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
-15 LRA AMP B.2.1.8 BWR Penetrations In the HCGS LRA, the applicant states that AMP B.2.1.8, "BWR Penetrations," is an existing program that is consistent with the program elements in GALL Report AMP XI.M8, "BWR Penetrations." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.8. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "cracking," "SCC," "indication,"
and "flaw."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date GALL AMP XI.M8 BWR Penetrations Revision 1 !
2001 i HCGS LRA A2.1.8 BWR Penetrations No Revision No. !
8/18/2009 HCGS LRA B2.1.8 BWR Penetrations No Revision No.
8/18/2009 HC-PBD-AMP-XI.M8 BWR Penetrations Basis Document Revision 2 12/8/2009 BWRVIP-49-A BWRVIP, Instrument Penetration Inspection and Flaw No Revision No.
Evaluation Guidelines March 2002 NIA Print out from Site database on Hydrogen Injection No Revision No.
Availability from Current and Previous refueling cycles Not dated I
Notification No. Indication found in N2K nozzle to safe end weld No Revision No.
20211152 1/14/2004 OU-M-122 Qualification and Certification of Nondestructive Exam Revision 2 Personnel I
During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
- 16 During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.9 BWR Vessel Internals In the HCGS LRA, the applicant states that AMP B.2.1.9, "BWR Vessel Internals," is an existing program that is consistent with the program elements in GALL Report AMP XI,M9, "BWR Vessel Internals." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.9. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "cracking," "SCC," "weld,"
"indication," "flaw," and "jet pump."
-17 The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date ER-AB-331-101 BWR Reactor Internals Program Revision 3 Not dated Notification No. Steam Dryer Support Ring Indications No Revision No.
20411396 4/22/2009 Notification No. Indication on steam dryer weld BV-5 No Revision No.
20280742 4/18/2006 Notification No. 2 indications on steam dryer weld CH-7a No Revision No.
202574 4/17/2006 Notification No. Steam dryer damage to lower guide No Revision No.
20280947 4/20/2006 I
Notification No. Jet pump wedge wear on JP#2 No Revision No.
20279888 7/13/2006 Notification No. Jet pump wedge Stellite indications on JP#6 No Revision No.
20279979 4/14/2006 HCR-13-IWI-06-1 & Jet pump indications No Revision No.
HCR-13-IWI-06-2 4/2006 HCR14-1 04342-7 Refuel Outage 14 IWI Summary No Revision No.
10/2007 EPRI 1016577 BWRVIP-198, BWRVIP Inspection Trends, 2008 Update No Revision No.
10/2008 Order 70097073 Steam dryer Support Ring Indications No Revision No.
4/23/2009 During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
- 18 The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.10 Thermal Aging and Neutron Embrittlement of CASS In the HCGS LRA, the applicant states that AMP B.2.11 0, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)," is an existing program that is consistent with the program elements in GALL Report AMP XI.M10, 'Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.10. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "cracking," "SCC," "CASS,"
"indication," and "flaw."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date GALL AMP XI.M13 Thermal Aging and Neutron Irradiation Embrittlement of Cast Revision 1 Austenitic Stainless Steel (CASS) 2001 HCGS LRA A2.1.10 Thermal Aging and Neutron Irradiation Embrittlement of Cast No Revision No.
Austenitic Stainless Steel (CASS) 8/18/2009 HCGS lRA B2.1.10 Thermal Aging and Neutron Irradiation Embrittlement of Cast No Revision No.
Austenitic Stainless Steel (CASS) 8/18/2009 HC-PBD-AMP-XI.M13 Thermal Aging and Neutron Irradiation Embrittlement of Cast Revision 1 Austenitic Stainless Steel Program Basis Document 7/22/2009
-19 Document Title Revision I Date LR-N05-0337 Lett.. from PSEG to NRC, lSI Inspection Activities - 90 day ~Rev;sion No.
report. Thirteenth Refueling Outage HCGS Docket No. 50-354 12006 RA-08-030 Letter from Oyster Creek NGS to NRC License Renewal n No.
Commitment Docket No. 50-219 4/9/2008 OU-AA-122 Qualification and Certification of Nondestructive Exam Revision 2 Personnel Not dated During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP. as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 8.2.1.11 Flow Accelerated Corrosion In the HCGS LRA. the applicant states that AMP B2.1.11, "Flow Accelerated Corrosion (FAC),"
is an existing program that is consistent with an exception to the program elements in GALL Report AMP XI.M17, "Flow-Accelerated Corrosion." To verify this claim of consistency, the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive
- 20 actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (opera~ing experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.11. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The one exception affects the LRA program element 1 (scope of program) and element 4 (detection of aging effects). In the GALL Report AMP, these program elements recommend using the EPRI guidelines contained in Nuclear Safety Analysis Center-202L-R2, "Recommendations for an Effective Flow Accelerated Corrosion Program" (NSAC-202L-R2), to assure that the structural integrity of all carbon steel lines and valve bodies containing single phase and two-phase high-energy fluids is maintained. In the LRA, the applicant states that the FAC AMP is based on the EPRI guidelines found in NSAC-202L-R3.
During its audit, the staff reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using keywords: "flow accelerated corrosion," "FAC," and "corrosion."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date NSAC-202L Recommendations for an Effective Flow Accelerated Corrosion Revision 2 Program 4/1999 NSAC-202L Recommendations for an Effective Flow Accelerated Corrosion Revision 3 Proqram 12/2006 EPRI1013012 Determining Piping Wear Caused by Flow-Accelerated Revision 0 Corrosion form SinQle-Outage Inspection Data 3/2006 ER-AA-430 Conduct of Flow Accelerated Corrosion Activities No Revision No.
80096881-1201 ER-AA-430-1001 Guidelines for Flow Accelerated Corrosion Activities No Revision No.
80096881-1202 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program. Aspects of the program elements 1 and 4 (scope of program and detection of aging effects) of the LRA AMP associated with exceptions were not evaluated during this audit.
Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.
During the audit of program elements 1-6, the staff found that:
Elements 2 (preventive actions), 3 (parameters monitored or inspected), 5 (monitoring and trending), and 6 (acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP;
- 21 Elements 1 (scope of program) and 4 (detection of aging effects) of the LRA AMP were not strictly consistent with the corresponding elements of the GALL Report AMP but sufficient information was available to allow the staff to determine that these elements of the LRA AMP are equivalent to the corresponding elements of the GALL Report AMP.
The basis for the staffs determination that elements 1 (scope of program) and 4 (detection of aging effects) of the LRA AMP are equivalent to the corresponding GALL Report AMP is that NSAC-202L-R3 is essentially equivalent to NSAC-202L-R2 and provides an equivalent function of managing the FAC AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.12 Bolting Integrity In the HCGS LRA, the applicant states that AMP B.2.1.12, "Bolting Integrity," is an existing program with enhancement and exception that is consistent with the program elements in GALL Report AMP XI.M18, "Bolting Integrity." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement, LRA Section A.2.1.12. For the Bolting Integrity Program, the audit report also considers specific recommendations in the GALL Report related to program element 7 (corrective actions). More general GALL Report recommendations related to program elements 7-9 {corrective actions, confirmation process,
- 22 and administrative controls) are audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The one enhancement affects LRA program element 7 (corrective actions). This enhancement expands on the existing program element by modifying the existing program to state that the following bolting materials should not be reused: a) Galvanized bolts and nuts; b) ASTM A490 bolts; c) Any bolt and nut tightened by the turn of the nut method.
In LRA Section A.5, License Renewal Commitment List, Commitment Number 12, the applicant committed to implement this enhancement prior to the period of extended operation.
The one exception affects LRA program element 5 (monitoring and trending). In the GALL Report AMP, this program element recommends that if bolting connection for pressure retaining components (not covered by ASME Section XI) is reported to be leaking, then it may be inspected daily, and that if the leak rate does not increase the inspection frequency may be decreased to biweekly or weekly. Alternatively, this program element in the LRA states that the applicant uses its Corrective Action Program to determine an appropriate inspection frequency for identified leaks in bolting connections.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "bolt," "nut," "preload," "torque," "leak," "thread,"
and "gasket."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document TiUe Revision I Date SH-PBD-AMP-XI.M18 Program Basis Document - Bolting Integrity Revision 2 12115/2009 OU-AA-335-014 VT-1 Visual Examination Revision 0 Not dated OU-AA-335-015 VT-2 Visual Examination Revision 0 Not dated SH.MD-GP.ZZ-0022 Bolt Torquing and Bolt Sequence Guidelines Revision 4 6/10/2009 ER-AA-5400-1002 Buried Piping Examination Guide Revision 1 Not dated ER-SH-330-0009 PSEG Nuclear Repair Program Manual Revision 1 Not dated i HCGS Notification Bolt Missing on Base Plate of Pipe Support No Revision No.
I 20190648 5/20/2004 HCGS Notification Diesel Generator Lube Oil Leak from Strainer No Revision No.
20195446 7101/2000 HCGS Notification RWCU Pump Flange Found Leaking No Revision No.
20028454 5/02/2000
- 23 The staff noted that the applicant's program basis document for AMP B.2.1.12 states that the Bolting Integrity Program follows published EPRI NP-5769 guidelines for safety-related bolting, with the exceptions noted in NUREG 1339, and that material procurement, use of approved lubricants and sealants, proper torquing for preload control, and leakage evaluations are in accordance with applicable EPRI NP-5769 and TR-104213 recommendations. Because these EPRI guidance documents are referenced in GALL AMP XLM18, Elements 1 and 2, the staff finds the applicant's incorporation of guidance from these documents into its Bolting Integrity Program to be acceptable.
