IR 05000266/2010011

IR 05000266-10-011; NextEra Energy Point Beach, LLC; 08/09/10 - 08/26/10; Point Beach Nuclear Plant (Pbnp), Unit 1; Post-Approval Site Inspection for License Renewal Inspection Report

ML102850469
Person / Time
Site:	Point Beach
Issue date:	10/08/2010
From:	Ann Marie Stone NRC/RGN-III/DRS/EB2
To:	Meyer L Point Beach
References
IR-10-011
Download: ML102850469 (46)

Text

UNITED STATES tober 8, 2010

SUBJECT:

POINT BEACH NUCLEAR PLANT, UNIT 1 NRC POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL INSPECTION REPORT 05000266/2010-011

Dear Mr. Meyer:

On August 26, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed a Post-Approval Site Inspection for License Renewal at your Point Beach Nuclear Plant, Unit 1. The enclosed report documents the results of this inspection, which were discussed on August 26, 2010, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The team concluded that commitments were properly identified, implemented, and completed.

On the basis of the sample selected for review and in consultation with the Division of License Renewal in the Office of Nuclear Reactor Regulation, the NRC concludes the licensee has completed the necessary commitments for operation into the period of extended operation.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-266; License Nos. DPR-24;

Enclosure:

Inspection Report 05000266/2010-011 w/Attachment: Supplemental Information

REGION III==

Docket No: 05000266 License No: DPR-24 Report No: 05000266/2010-011 Licensee: NextEra Energy Point Beach, LLC Facility: Point Beach Nuclear Plant, Unit 1 Location: Two Rivers, WI Dates: August 9, 2010 - August 26, 2010 Inspectors: Stuart Sheldon, Senior Reactor Engineer (Lead)

Tom Bilik, Senior Reactor Engineer James Neurauter, Senior Reactor Engineer Gerard ODwyer, Reactor Engineer Shavon Edmonds, Reactor Engineer Approved by: Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000266/2010-011; 08/09/10 - 08/26/10; Point Beach Nuclear Plant (PBNP), Unit 1; Post-Approval Site Inspection for License Renewal The report covers a team inspection conducted by region-based engineering inspectors. The inspectors concluded that commitments, license conditions, and regulatory requirements associated with the issuance of the renewed operating license were being met. The NRCs program for overseeing the Safe Operation of Commercial Nuclear Power Reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings No violations of significance were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

4OA5 Other Activities

.1 Post-Approval Site Inspection for License Renewal (Phase 2) - IP 71003

a. Inspection Scope

(1) Review of Newly Identified Structures, Systems, and Components (SSCs)

The inspectors discussed the identification of newly identified SSCs, under the purview of 10 CFR 54.37(b), with the licensees license renewal staff. The licensees 10 CFR 54.37(b) report dated July 19, 2010, identified 188 newly identified SSCs.

Most of the items had been in the plant but were not in the equipment database used for the license renewal application. All but one item were already managed by an existing Aging Management Program. This one item, wood within the new fuel storage racks, was not being managed and has since been incorporated into the structures monitoring program. The list of newly identified SSCs is scheduled to be incorporated into the next Final Safety Analysis Report (FSAR) update and tracked by Action Request (AR) 01113848 to be submitted in March 2011. The inspectors did not identify any deficiencies.

(2) Review of FSAR and Commitment Change Process As part of reviewing the Aging Management Programs (AMPs) associated with the commitments, the inspectors reviewed the FSAR descriptions to confirm the implemented programs were consistent with the FSAR descriptions. The inspectors noted that FSAR Section 15.4.1, Reactor Vessel Irradiation Embrittlement Time Limited Aging Analysis (TLAA), stated in the subsection on Reactor Vessel Pressurized Thermal Shock that the Master Curve Methodology showed that the Reactor Pressure Vessel (RPV) limiting weld metal meets Pressurized Thermal Shock (PTS) screening criteria out to End of Extended Life and beyond. The inspectors questioned the appropriateness of these FSAR statements since the Master Curve Methodology had not been approved by the NRC for use on either unit of PBNP. On August 12, 2010, the licensee initiated AR 1178961 to analyze the statements. The AR generated an FSAR change request to remove the statements from the FSAR. This request was implemented and on August 25, 2010, the inspectors noted that the statements had been removed from the FSAR.