The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of program element 5 (monitoring and trending) of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of these program elements that are not associated with the exception were evaluated and are described below During the audit of program elements 1-6, the staff found that:
Elements 3, 4, 5, and 6 (parameters monitored/inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether elements 1 and 2 (scope of program, and preventive actions) of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 1 and 2 are consistent with the corresponding elements of the GALL Report AMP, the staff indicated that it would consider issuing RAls for the following subjects:
In its description of the LRA AMP, the applicant states that component support and structural bolting are managed as part of the Structures Monitoring Program, crane and hoist bolting is managed as part of the Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program, aging management of heating and ventilation bolted joints is managed by the External Surfaces Monitoring Program, and bolting in a buried environment is managed by the Buried Piping Inspection Program. In the GALL Report AMP, element 1 states that the program covers bolting within the scope of license renewal, including 1) safety-related bolting, 2) bolting for nuclear steam supply system (NSSS) component supports, 3) bolting for other pressure retaining components, including non-safety related bolting, and 4) structural bolting (actual measured yield strength 2:150 ksi). Also, in the GALL Report AMP, element 2 states that selection of bolting material and use of lubricants and sealants is in accordance with the guidelines of EPRI NP-5769 and the additional recommendations in NUREG-1339, and that bolting replacement activities include proper torquing and application of appropriate preload based on EPRI documents. It is not clear to the staff that the applicant's statement about the LRA AMP is consistent with the recommendations of the GALL Report AMP because it is not clear to the staff that all recommendations credited with managing the aging effects of bolting in the elements of GALL AMP XI.M18 are included in other programs that the applicant credits with managing aging effects of bolting. Also, it is not clear to the staff how procurement,
- 24 control of lubricants and sealants, application of appropriate preloads, and proper torquing of bolts are incorporated in the other programs credited by the applicant because those programs primarily involve inspection activities.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le. no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1-6 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.13 Open-Cycle Cooling Water System In the HCGS LRA, the applicant states that AMP B2.1.13, "Open-Cycle Cooling Water System,"
is an existing program that is consistent with the program elements in GALL Report AMP XI.M20, "Open-Cycle Cooling Water System." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.13. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent
- 25 database search of the applicant's operating experience database using the keywords:
"corrosion," "microbiological corrosion," "MIC," and "chemistry."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.M20 Open-Cycle Cooling Water Program Revision 2 10/9/2009 CY-AA-120-410 Circulating/Service Water Chemistry Revision 2 Not dated CY-AA-120-4110 Raw Water Chemistry Strategic Plan No Revision No.
Not dated ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide Revision 3 Not dated ER-AA-2030 Conduct of Plant Engineering Manual, Step 4.5.2, Step 4.6.5, Revision 8 Attachment 4. Not dated S1.0P-PM.SW-0001 Flush of Emergency Diesel Generator SW Supply Header I ~~~~~~~d1 SC.MD-PM.CC-0002 Component Cooling Heat Exchangers 11. 21 and 22 Intemal Revision 13 Inspection (6Y) Not dated Operator Training Performance Monitoring-Equipment Reliability due to Aging Revision 0 Presentation and Degradation 12/16/2009 ER-AA-340 GL 89-13 Implementing Procedure Revision 4 Not dated CR Number 20156978 25SW Pump Base Drain Has Thru Wall Leak No Revision No.
8/28/2003 CR Number 20192157 SW Leakage From Valve and Corrosion No Revision No.
4/20/2005 CR Number 20204610 22SW522 & 523 Have Sever Corrosion No Revision No.
9/23/2004 During the audit of program elements 1-6, the staff found that:
Elements 1-6 {scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria}
of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience
{Le., no previously unknown aging effects were identified by the applicant or the staff};
and The operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
- 26 Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 8.2.1.14 Closed-Cycle Cooling Water System In the HCGS LRA, the applicant states that AMP B2.1.14, "Closed-Cycle Cooling Water System," is an existing program with enhancements and an exception that is consistent with the program elements in GALL Report AMP MI.X21 , "Closed-Cycle Cooling Water System." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit.
This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 3 (parameters monitored or inspected),
element 4 (detection of aging effects) and element 5 (monitoring and trending). This enhancement expands on the existing program element by adding new recurring tasks for enhancing the performance monitoring of the Closed-Cycle Cooling Water System.
The second enhancement affects LRA program element 3 (parameters monitored or inspected),
element 4 (detection of aging effects) and element 5 (monitoring and trending). This enhancement expands on the existing program element by adding new tasks for enhancing the performance monitoring of the Chilled Water System.
The third enhancement affects LRA program element 3 (parameters monitored or inspected),
element 4 (detection of aging effects) and element 6 (acceptance criteria). This enhancement expands on the existing program element by adding a one time inspection of selected Closed-Cycle Cooling Water program components in stagnant flow areas to confirm the effectiveness of the Closed-Cycle Cooling Water Program.
The fourth enhancement affects LRA program element 3 (parameters monitored or inspected),
element 4 (detection of aging effects) and element 6 (acceptance criteria). This enhancement expands on the existing program element by adding a one time inspection of selected Closed-Cycle Cooling Water Program chemical mixing tanks and associated piping to confirm
- 27 the effectiveness of the Closed-Cycle Cooling Water Program on the interior surfaces of the tanks and associated piping.
The fifth enhancement affects LRA program element 2 (preventive action), element 4 (detection of aging effects) and element 5 (monitoring and trending). This enhancement expands on the existing program element by implementing a pure water control program for the plant auxiliary building chilled water system, which is part of the Control Area Chilled Water System. This program will comply with the pure water control program in accordance with EPRI TR 1007820.
The sixth enhancement affects LRA program element 3 (parameters monitored or inspected),
element 4 (detection of aging effects) and element 5 (monitoring and trending). This enhancement expands on the existing program element by adding a one-time inspection of selected Control Area Chilled Water System components to confirm the effectiveness of the Closed-Cycle Cooling Water program.
The first exception affects LRA program elements 2-5 (preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending). In the GALL Report AMP, these program elements recommend the use of EPRI Closed Cooling Water Chemistry Guidelines, TR-107396 Revision O. Alternatively, the applicant has indicated that the Closed-Cycle Cooling Water System Program is based on Revision 1 of this document, which was published in 2004 and is cited as EPRI TR-1007820.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "corrosion," "pH," "chloride," and "chemistry."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI. M21 Closed-Cycle Cooling Water Program Revision 2 12/14/2009 HC. OP-ST. KJ-OOO 1 Emergency Diesel Generator 1XG400 Operability Test Revision 67 ted HC.OP-IS.EG-0001 Safety Auxiliaries Cooling Pump Surveillances-A SACS Revision 30 Pump XP210-Inservice Test Not dated HC.CH-TI.ZZ-0012 Chemistry Sampling Frequencies, Specifications and Revision 55 Surveillance Not dated CY-AA-120-400 Closed Cooling Water Chemistry =:n11 dated CY-AA-12D-4000 Closed Cooling Water Chemistry Strategic Plan Revision 4 I Not dated
- Operator Training Presentation Performance Monitoring-Equipment Reliability Due to Revision 0 Aging and Degradation 12/16/2009 CR Number 20223872 Corrosion Inside Cooler 1AVH401 No Revision No.
5/712006
- 28 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of program elements 2-6 (preventative actions, parameters monitored or inspected, monitoring and trending, acceptance criteria) of the LRA AMP associated with the exception were not evaluated during this audit.
Aspects of these program elements that are not associated with the exception were evaluated and are described below.
During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope, preventative actions, parameters monitored or inspected, monitoring and trending, acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.15 Inspection of Overhead Load, Refueling In the HCGS LRA, the applicant states that AMP B2.1.15 "Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M23, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems."
To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection
- 29 of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.1S. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 1 (scope of program) and element 3 (parameters monitored or inspected). This enhancement expands on the existing program element by adding visual inspection of structural components and structural bolts for loss of material due to general corrosion, pitting, and crevice corrosion and structural bolting for loss of preload due to self-loosening.
The second enhancement affects LRA program element 1 (scope of program) and element 3 (parameters monitored or inspected). This enhancement expands on the existing program element by adding the requirement for visual inspection of the rails and the rail system for loss of material due to wear.
The third enhancement affects LRA program element 6 (acceptance criteria). This enhancement expands on the existing program element by requiring evaluation of significant loss of material due to corrosion for structural components and structural bolts, and significant loss of material due to wear of rail in the rail system.
In Appendix A, Table A-S of the LRA, Commitment No.13, the applicant committed to implement these enhancements prior to the period of extended operation.
During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "heavy load," "handling," "polar crane," and "overhead."
During the interview, the staff requested clarification on whether structural bolting, which is inspected as part of this program, is also included in the Bolting Integrity Program. The applicant responded that the structural bolting associated with the overhead handling systems is not included in the Bolting Integrity Program, and that the Bolting Integrity Program states that some bolting is included in other AMPs including this one. The staff was satisfied with the response.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date Crane Manufactures Specifications for Electrical Overhead Traveling Cranes No Revision No.
Association of 1970 America, Inc, CMAA Specification No. 70 ASME/ANSI B30.2 Overhead and Gantry Cranes (Top Running Bridge, Single or No Revision No.
Multiple Girder, Top running Trolley HOist) 1976
- 30 Document Title Revision I Date ASME/ANSI B30.10 Hooks No Revision No. i 2005 ASME/ANSI B30.11 Monorails and Under hung Cranes No Revision No. !
2004 ASME/ANSI B30.16 Overhead Hoists (Under hang) No Revision No.
2003 i
- NUREG-0612 Control of Heavy Loads at Nuclear Power Plants, U.S. Nuclear No Revision No.
Regulatory Commission 1980 NRC Bulletin 96-02 Movement of Heavy Loads Over the Spent Fuel, over Fuel in the No Revision No.
Reactor Core, or Over Fuel in the Reactor Core, or Over Safety- 4/11/1996 Related EQuipment SH-PBD-AMP-XI.M23 Inspection of Overhead Heavy Load and Ught Load (Related to No Revision No.
Refueling) Handling Systems 2009 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e. no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
- 31 LRA AMP B.2.1.16 Compressed Air Monitoring In the HCGS LRA, the applicant states that AMP 82.1.16, "Compressed Air Monitoring," is an existing program that is consistent with the program elements in GALL Report AMP XI.M24, "Compressed Air Monitoring." To verify this claim of consistency the staff audited the LRA AMP.
This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.16. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "corrosion," "rust," and "piping."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.M24 Compressed Air Monitoring Revision 2 12/16/2009
- NRC Generic Letter 88-14 Instrument Air Supply Problems Affecting Safety-related Revision 0 Components. 8/8/1988 HC.IC-GP.ZZ-0069 Dew Point Test Revision 9 Not dated HC.OP-LR.GS-0100 GS Accumulator and Check Valve Leakage Rate Testing Revision 0 Not dated INPO SOER 88-01 Instrument Air System Failures No Revision No.
5/18/1988 EPRI TR-108147 Compressor and Instrument Air System Maintenance Guide No Revision No.
Revision to NP-7079 5/18/1988 CR Number 20048702 #1 SAC 11ST1081NTCLR VLV Corrosion No Revision No.
11/30/2000 CR Number 20093958 Replace/Repair Underground 1 W Station Air Piping No Revision No.
03/14/2002 During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope, preventative actions, parameters monitored or inspected, monitoring and trending, acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
- 32 The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 8.2.1.17 Fire Protection In the HCGS LRA, the applicant states that AMP B2.1.17, "Fire Protection," is an existing program with enhancements and an exception that is consistent with the program elements in GALL Report AMP XI.M26, "Fire Protection." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement, Section A.2.1.17. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 3 (parameters monitored or inspected),
element 4 (detection of aging effects), element 5 (monitoring and trending), and element 6 (acceptance criteria). This enhancement expands on the existing program elements by providing additional inspection guidance to identify degradation of fire barrier walls, ceilings, and floors for aging effects, such as cracking, spalling and loss of material caused by freeze-thaw, chemical attack, and reaction with aggregates.
The second enhancement affects LRA program element 3 (parameters monitored or inspected),
element 4 (detection of aging effects), element 5 (monitoring and trending), and element 6 (acceptance criteria). This enhancement expands on the existing program elements by
- 33 providing specific guidance for examining exposed external surfaces of the fire pump diesel fuel oil supply line for corrosion during pump tests.
In Appendix A, Table A-5 of the LRA, in Commitment No. 17, the applicant committed to implement these enhancements prior to the period of extended operation.
The first exception affects LRA program element 3 (parameters monitored or inspected) and element 4 (detection of aging effects). In the GALL Report AMP, this program element recommends a visual inspection and function test of the Halon and carbon dioxide (C02 )
systems every six months. Alternatively, this program element in the LRA states that the Halon and Carbon Dioxide fire suppression systems currently undergo functional testing every refueling cycle (18-months).
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "seal rupture," "fire degradation," and "diesel fire pump."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.M26 Program Basis Document - GALL Program XI.M26 Revision 1, 8/21/2009 HC.FP-SV.ZZ-0056 (F) Fire Barrier Inspection Revision 4 Not dated HC.FP-SV.ZZ-0026 (F) Flood and Fire Barrier Penetration Seal Inspection Revision 4 Not dated HC.FP-SV.ZZ-0078 (F) Drywall Fire Barrier Inspection Revision 2 Not dated HC.FP-SV.ZZ-0027 (F) Class 1 Fire Door Inspection and Operability Test Revision 6 Not dated HC.FP-SV.ZZ-0028 (F) Class 1 Fire Damper Visual Inspection Revision 2 Not dated HC.FP-ST.KC-0006 (F) Fire Pump Capacity Test Revision 9 Not dated HC.FP-ST.KC-0021 (F) C02 System Operability and Partial Discharge Test Revision 11 Not dated HC.FP-ST.KC-0048 (F) Halon System Air Flow Test Revision 3 Not dated FP-M-005 Fire Protection Surveillance and Periodic Test Program Revision 0 Not dated The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of program element 3 (parameters monitored or inspected) and program element 4 (detection of aging effects) of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of these program elements that are not associated with the exception were evaluated and are described below.
- 34 During the audit of program elements 1-6, the staff found that:
Elements 1, 2, 3, and 5 (scope of program, preventive actions, parameters monitored/inspected, and monitoring and trending) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether elements 4 and 6 (detection of aging effects and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 4 and 6 are consistent with the corresponding elements of the GALL Report AMP, the staff indicated that it would consider issuing RAls for the following subjects:
In element 4 of the GALL AMP, it states that visual inspections of the halon/C02 fire suppression system detect any sign of added degradation, such as corrosion, mechanical damage, or damage to dampers. In element 6 of the GALL AMP it states that any signs of corrosion and mechanical damage of the Halon/C02 fire suppression system are not acceptable. However, based on a review of the Program Basis Document that references procedure HC.FP-ST.KC-0021 (F), it was not clear if the applicant performs the visual inspection nor was it clear what acceptance criteria are used.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant. is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1-6 for which additional information or additional evaluation is required before consistency can be determined; and Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and
- 35 Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 8.2.1.18 Fire Water System In the HCGS LRA, the applicant states that AMP B2.1.18, "Fire Water System," is an existing program with enhancements and exceptions that is consistent with the program elements in GALL Report AMP XI.M-27, "Fire Water System." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.18. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program elements 2-6 (preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria). This enhancement expands on the existing program elements to inspect selected portions of the water based fire protection system piping located aboveground and exposed to the fire water internal environment by non-intrusive volumetric examinations, and that these inspections shall be performed prior to the period of extended operation and will be performed every 10 years thereafter.
The second enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program elements to replace or perform 50-year sprinkler head inspections and testing using the guidance of NFPA-25 "Standard fo(the Inspection, Testing and Maintenance of Water-Based Fire Protection Systems" (2002 Edition),
Section 5-3.1.1. These inspections will be performed by the 50-year inservice date and every 10 years thereafter.
In Appendix A, Table A-5 of the LRA, in Commitment No. 18, the applicant committed to implement these enhancements prior to the period of extended operation.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "biofouling," and "MIC."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.M27 Program Basis Document, Fire Water System Revision 1 Not dated
- 36 Document Title Revision I Date HC.FP-ST.KC-0008 (F) Fire Main Flow Test Revision 1 Not dated HC.FP-ST.KC-0004 (F) Class 1 Fire Suppression Water System Flush Revision 4 Not dated HC.FP-ST.KC-0006 (F) Fire Pump Capacity Test Revision 9 Not dated HC.FP-PM.KC-0036(Z) Fire Hydrant Inspection Revision 7 Not dated FP-AA-005 Fire Protection Surveillance and Periodic Test Program reisiono dated ND.FP-ST.FS-0037 (Q) Fire Hose Service Test and EP Equipment Inspection Revision 1 Not dated The staff asked the applicant to clarify whether gasket inspections are performed as part of the fire hose inspection. The applicant clarified that gaskets are considered short-lived components, because if the fire hose leaks during the hydrotest, the gasket is inspected and replaced if degraded. The staff considers this to be consistent with the GALL AMP.
The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit of program elements 1-6, the staff found that Elements 1-6 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and
- 37 Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 8.2.1.19 Aboveground Steel Tanks In the HCGS LRA, the applicant states that AMP B.2.1.19, "Aboveground Steel Tanks," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M29, "Aboveground Steel Tanks." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.19. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program elements 4, 5, and 6 (detection of aging effects, monitoring and tending, and acceptance criteria). This enhancement expands on the existing program element by adding ultrasonic inspection of the Fire Water Storage Tanks. The enhancement is provided to measure corrosion of bottom surfaces on those specific tanks, which are mounted on concrete pads, where visual inspection is not practicable due to inaccessibility.
The second enhancement affects LRA program elements 2, 4, 5, and 6 (preventive actions, detection of aging effects, monitoring and tending, and acceptance criteria). This enhancement expands on the existing program element by adding removal of insulation to facilitate effective visual inspection of the Fire Water Storage Tank surfaces. Note that the Fire Water Storage Tanks in-scope at the Hope Creek Generating Station are isolated from their concrete foundation by a fiber pad. Hence, the subject AMP does not specify inspection of the interface between the steel and concrete foundation.
In A.2.1.19 of the LRA, the applicant committed to implement these enhancements prior to the period of extended operation.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "corrosion," "tank," and "steel."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date S H-PBD-AMP-XI. M29 Program Basis Document Aboveground Steel Tanks Revision 1 8/18/2009 Notification 20122414 Extemal Coating Breakdown Identified No Revision No.
11/21/2002
- 38 Document Title Revision I Date OU-M-335-015 ual Examination Revision 0 Not dated SH-RA-IS.ZZ-0109(0) Storage Tank Integrity Testing Revision 4 12/12/2001 No document number Performance Monitoring - Equipment Reliability Due to Revision 0 (Presentation) Aging and Degradation 12/16/2009 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant. is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.20 Fuel Oil Chemistry In the HCGS LRA, the applicant states that AMP B.2.1.20, "Fuel Oil Chemistry," is an existing program with enhancements and exceptions that is consistent with the program elements in GALL Report AMP XI.M30, "Fuel Oil Chemistry." To verify this claim of consistency, the staff
- 39 audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A2.1.20. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 1 (scope of program), element 2 (preventive actions), element 3 (parameters monitored or inspected). and element 4 (detection of aging effects). This enhancement provides equivalent requirements for fuel oil purity and fuel oil testing. as described by the Standard Technical Specifications.
The second enhancement affects LRA program element 1 (scope of program). element 2 (preventive actions), element 3 (parameters monitored or inspected), and element 7 (corrective actions). This enhancement requires the addition of biocides, stabilizers and corrosion inhibitors as determined by fuel oil sampling or inspection activities.
The third enhancement affects LRA program element 1 (scope of program). element 2 (preventive actions). element 3 (parameters monitored or inspected), and element 7 (corrective actions). This enhancement requires internal inspection of Diesel Fire Pump Fuel Oil 280-gallon tank (T-565) using visual inspections and ultrasonic thickness examination of tank bottom.
The fourth enhancement affects LRA program element 1 (scope of program), element 2 (preventive actions). element 3 (parameters monitored or inspected). and element 4 (detection of aging effects). This enhancement provides quarterly water and sediment multilevel sampling on the Diesel Fuel Oil Storage Tanks identified in A2.1.20, in accordance with ASTM D2709.
The fifth enhancement affects LRA program element 1 (scope of program). element 2 (preventive actions). element 3 (parameters monitored or inspected). and element 4 (detection of aging effects). This enhancement provides internal inspection of the Diesel Fuel Oil Storage Tanks identified in A2.1.20 using visual inspections and ultrasonic thickness examination of tank bottoms.
The sixth enhancement affects LRA program element 1 (scope of program), element 3 (parameters monitored or inspected), element 4 (detection of aging effects), element 5 (monitoring and trending), and element 6 (acceptance criteria). This enhancement provides quarterly particulate sampling of the Diesel Fire Pump Fuel Oil 280-gallon tank (T-565), in accordance with modified ASTM 2276-00 Method A The modification consists of using a filter with a pore size of 3.0 microns instead of 0.8 microns.
The seventh enhancement affects LRA program element 1 (scope of program), element 3 (parameters monitored or inspected), and element 4 (detection of aging effects). This enhancement veri'fies the absence of any significant aging effects of each of the 550-gallon Diesel Fuel Oil Day Tanks, by performing a one-time inspection.
In Appendix A, Table A5 of the LRA, in Commitment No. 20, the applicant committed to implement these enhancements prior to the period of extended operation.
- 40 The first exception affects LRA program element 1 (scope of program), element 3 (parameters monitored or inspected), element 4 (detection of aging effects), and element 6 (acceptance criteria). The GALL Report AMP requires periodic sampling of tanks in accordance with the manual sampling standards of ASTM D 4057-95 (2000). The applicant stated that the 280 gallon Diesel Fire Pump Fuel Oil Tank (T-565) samples are single point samples obtained from the tank drain line located off of the bottom of the tank. This sample is not in accordance with the manual sampling standards as described in ASTM D 4057. The applicant further stated that for fuel oil storage tanks of less than 159 cubic meters spot sampling recommendations in ASTM D 4057-95 (2000) include a single sample from the middle (a distance of one-half of the depth of liquid below the liquid's surface). The 280-gallon Fire Pump Day Tanks are 1.06 cubic meters so the spot sampling recommendations in ASTM D 4057 are applicable. Although the actual sample location for tanks is lower than prescribed by the ASTM D 4057 standard, the sample results are more likely to capture contaminants, water, and sediment, thus making this a conservative sample location for fuel oil containments. Additionally, the applicant stated that the diesel generator is run on a weekly basis (taking suction from the bottom of the tank) and significant stratification is unlikely in such a small tank that is mixed weekly.
The second exception affects LRA program element 1 (scope of program), element 2 (preventive actions), element 3 (parameters monitored or inspected), element 4 (detection of aging effects), element 5 (monitoring and trending), and element 6 (acceptance criteria). The GALL Report AMP requires periodic sampling, draining, cleaning, and internal inspection of tanks, to reduce the potential for loss of material by exposure to fuel oil contaminated with water and microbiological organisms. The applicant stated that multilevel sampling, tank bottom draining, cleaning, and internal inspection of the 550-gal/on diesel fuel oil day tanks (1A-T-404, 1B-T-404, 1C-T-404 and 1D-T-404) is not periodically performed. Instead, the applicant stated that fuel oil from the 550-gallon day tanks is recirculated back to the 26,500-gallon storage tanks quarterly. To confirm the absence of any significant aging effects, the applicant will perform a one-time inspection of each of the 550-gallon day tanks and the condition will be entered into the corrective action process for resolution.
The third exception affects LRA program element 1 (scope of program), element 2 (preventive actions). element 3 (parameters monitored or inspected), element 5 (monitoring and trending),
and element 6 (acceptance criteria). The GALL Report AMP requires the additions of biocides, stabilizers, and corrosion inhibitors to prevent degradation of the fuel oil quality. The HCGS Fuel Oil Chemistry AMP does not require the addition of biocides, stabilizers, and corrosion inhibitors, but instead requires their use only in response to test results that indicate biocides, stabilizers, and corrosion inhibitors are needed.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "MIC," "microbiological," "pitting," "corrosion,"
and "tank."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
- 41 Relevant Documents Reviewed Document Title Revision I Date
- HC.CH-AP.ZZ-0041, Hope Creek Generating Station Diesel Fuel Oil Testing Program No Revision No.
- Revision 12 80096881-2202 I HC.CH-SA.ZZ-0011, Diesel Fuel Oil Sampling No Revision No.
80096881-2203 I
Revision 18 N/A Enhance procedures to include the addition of biocides to No Revision No.
minimize biological activity, stabilizers to prevent biological 80096881-22XX breakdown of the diesel fuel, or corrosion inhibitors to mitigate I corrosion as determined by fuel oil analysis activities.
! N/A One-time Internal Inspection of 1A-T-404 - 550-gallon Diesel Fuel No Revision No.
Oil Day Tank 80096881-22XX t N/A One-time Internal Inspection of 1B-T-404 - 550-gallon Diesel Fuel No Revision No.
Oil Day Tank 80096881-22XX N/A One-time Internal Inspection of 1C-T-404 - 550-gallon Diesel Fuel No Revision No.
Oil Day Tank 80096881-22XX N/A One-time Internal Inspection of 1 D-T404 - 550-gallon Diesel Fuel No Revision No.
Oil Day Tank 80096881-22XX
- 7524 T-565 92D Sample & Analyze No Revision No .
t Order 30172014 Diesel Fuel Oil 80096881-2221 (lAW HC.CH-SA.ZZ-0011
& HC.CH-AP.ZZ-0041)
The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements. Aspects of program elements 1-6 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP associated with the exceptions were not evaluated during this audit. Aspects of program elements not associated with the exceptions were evaluated and are described below.
During the audit of program elements 1-6, the staff found that:
Element 5 (monitoring and trending) and element 6 (acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Elements 1 (scope of program), 2 (preventive actions), 3 (parameters monitored or inspected), and 4 (detection of aging effects) of the LRA AMP were not strictly consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element numbers 1-6 are consistent with the corresponding elements of the GALL Report AMP, the staff indicated that it would consider issuing an RAI for the following subject:
During the staff review of the enhanced sampling procedures for the main fuel oil storage tank, the diesel fire pump fuel oil storage tanks, and the diesel fuel oil storage tanks, it was noted that the procedures state that if a Significant amount of water (greater than two ounces per gallon of fuel) is present, then a Notification per the Corrective Action Plan should be submitted. However, it is not clear how the person performing the testing will be able to complete the analysis with the current level of detail provided in the procedure. For example. with the main fuel oil storage tank, it was unclear how the tester would be able to discern two ounces of water in a 10-gallon sample. With the diesel fire pump fuel oil storage tank sample, it was unclear what level of water was
- 42 rejectable. given that only a one liter sample was specified to be drawn. Based on this information, the staff requested that the applicant provide clarification how there is reasonable assurance that the analyses to be performed in the enhanced procedures will be performed correctly.
During the audit of program element 10 (operating experience). the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1-6 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant. is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.21 Reactor Vessel Surveillance In the HCGS LRA, the applicant states that AMP B.2.1.21, "Reactor Vessel Surveillance," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M31, "Reactor Vessel Surveillance." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.21. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit.
The first enhancement affects LRA program element 6 (acceptance criteria). This enhancement expands on the existing program element by implementing the BWRVIP-116, "BWR Vessel and
- 43 Internals Project integrated Surveillance Program (ISP) Implementation for License Renewal,"
including the conditions specified by the NRC in its Safety Evaluation dated February 24, 2006.
The second enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program element by describing the actions the licensee will undertake if plant operations exceed either the limitations specified in RG 1.99, Rev. 1, or the surveillance data that are to determine the Upper Shelf Energy or P-T limits. In addition, if all the surveillance capsules are removed, the enhancement describes the actions the licensee will undertake, which could include reinstituting an active surveillance for HCGS.
In LRA Section A.S, License Renewal Commitment List, Commitment Number 21, the applicant committed to implement this enhancement prior to the period of extended operation.
During its audit, the staff reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "degradation," "flaw," "weld," and "reactor vessel."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date NIA Title 10 Code of Federal Regulations (CFR), Chapter 50, No Revision No.
Appendix H 1/1/2009 I
NIA NRC Regulation Guide 1.99 Revision 1 i Not dated BWRVIP-116 BWR Vessel and Internals Project integrated Surveillance No Revision No.
Program (lSP) Implementation for License Renewal 7/2003 GALL AMP XI.M31 Reactor Vessel Surveillance Revision 1 2001 HCGS LRA A2.1.21 Reactor Vessel Surveillance No Revision No.
8/18/2009 HCGS LRA B2.1.21 Reactor Vessel Surveillance No Revision No.
811812009 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff found that:
Elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
- 44 During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le. no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.22 One-Time Inspection In the HCGS LRA, the applicant states that AMP B.2.1.22, "One-Time Inspection Program," is a new program that is consistent with the program elements in GALL Report AMP XI.M32, "One Time Inspection." The applicant committed to implementing this program prior to the period of extended operation in License Renewal Commitment 22 of LRA Section A.5, License Renewal Commitment List. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.22. Program elements 7 -9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "loss of materia'," "stress corrosion cracking," "fouling," "MIC," "microbiological," "rust," "pitting," "microbiological corrosion,"
"corrosion," "internal surface corrosion," and "weld."
- 45 The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.M32 One-Time Inspection - Program Basis Document Revision 2 I Not dated lRA Section B.2.1.22 HCNGS lRA, Appendix B, One-Time Inspection No Revision No.
Not dated lRA Section A.2.1.22 HCNGS lRA, Appendix A. One-Time Inspection No Revision No.
Not dated HCGS-SSBD-OTI Hope Creek One-Time Inspection Sample Basis Document Revision 0 Not dated During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience identified by the staff's independent database search and supplemented by the applicant is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore. acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
- 46 LRA AMP 8.2.1.23 Selective Leaching of Materials In the HCGS LRA, the applicant states that AMP B2.1.23, "Selective Leaching of Materials," is a new program that is consistent with the program elements in GALL Report AMP XI.M33, "Selective Leaching of Materials." The applicant committed to implementing this program in the last 10 years of the current term, prior to the period of extended operation in the UFSAR Supplement provided as Appendix A Item A.2.1.23 of the HCGS LRA. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.23. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "leach," "iron," "copper," and "aluminum."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision f Date SH-PBD-AMP-XI.M33 Selective Leaching of Materials Revision 1 7/1412009
. CR Number 20024078 Aluminum Bronze Bolt Torque Values No Revision No.
3/22/2000 During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected. detection of aging effects. monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience identified by the staff's independent database search and supplemented by the applicant is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience identified by the staff's independent database search and supplemented by the applicant is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
- 47 The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the applicant has committed to modify the U FSAR Supplement so as to make the program description adequate.
LRA AMP B.2.1.24 Buried Piping In the HCGS LRA, the applicant states that AMP B.2.1.24, "Buried Piping Inspection," is an existing program with an enhancement that is consistent with the program elements in GALL Report AMP XI.M34, "Buried Piping and Tank Inspection." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.24. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The one enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program element by adding an explicit requirement for at least one inspection of each material type (steel, gray cast iron, and ductile cast iron piping) by either an opportunistic or focused excavation and inspection within ten years prior to entering the period of extended operation and again within the first ten years of the period of extended operation.
In A.2.1.24 of the LRA, the applicant committed to implement the enhancement within ten years prior to entering the period of extended operation and again within the first ten years of the period of extended operation.
During its audit, the staff conducted walkdowns, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "piping,"
"corrosion," "loss of material," "pitting," "steel," "iron," "underground," and "buried."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
- 48 Relevant Documents Reviewed Document Title Revision I Date CR20229886 Determine Rate of Corrosion of Pipe Revision D 3/24/2005 ER-M-5400 Buried Piping Program (BPP) Guide Revision 1 Commitment No. 80096880-2001 Not dated ER-M-5400-1002 Buried Piping Examination Guide Revision 1 Commitment No. 80096880-2002 Not dated SA-M-117 Excavation, Trenching, and Shoring Revision 1 Commitment No. 80096880-2003 Not dated CR20094719 IGSC in CCW Piping Welds No Revision No.
3/22/2002 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
- 49 LRA AMP B.2.1.25 External Surfaces Monitoring In the HCGS LRA, the applicant states that AMP B.2.1.25 "External Surfaces Monitoring," is a new program that is consistent with the program elements in GALL Report AMP XI.M36, "External Surfaces Monitoring." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.25. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "flaw," "corrosion,"
"inspection," "MIC," "loss of material," "weld," and "rust."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-Xi-M36 External Surfaces Monitoring Revision 1 7/29/2009 OU-AA-122 Qualification and Certification of Nondestructive Revision 1 Examination (NDE) Personnel Not dated ER-AA-2030 Conduct of Plant Engineering Manual Revision 7 Not dated CROOO080060430 Torus Support Column Pin and Steel Degradation No Revision No.
4/18/2003 CROOO060075899 Tank Surface Rusting/Repaint No Revision No.
3/14/2007 During the audit of program elements 1-6, the staff found that:
Elements1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP,
- 50 as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.26 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components In the HCGS LRA, the applicant states that AMP B.2.1.26, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," is a new program that is consistent with the program elements in GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.26. Program elements 7-9
{corrective actions, confirmation process, and administrative controls} are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "internal," "surface," and "corrosion."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.M3S Program Basis Document - Inspection of Intemal Surfaces in Rev 3 Miscellaneous Piping and Ducting Components 2009 ANSI N-510-19S0 Aging Assessment Field Guide Revision 0 12/2003
- 51 Document Title Revision I Date ASME N-1-2008 Testing of Nuclear Air Treatment System No Revision No.
1980 ASME NQA-1-2008 Quality Assurance Requirements for Nuclear Facility No Revision No.
Applications 2008 ASME N511-2007 In-Service Testing of Nuclear Air Treatment, Ventilation, and No Revision No.
Air-Conditioning Systems 2007 ANSI N45.45.2.6 Qualifications of Inspection, Examination and Testing No Revision No.
1978 Personnel for Nuclear Power Plants 1978 During the audit, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.27 Lubricating Oil Analysis In the HCGS LRA, the applicant states that AMP B.2.1.27, "Lube Oil Analysis," is an existing program with an exception that is consistent with the program elements in GALL Report AMP XI.M39, "Lubricating Oil Analysis Program." To verify this claim of consistency, the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions,
- 52 parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.27. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The exception affects LRA program element 3 (parameters monitored or inspected). The GALL Report AMP recommends that the flash point be determined for oil in components that do not have regular oil changes. The applicant states that the determination of flash point in lubricating oil is used to indicate the presence of highly volatile or flammable materials in a relatively nonvolatile or nonflammable material, such as found with fuel contamination in lubricating oil.
The existing Lubricating Oil Analysis program includes flash point analysis for the in-service emergency diesel generator (EDG) lubricating oil (the only potential application for the introduction of highly volatile or flammable materials) and for all new lubricating oil. The applicant further states that for the remaining components in the scope of the program, determination of flash point is not measured.
During its audit, the staff reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "oil," "pitting," "corrosion," "oxidation," "rust," "leak."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date MA-AA-716-230 Predictive Maintenance Program No Revision No.
80086881-2701 MA-AA-716-230-1001 Oil Analysis Interpretation Guideline No Revision No.
80086881-2702 MA-AA-716-230-1004 Lubricant Sampling Guideline No Revision No.
80086881-2703 MA-AA-716-006 Control of Lubricants Program Revision 5 80086881-2704 S M-AA-300-1 001 Procurement Activities and Responsibilities Revision 4 80086881-2705 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program. Aspects of program element 3 of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of these elements not associated with the exception were evaluated and are described below.
During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
- 53 During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.28 ASME Section XI IWE In the HCGS LRA, the applicant states that AMP B.2.1.28, "ASME Section XI, Subsection IWE,"
is an existing program with enhancements that are consistent with the program elements in GALL Report AMP XI,S1, "ASME Section XI, Subsection IWE." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.28. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 1 (scope of program). This enhancement expands on the existing program element by adding an internal moisture barrier at the junction of the drywell concrete floor and the steel drywell shell prior to the period of extended operation.
The second enhancement affects LRA program element 1 (scope of program). This enhancement expands on the existing program element by adding a revision to the HCGS ASME Section XI, Subsection IWE aging management program implementing documents to
- 54 require inspection of the moisture barrier for loss of sealing in accordance with IWE-2500 requirements after it is installed.
The third enhancement affects LRA program element 1 (scope of program). This enhancement expands on the existing program element by adding verification that the reactor cavity seal rupture drain lines are clear from blockage once prior to the period of extended operation and one additional time during the first 10 years of the period of extended operation.
The fourth enhancement affects LRA program element 1 (scope of program). This enhancement expands on the existing program element by adding verification that drains at the bottom of the drywell air gap are clear from blockage once prior to the period of extended operation and one additional time during the first 10 years of the period of extended operation.
The fifth enhancement affects LRA program element 1 (scope of program). This enhancement expands on the existing program element by adding investigation of the source of leakage detected by the reactor cavity seal rupture drain line instrumentation and access its impact on the drywell shell.
The sixth enhancement affects LRA program element 1 (scope of program). This enhancement expands on the existing program element by adding monitoring of the drains at the bottom of the drywell air gap for leakage in the event leakage is detected by the reactor cavity seal rupture drain line instrumentation.
In Appendix B, Subsection 8.2.1.28 ASME Section XI, Subsection IWE of the LRA, the applicant committed to implement these enhancements prior to the period of extended operation.
During its audit, the staff conducted walkdowns, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI-S 1, Aging Management Program Basis Document, ASME Section Revision 2 Books 1, 2, and 3 XI, Subsection IWE, GALL Program XI.S1 11/6/2009 SA-PBD-AMP Aging Management Program Results Document, ASME No Revision No.
B.2.1.28, Book 1 of 1 Section XI, Subsection IWE, GALL ProQram XI.S1 Not dated Notification Order New HCGS Moisture Barrier No Revision No.
70088803 Not dated Notification No. Walkdown and Evaluation for IN 2006-01 No Revision No.
20245279 Not dated Notification No. UT Examination of the Drywell Area No Revision No.
20315604 Not dated The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
- 55 During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff): and The operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff indicated that it would consider issuing two RAls for the following subjects:
Program element 10 for the HCGS ASME Section XI, Subsection IWE aging management program describes water leakage during the 2009 refueling outage from the seal rupture drain line penetration J13 sleeve which is located in the drywell air gap region. Water may be trapped between the concrete and drywell steel below the J13 penetration sleeve since it is located approximately eight feet above the dryweillower air gap drains. This could potentially corrode the drywell steel containment and impact its integrity. Therefore, the staff will consider requesting the applicant to provide plans for determining the root cause and to perform non-destructive examinations (NDE) of the drywell area below the penetration sleeve J13 to demonstrate that water is not trapped in the two inch annular space between the drywell and concrete shield wall.
Program element 10 of the HCGS ASME Section XI, Subsection IWE aging management program describes general corrosion and pitting of the torus shell and deficiencies in the interior coatings identified in 2004 by underwater inspections performed by divers as part of the IWE inspection program. However, the LRA and program basis document do not provide sufficient information for the staff to evaluate and make an assessment regarding the impact of these deficiencies. Therefore, the staff will consider requesting the applicant to provide following additional details of underwater inspections performed during 2004, including extent of degradation due to corrosion and general condition of coating applied to the inside surface of the torus.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
- 56 Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
lRA AMP B.2.1.29 ASME Section XIIWF In the HCGS LRA, the applicant states that AMP B2.1.29, "ASME Section XI, Subsection IWF,"
is an existing program that is consistent with the program elements in GALL Report AMP XI.S3, "ASME Section XI, Subsection IWF." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.29. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "IN 2009-04," "constant support," and "component support."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XLS3 Hope Creek Generating Station Units 1 and 2 and Hope Revision 2 Creek Generating Station ASME Section XI, Subsection 11/0612009 IWF HOP03.G03 HCGS lSI Program Plan Hope Creek Generating Station Revision 0 Third Interval, Not dated Notification No. Supports have medium rust Torus room No Revision No.
20141931 Not dated Notification No. Torus Support Column pin and steel degradation No Revision No.
20140321 Not dated Notification No. Piping Rupture Condenser; Order No. 70041898, No Revision No.
20207276 Confirmation #3773029 Not dated
- 57 During the audit of program elements 1-6, the staff found that:
Elements 1 through 6 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff indicated that it would consider issuing an RAI for the following subject:
GALL Program XLM18, Bolting Integrity states that Gall Program XLS3, "ASME Section XI Subsection IWF" manages inspection of safety related bolting. HCGS station document SH-PBD-AMP-XLM18 states that the Bolting Integrity AMP follows information as delineated in NUREG-1339, published EPRI NP-5769 guidelines, and industry recommendations. EPRI NP-5769, EPRI TR -104213, and NUREG -1339 recommend inspections for stress corrosion cracking (SCC) to prevent or mitigate degradation and failure of structural bolts with actual yield strength of 150,000 pounds per square inch. However, HCGS LRA Section 3.5.2 states that ASTM A490 bolts, with actual yield strength of 150,000 pounds per square inch, have high resistance to SCC due to their ductility and industry and plant specific operating experience have not identified SCC of ASTM A490 bolts as a concern. The staff will request the applicant to explain the basis for the conclusion that ASTM A490 bolts have resistance to SCC due to their ductility.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; and
- 58 Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.30 Appendix J In the HCGS LRA, the applicant states that AMP 82.1.30, "10 CFR Part 50, Appendix J," is an existing program that is consistent with the program elements in GALL Report AMP XI.S4, "10 CFR Part 50, Appendix J." To verify this claim of consistency the staff audited the LRA AMP.
This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.30. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PDB-AMP-XI.S4 10 CFR Part 50, Appendix J Revision 2 12/9/2009 Notification 20395653 Unsat. Excessive B CREF Make-up flow No Revision No.
2009 Order #70075575 R14 LLRT Exceeded 1ST LIMIT No Revision No.
04/25/2008 Order #70096871 R15 LLRT Exceeded 1ST LIMIT No Revision No.
- 04/23/2009 Order #70056408 LLRT GB-9531B1 exceeded admin. limit No Revision No.
04/16/2006 Order #70056413 ABHF-F019 Failed as Found Leak Rate Test No Revision No.
04/23/2006 Order #70096934 R15 LLRT Exceeded 1ST Limit No Revision No.
04/21/2009 Order #70075360 R14 Failed BGFT-F001 Failed as found LLRT No Revision No.
04/24/2008 NRC IN 92-20 Inadequate Local Leak Rate Testing No Revision No.
3/3/1992 During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventive action, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
- 59 During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
During the audit, the staff asked the applicant about the use of NRC Information Notice (IN) 92-20, specifically concerning the testing of two ply bellows used in the torus of BWR Mark I containments. The applicant stated that HCGS has two ply bellows and has revised the ILRT procedure to incorporate the information from IN 92-20.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 6.2.1.31 Masonry Walls In the HCGS LRA, the applicant states that AMP B.2.1.31. "Masonry Wall Program," is an existing program with enhancements that is consistent with the program elements in GALL AMP XI.S5, "Masonry Wall Program." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience). and the description as contained in the UFSAR supplement Section A,2.1.31. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 1 (scope of program). This enhancement expands on the existing program element by adding the following structures and components:
auxiliary boiler building, fire water pump house, masonry wall fire barriers, switchyard, and turbine building.
- 60 The second enhancement affects LRA program element 3 (parameters monitored or inspected).
This enhancement expands on the existing program element by adding an examination checklist for masonry wall inspection requirements.
The third enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program element by specifying an inspection frequency of not greater than five years for the masonry walls.
In A.2.1.31 of the LRA, the applicant committed to implement the enhancement prior to entering the period of extended operation.
During its audit, the staff conducted field walk downs, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords:
"concrete," "corrosion," "cracking," and "masonry."
The table below lists the documents that were reviewed by the staff and found relevant to the onsite audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date I SH-PBD-AMP-XI.S5 Masonry Wall Program, GALL PROGRAM XI.S5 Masonry Revision 2 Wall ProQram Not dated SH-PBD-AMP-XI.S6 SGS and HCGS Structures Monitoring Program No Revision No.
Not dated I ER-M-31 0-1 009 Condition Monitoring of Structures Revision 1 !
Not dated NC.DE-TS.ZZ-4302 Analysis and Design of Masonry Wails Revision 0 Not dated A-0-ZZ-SEE-1160 Establishment of Requirement for Monitoring the Condition of Revision 1 Structures Not dated HCGS UFSAR Concrete Masonry Walls Revision 15 Section 3.8.4.5.3 10/2006 The staff conducted its onsite audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff found that:
Elements 1-6 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and
- 61 The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.32 Structures Monitoring In the HCGS LRA, the applicant states that AMP B.2.1.32, "Structures Monitoring Program," is an existing program with enhancements that is consistent with the program elements in GALL AMP XI.S6, "Structures Monitoring Program." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience), and the description as contained in the UFSAR supplement Section A.2.1.32. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The enhancements affect LRA program element 1 (scope of program), program element 3 (parameters monitored or inspected), program element 4 (detection of aging effects), and program element 6 (acceptance criteria). In Appendix A of the LRA, the applicant committed to implement these enhancements prior to the period of extended operation.
The first enhancement affects LRA program element 1 (scope of program). This enhancement expands on the existing program element by adding the following structures and components:
Auxiliary boiler building; fire water pump house; shoreline protection dike and sheet piles (RG 1.127); switchyard; turbine building; transmission towers; yard structures (foundations for fire water tanks, manholes, transformer foundations credited SBO);
masonry walls, including fire barriers; building penetrations that perform flood barrier, pressure boundary, shelter and protection intended functions; miscellaneous steel (catwalks, vents, louvers, platforms, etc.); pipe whip restraints, jet impingement, and missile shields; ice barriers, trash rack (RG 1.127); panels, racks, cabinets, and other
- 62 enclosures; metal-enclosed bus; component supports including electrical cable trays, electrical conduit, tubing, HVAC ducts, instrument racks, battery racks, and supports for piping and components that are not within the scope of ASME Section XI, Subsection IWF; and duct banks that contain safety-related cables and cables credited for SBO and ATWS.
The second enhancement affects LRA program element 3 (parameters monitored or inspected).
This enhancement expands on the existing program element by including visual inspections of concrete surfaces around anchors for cracking and spalling.
The third enhancement affects LRA program element 3 (parameters monitored or inspected).
This enhancement expands on the existing program element by clarifying that inspections are performed for loss of material due to corrosion and pitting of additional steel components such as embedments, panels and enclosures, doors, siding, metal deck, and anchors.
The fourth enhancement affects LRA program element 3 (parameters monitored or inspected).
This enhancement expands on the existing program element by including a one-time inspection of the external stainless steel surfaces of the expansion bellows at condensate storage tank dike for loss of material due to corrosion, within the ten-year period prior to the period of extended operation.
The fifth enhancement affects LRA program element 3 (parameters monitored or inspected).
This enhancement expands on the existing program element by requiring inspection of penetration seals, structural seals, and elastomers for degradation (hardening, shrinkage, and loss of strength) that will lead to loss of sealing.
The sixth enhancement affects LRA program element 3 (parameters monitored or inspected).
This enhancement expands on the existing program element by requiring monitoring of vibration isolators associated with component supports other than those covered by ASME Section XI, Subsection IWF.
The seventh enhancement affects LRA program element 3 (parameters monitored or inspected). This enhancement expands on the existing program element by adding an examination checklist for masonry wall inspection requirements.
The eighth enhancement affects LRA program element 3 (parameters monitored or inspected).
This enhancement expands on the existing program element by enhancing parameters to be monitored for wooden components to include change in material properties, and loss of material due to insect damage and moisture damage.
The ninth enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program element by specifying an inspection frequency of not greater than five years for the structures including submerged portions of the service water intake structure.
The tenth enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program element by requiring individuals responsible for inspections and assessments for structures to have a Bachelors of Science degree and/or
- 63 Professional Engineer license and a minimum of four years experience working on building structures.
The eleventh enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program element by performing periodic sampling, testing, and analysis of groundwater chemistry for pH, chlorides, and sulfates on a frequency of five years.
The twelfth enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program element by requiring supplemental inspections of the affected in-scope structures within 30 days following extreme environmental or natural phenomena (large floods, significant earthquakes, hurricanes, and tornadoes).
The thirteenth enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program element by performing a chemical analysis of ground or surface water in-leakage When there is significant in-leakage or there is reason to believe that the in-leakage may be damaging concrete elements or reinforcing steel.
The fourteenth enhancement affects LRA program element 6 (acceptance criteria). This enhancement expands on the existing program element by including additional acceptance criteria as contained in ACI 349.3R-96.
During its onsite audit, the staff conducted field walk downs, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "boric acid," "concrete," "corrosion," "cracking," "masonry," and "spent fuel pooL" The table below lists the documents that were reviewed by the staff and found relevant to the on site audit These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.S6 SGS and HCGS Structures Monitoring Program Revision3 Not dated SH-PBD-AMP-XI.S5 SGS and HCGS Masonry Wall Program Revision2 Not dated SH-PBD-AMP-XI.S7 SGS and HCGS RG 1.127, Inspection of Water-Control Revision 1 Structures Associated With Nuclear Power Plants Not dated
. ER-M-310-1009 Condition Monitoring of Structures Revision 1 !
Not dated ER-M-31 0-1 004 Maintenance Rule - Perfonnance Monitoring Revision 7 I Not dated ER-M-310 Implementation of the Maintenance Rule Revision7 Not dated HC-AMRBD-MEAE Aging Management Review Basis Document for Materials, No Revision No.
Environments, and Aging Effects Not dated A-0-Z-SEE-1160 Establishment of Requirement for Monitoring the Condition of Revision 1 Structures Not dated
- 64 The staff conducted its onsite audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
During the onsite audit, the staff found that:
Elements 1, 2, 3, 5, and 6 (scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and assessment criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether element 4 (detection of aging effects) of the LRA AMP was consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element number 4 is consistent with the corresponding elements of the GALL Report AMP, the staff indicated that it would consider issuing an RAI for the following subject:
Underground reinforced concrete structures and structures in contact with raw water at HCGS are subject to an aggressive environment with chloride levels up to 15,000 ppm that exceed the GALL Report threshold limit for chlorides << 500 ppm). The applicant stated during the onsite audit that inspection of below-grade structures will be performed only when exposed during plant excavations for construction or maintenance activities.
In addition, service water intake structure will be monitored to provide a bounding condition and indicator of the likelihood of concrete degradation for inaccessible portions of concrete structures. It is not clear to the staff how the detection of aging effects will be adequately managed by the measures proposed by the applicant. Therefore, the staff plans to request the applicant to provide more details on how aging effects are detected in the inaccessible areas, since groundwater intrusion has been observed through seismic expansion joints, concrete construction joints, and expansion and shrinkage cracks in the concrete.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The HCGS structural monitoring program inspection history has revealed minor degradation of structural components, but none were significant enough to impact their intended function.
Deficiencies identified were evaluated and corrected. Baseline inspections of all structures in the scope of Maintenance Rule were completed in 1997. In 2007 condition monitoring inspections of the Reactor Building were performed and indicated satisfactory results. Some minor rust was found on the torus horizontal restraint end plates that connect to the wall and
- 65 minor rust was found on the building floor framing steel, but conditions were found to not warrant immediate repair. Leakage of water from the spent fuel pool has occurred. The water leakage is confined to the gravity drain system and occurs only when the spent fuel pool level is increased above the normal level. In October 2001, the water leakage was identified as coming from the #11 fuel pool line drain. Analysis of the water indicated fuel pool water. Subsequent investigations in 2006 indicated that as the fuel pool level was increased water began to flow from the #11 fuel pool line drain at a rate of about 46 drops per minute with a maximum flow of 54 drops per minute. No observed flow was observed at other drains. Follow-up visual inspections of the north wall of the fuel pool indicated that the wall of the fuel pool from approximately 24" to the water level was satisfactory for continued operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that with enhancements most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report; while identifying certain aspects of LRA program element 4 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 8.2.1.33, RG 1.127 In the HCGS LRA, the applicant states that AMP B2.1.33, "Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants," is an existing program with enhancement that is consistent with the program elements in GALL Report AMP XI.S7, "Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.33. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 1 (scope of program). This enhancement expands on the existing program element by adding Shoreline Protection and Dike structures.
The second enhancement affects LRA program element 3 (parameters monitored or inspected).
This enhancement expands on the existing program element by adding monitoring wooden
- 66 components to include change in material properties and loss of material due to insect damage and moisture damage.
The third enhancement affects LRA program element 4 (detection of aging effects). This enhancement expands on the existing program element by: (1) requiring that inspection for submerged concrete structural components be performed by dewatering a pump bay or by a diver if the pump bay is not dewatered; (2) specifying an inspection frequency of not greater than 5 years for in scope structures including submerged portions of the Service Water Intake Structure; and (3) requiring supplemental inspections of the in scope structures within 30 days following extreme environmental or natural phenomena (large floods, Significant earthquakes, hurricanes, and tornadoes).
In Appendix A2.1.33 of the LRA, the applicant committed to implement these enhancements prior to the period of extended operation.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant.
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date i SH-PBH-AMP-X1.S7 Regulatory Guide 1.127,lnspection of Water-Control Structures Revision 1 Associated with Nuclear Power Plants 7/16/2009 I
i ER-AA-310-1004 Maintenance Rule Revision 7 Not dated ER-AA-31 0-1 009 Condition Monitoring of Structures Revision 1 Not dated Notification Number Safety Concern-Spalled Concrete on SWIS No Revision No.
20147242 6/04/2003 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff found that:
Elements 2-6 (preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending. and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether element 1 (scope of program) of the LRA AMP is consistent with the corresponding elements of the GALL Report AMP.
In order to obtain the information necessary to verify whether the LRA program element 1 is consistent with the corresponding elements of the GALL Report AMP, the staff indicated that it would consider issuing an RAI for the following subject:
- 67 In element 1 of the Program Basis Document SH-PBD-AMP-XI.S7, the applicant states there are no HCGS water-control structures that are credited for flood protection. It is not clear that this statement is consistent with Table 2.4.9 of the LRA which indicate parts of the service water intake structure are flood barriers.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1-6 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 8.2.1.34, Protective Coatings In the Hope Creek LRA, the applicant states that AMP B.2.1.34, "Protective Coating Monitoring and Maintenance Program," is an existing program that is consistent with the program elements in GALL Report AMP XI.S8, "Protective Coating Monitoring and Maintenance Program." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.34. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience
- 68 database using the keywords: "cracking," "corrosion," "masonry," "concrete," "leach," and "coating."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date CC-HC-6006 Monitoring the Performance of Service Level I Coating No Revision No.
Systems for Hope Creek GeneratinQ Station 80096881-0601 During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending. and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
- 69 LRA AMP B.2.1.35 Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements In the HCGS LRA, the applicant states that AMP B.2.1.35, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environment Qualification Requirements," is a new program that is consistent with the program elements in GALL Report AMP XI.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environment Qualification Requirements." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.35. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "cable," "degradation,"
"oxidation," "cracking," and "thermal."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date SH-PBD-AMP-XI.E 1 Aging Management Program Basis Document Revision 1 07/30/2009 I
TR-109619 EPRI Guideline for the Management of Adverse Localized No Revision No.
Equipment Environments 06/1999 HC-PBD-AMP Hope Creek Generating Station AMP Results Book No Revision No.
B.2.1.39 Not dated During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP,
- 70 as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.36 Electrical Cables used in Instrumentation In the HCGS LRA, the applicant states that AMP B2.1.36, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits," is a new program that is consistent with the program elements in GALL Report AMP XI.E2, "Electrical Cables and Connections Not Subject to 10CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits." To verify this claim of consistency, the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.36. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted independent searches of the applicant's operating experience database using the key words: "cable," "degradation," "oxidation,"
"cracking," and "thermal."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date HC-PBD-AMP Electrical Cables and Connections Not Subject to 10 CFR No Revision No.
B.2.1.36 50.49 Environment Qualification Requirements Used in Not dated Instrumentation Circuits
- 71 Document Title Revision I Date SH-PBD-AMP-XI.E2 Electrical Cables and Connections Not Subject to 10 CFR Revision 2 Book 1 of6 50.49 Environment Qualification Requirements Used in 12/18/2009 Instrumentation Circuits SH-PBD-AMP-XI.E2 Electrical Cables and Connections Not Subject to 10 CFR Revision 2 Book 20f6 50.49 Environment Qualification Requirements Used in 12/18/2009 Instrumentation Circuits SH-PBD-AMP-XLE2 Electrical Cables and Connections Not Subject to 10 CFR Revision 2
- Book 30f6 50.49 Environment Qualification Requirements Used in 12/18/2009 i Instrumentation Circuits During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
-72 LRA AMP 8.2.1.37 Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements In the HCGS LRA, the applicant states that AMP B.2.1.37, "Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," is a new program that is consistent with the program elements in GALL Report AMP XI,E3, "Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.37. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted walkdowns, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "manhole," "duct,"
"water," "submergence," "cable," "water tree," "electrical tree," "underground," "splice," and, "vault."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Title Revision I Date l Document 1SH-PBD-AMP-XI.E3 Inaccessible Medium Voltage cables Not Subject to 10 CFR Revision 1 50.49 Environmental Qualification ReqUirements GALL Program 8/04/2009 i XI.E3 i LS-AA-115 Operating Experience Procedure Revision 11 i Not dated 12484051 Hope Creek Switching Station Power and Control Duct Plan Revision 11 2/15/1985 125697 Hope Creek Switching Station Revision 0 Station Power and Control Ducts - Profile Views 3/18/1982 1241160 Hope Creek Switching Station Revision 6 13kV Station Power Ducts - Profile View 6/7/1985 I E-1503-0 Electrical Facilities Site - Southwest Revision 13 1/25/1995 I E-1502-0 Electrical Facilities Site Southeast Revision 16 7/21/1991
- HC-PBD-AMP- Inaccessible Medium Voltage Cables Not Subject to 10 CFR No Revision No.
I B.2.1.37 50.49 Environmental Qualification Requirements GALL Not dated Prooram XI.E3 AMP Results Book LS-AA-125 Corrective Action Program (CAP) Procedure Revision 12 Not dated A-0-ZZ-EDS-0225-0 Class IE Medium Voltage Shielded Power Cable for Use At Revision 0 Hope Creek Generating Station 3/28/1991 05000354/2009004 Hope Creek Generating Station NRC Integrated Inspection No Revision No.
Report 11/12/2009
- 73 Document Title Revision I Date I Notification 20420237 SSWP Cables Submerged No Revision No.
06/15/2009 During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience identified by the staffs independent database search and supplemented by the applicant is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience identified by the staff's independent database search and supplemented by the applicant is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff indicated that it would consider issuing an RAI for the following subject:
The applicant's operating experience and staff walkdown and review of operating experience identified cases of in-scope inaccessible medium voltage cable exposure to significant moisture/cable submergence (Le., periodic exposure to moisture that lasts more than a few days). Prolonged exposure to significant moisture is inconsistent with GALL AMP XI.E3 including program elements 2, "preventive actions," and 4, "detection of aging effects." Based on operating experience, the applicant's corrective actions with respect to limiting in-scope cables exposure to significant moisture may not be inadequate.
The staff also audited the description of the LRA AMP provided in the LRA UFSAR Supplement, Section A.2.1.37. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR Supplement was an adequate description of the LRAAMP.
In order to obtain the information necessary to verify the sufficiency of the UFSAR Supplement program description, the staff indicated that it would consider issuing an RAI for the following subject:
LRA UFSAR Supplement Section A.2.1.37 does not include definitions of significant moisture or significant voltage consistent with SRP LR Table 3.6-2 or GALL Report AMP XI.E3, "Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." The lack of these definitions in combination with the applicant's objective of inspection to keep cables infrequently submerged to
- 74 minimize exposure to significant moisture may not provide consistency with GALL Report AMP XI.E3.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; and Identified a need for additional information regarding the adequacy of the program description in the UFSAR Supplement.
LRA AMP B.2.1.38 Metal Enclosed Bus In the HCGS LRA, the applicant states that AMP B.2.1.38, "Metal Enclosed Bus" is a new program that is consistent with the program elements in GALL Report AMP XI.E4, "Metal Enclosed Bus." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.38. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff conducted a walk down, interviewed the applicant's staff, observed a demonstration of the thermography camera used by the applicant, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "bus," and "corrosion."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed I Document Title Revision I Date
! SH-PBD-AMP-XI.E4 Aging Management Program Basis Document Revision 1 Not dated MA-AA-71 B-230-1 003 General Guidelines for Thermography Inspections Revision 3 Not dated HC-PBD-B.2.1.38 Aging Management Program Results Book Revision 1 Not dated
- 75 During the audit of program elements 1-6, the staff found that:
Elements 2- 6 (preventive actions, parameters monitored or inspected, detection of aging effects. monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether element 1 (scope of program) of the AMP was consistent with the corresponding element of the GALL Report; therefore, the staff requested the applicant provide a list of metal enclosed bus in the basis document. The applicant provided the staff with an itemized list of the in scope metal enclosed bus. The staff found this description to be consistent with the description provided in the GALL Report and, therefore, acceptable.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant. is sufficient to detect and manage aging effects during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, a9ceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.2.1.39 Electrical Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements In the HCGS LRA, the applicant states that AMP B.2.1.39, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification ReqUirements," is a new program with an exception that is consistent with the program elements in GALL Report AMP XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements."
To verify this claim of consistency the staff audited the LRA AMP. This audit report considers
-76 program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.2.1.39. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. This audit report does not consider the sufficiency of exceptions. Issues identified but not resolved in this report are addressed in the SER.
The one exception affects LRA program element 1 (scope of program), element 3 (parameters monitored or inspected), element 4 (detection of aging effects), and element 5 (monitoring and trending.) The applicant stated that the exception to GALL Report AMP XI.E6 is based on draft interim staff guidance LR-ISG-2007-02 issued for public comment September 7,2007.
Subsequent to the applicant's LRA, the staff issued LR-ISG-2007-02 for staff and public use on December 23, 2009 (74 FR 68287). Therefore, the staff review of LRA AMP B2.1.39 is based on the guidance provided by LR-ISG-2007-02 and GALL Report AMP XI.E3.
During its audit, the staff conducted walkdowns, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "cable,"
"connection," "bolt," "loose," "electrical," "corrosion," "termination," "resistance," "generic letters,"
"bulletins," "regulatory issue summaries," "licensee event reports," "event notifications,"
"inspection findings," "inspection reports," and "thermography."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision I Date NUREG 1801 Generic Lessons Leamed (GALL) Report Chapter X, "Time-Limited VoL 2, Aging Analysis Evaluation of Aging Management Programs Under Revision 1 10 CFR 54.21 (c)(1)(iii): AMP X.E1, "Environmental Qualification of 9/2005 Electric Components."
MA-AA-716-230-1003 Thermography Program Guide Revision 3 Not dated LR-ISG-2007-02 Changes to Generic Aging Lessons Learned (GALL) Report Aging No Revision No.
i Management Program (AMP) XLE6, "Electrical Cable Connections 12/23/2009
- Not Subject to 10CFR 50.49 Environmental Qualification Requirements' HC-SSBD-E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Revision A Draft Environmental Qualification Requirements Sample Basis Document Not dated SH-PBD-AMP-XLE6 Program Basis Document - Electrical Cable Connections Not Revision 1 Subject to 10 CFR 50.49 Environmental Qualification Requirements 7/30/2010 GALL ProQram XLE6
- HC-PBD-AMP- Electrical Cable Connections Not Subject to 10 CFR 50.49 No Revision No.
B.2.1.39 Environmental Qualification Requirements - GALL Program XI.E6 Not dated AMP Results Book LS-AA-125 Corrective Action Program (CAP) Procedure Revision: 12 Not dated The staff conducted its audit of LRA program elements 1-6 based on the contents of the new program. Aspects of program element 1 (scope of program), element 3 (parameters monitored
- 77 or inspected), element 4 (detection of aging effects), and element 5 (monitoring and trending), of the LRA AMP which are associated with the exceptions were not evaluated during this audit.
Aspects of these program elements that are not associated with the exceptions were evaluated and are described below.
During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff indicated that it would consider issuing an RAI for the following subject:
The operating experience examples referenced by the applicant in LRA Section B.2.1.39 conclude that the effects of aging and aging mechanisms are being adequately managed. The applicant stated that these examples provide objective evidence that the aging management program, acceptance criterion, and the corrective action process will be effective in resolving problems prior to loss of function. However, it is not clear based on the applicant's discussion that the included examples are representative of operating experience in that the search methodology and criteria are not discussed. (For example, operating databases searched, connection types, time frame, and connection stressors including application, loading and enVironment).
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in SRP-LR Table 3.6-2 as modified by ISG-ISG-2007-02 and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant to detect and manage aging, can be reached; and
- 78 Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP B.3.1.1 Metal Fatigue of Reactor Coolant Pressure Boundary In the HCGS LRA, the applicant states that AMP B3.1.1, "Metal Fatigue of Reactor Coolant Pressure Boundary," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP X.M1, "Metal Fatigue of Reactor Coolant Pressure Boundary." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.3.1.1. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
The first enhancement affects LRA program element 3 (parameters monitored or inspected).
This enhancement expands on the existing program element to include additional transients beyond those defined in the Technical Specifications and the UFSAR, and expanding the fatigue monitoring program to encompass other components identified to have fatigue as an analyzed aging effect, which require monitoring.
The second enhancement affects LRA program elements 1,2,3,5, and 6 (scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria). This enhancement expands on the existing program element to use software program to automatically count transients and calculate cumulative usage on select components.
The third enhancement affects LRA program elements 2, 3, 5, and 6 (preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria). This enhancement expands on the existing program element to address the effects of the reactor coolant environment on component fatigue life by assessing the impact of the reactor coolant environment on a sample of critical components for the plant identified in NUREG/CR-6260.
In Appendix A, Section A.5 of the LRA, the applicant committed to implement these enhancements prior to the period of extended operation.
During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "fatigue," "cooling," and "steam generator."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.
- 79 Relevant Documents Reviewed Document Title Revision I Date HC-PBD-AMP-X.M1 Program Basis Document, Metal Fatigue of Reactor Coolant Revision 2 Pressure Boundary 12/14/2009 HC.MD-ST.KJ-0001(Q) Diesel Generator Technical Specification Surveillance and Revision 39 l 000020157696 Preventive Maintenance PM Notification 41112002 No Revision No.
91412003
- 000020285565 PM Notification No Revision No.
512312006 VTD 320114 Vendor Technical Document Revision 3 61412007 HC-34Q-301 Analysis for Hope Creek Core Spray Nozzle Revision 0 512912007 I 0800118.323 Benchmark Calculation for the Hope Creek FatiguePro Revision 1 Stress-Based Fatigue Locations 12/3/2009 0800118.302 60 Year Plant Cycle Duty Projection Revision 2 10/13/2009 0800118.307 Environmental Fatigue Evaluation of Selected NUREG/CR Revision 2 6260 Components Based on Existing Analyses 10/30/2009 0800118.310 ASME Code Confirmatory Fatigue Evaluation of Reactor Revision 2 Core Spray Nozzles (N5A and N5B) 10130/2009 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.
During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff);
and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
Several instances of operating experience not in the LRA were discussed with members of the applicant's engineering staff. This included examples of applicable industry experience review (ref. 3 and 5 in the above table) and revision on the reactor vessel fatigue analysis due to increase in the high pressure coolant injection (HPCI) injections beyond the design cycle assumption (ref. 4 and 6 in the above table).
- 80 The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.
LRA AMP 8.3.1.2 EQ Electrical In the HCGS LRA, the applicant states that AMP B.3.1.2, "Environmental Qualification (EQ) of Electrical Components," is an existing program that is consistent with the program elements in GALL Report AMP X.E1, "Environmental Qualification (EQ) of Electric Components." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) and program element 10 (operating experience) and the description of the program as contained in the UFSAR Supplement Section A.3.1.2. Program elements 7-9 (corrective actions, confirmation process, and administrative controls) are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER.
During its audit, the staff interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "EQ," "qualification,"
"environmental," "electrical," "cable," component," "connection," and "termination."
The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.
Relevant Documents Reviewed Document Title Revision 1 Date NUREG 1801 Generic Lessons Learned (GALL) Report Chapter X, "Time- Vol. 2, Limited Aging Analysis Evaluation of Aging Management Revision 1 Programs Under 10 CFR 54.21(c)(1)(iii)," AMP X.E1, 09/2005 "Environmental Qualification of Electric Components."
Regulatory Guide Environmental Qualification of Certain Electric Equipment Revision 1 1.89 Important to Safety for Nuclear Power Plants 11/20/2008 SH-PBD-AMP-X.E1 Program Basis Document Revision 1 Environmental Qualification (EQ) of Electrical Components 08/07/2009
- 81 Document Title Revision I Date i NC.DE-PS.ZZ Programmatic Standard - Environmental Qualification Program Revision 1 0002(Q) Salem and Hope Creek Generating Stations 06/2412004 I
! HC-PBD-AMP Environmental Qualification (EQ) of Electric Components GALL No Revision No.
B.3.1.2 Program X.E1 AMP Results Book Not dated N/A Quarter 4tn Year 2009 - Station Hope Creek No Revision No.
Performance Health Report - Performance Indicators Not dated LS-AA-115 Operating Experience Procedure Revision: 11 Not dated During the audit of program elements 1-6, the staff found that:
Elements 1-6 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.
During the audit of program element 10 (operating experience), the staff found that:
The operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff); and The operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.
Applicant operating experience reviewed included quarterly EO program health reports dating from 2006 through 2009. EO self assessments dated 7/5/1999. 12127/2002 and 12/23/2003, basis document operating experience including work orders, corrective actions. EO program updates and improvements including benchmarking. An independent review of the applicant's operating experience database was also performed by the staff.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.
Based on this audit the staff:
Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant. is sufficient to detect and manage; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.