The inspectors reviewed the licensees procedures to ensure that commitment revisions would follow the guidance in NEI 99-04, Guidelines for Managing NRC Commitment Changes, including the elimination of commitments, and would properly evaluate, approve, and report changes to license renewal commitments listed in the FSAR in accordance with 10 CFR 50.59. The inspectors reviewed each change associated with a commitment as noted in the next section. No disparities were identified with respect to implementation.

The inspectors also reviewed the licensees commitment tracking program to evaluate its effectiveness. Overall the commitment tracking process was effective with the notable exception of Commitment 8, which is discussed in the following section.

(3) Review of Commitments The inspectors reviewed supporting documents including completed surveillance records, conducted interviews, and observed the activities described below to verity the licensee completed the necessary actions to comply with the license conditions that are a part of the renewed operating license. The inspectors verified the licensee implemented the Aging Management Programs and time-limited aging analyses (TLAA)included in NUREG-1839, Safety Evaluation Report (SER) Related to the License Renewal of the Point Beach Nuclear Plant Units 1 and 2, in accordance with Title 10 of the Code of Federal Regulations (CFR) Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants. The inspectors verified a selected sample of corrective actions taken as a consequence of the license renewal inspection.

When changes to these commitments were identified, the inspectors reviewed the Commitment Change Evaluation (CCE) to verify the licensee followed the guidance in NEI 99-04 for the license renewal commitment change process, including the elimination of commitments, and properly evaluated, reported, and approved where necessary, changes to license renewal commitments listed in the FSAR in accordance with 10 CFR 50.59.

The inspectors reviewed the commitments listed below which are referenced to Appendix A of the SER. As noted in a letter from the Executive Director for Operations to the Advisory Committee on Reactor Safeguards, dated December 21, 2005, (ML053420198), Region III considered expanding the scope of this inspection to include all commitments. All Commitment Items were selected except Items 40, 41, 43, 44, 49, 54, and 61, which were reported as complete in the SER and therefore, not reviewed.

Specific documents reviewed are listed in the enclosure.

1. Item 1, License Renewal Flags Commitment Item 1 specified that the licensee would develop and implement an AMP that would apply license renewal flags to each component that will be maintained as part of the equipment information database in the Passport system prior to period of extended operation.

The inspectors reviewed the licensing basis, program basis document, scheduled, and completed work orders, and implementing procedures. The inspectors verified that the licensee has developed and implemented a program to assign license renewal classification information to all systems, structures, and components evaluated under license renewal. The inspectors have also verified that license renewal flags will be maintained in accordance with the current licensing basis throughout the period of extended operation.

The inspectors also verified that a representative sample of components contained the correct classification codes under the license renewal process. The inspectors identified that the licensee miscoded a vent piping component in the equipment database. The licensee entered this issue into their corrective action as AR1178778 and performed an extent of condition evaluation to determine if other piping assets were miscoded. The licensee found an additional 24 piping assets that were miscoded due to individuals manually transferring component codes into the equipment database. The inspectors determined that this issue was minor because the components had already been properly evaluated for aging management.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 1.

2. Item 2, RI-ISI Program Inspections of Piping Welds Less than 4-Inch NPS

Commitment Item 2 specified that the RI-ISI Program inspections of piping welds less than 4-inch NPS will include volumetric examinations for non-socket welds and surface examinations for socket welds. The Program requires volumetric examination of non-socket welds and surface examination of socket welds until a meaningful volumetric inspection technique is created for the geometry presented by socket welds, in a sample of susceptible risk significant small bore (< 4 inch) ASME Class 1 and 2 piping.

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, non-destructive examination (NDE) records, and related condition reports (CRs); and interviewed the plant personnel responsible for this program. The inspectors verified that the inspection requirements are incorporated in the ISI program and station procedures.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 2.

3. Items 3, 32, 42, 57, and 69, Structures Monitoring Program

Commitment Item 3 specified that all concrete/grout at PBNP within the scope of license renewal will be managed for aging.

Commitment Item 32 specified the licensee implement an enhanced Structures Monitoring Program prior to the period of extended operation.

Commitment Item 42 specified that the Structures Monitoring Program will be enhanced to conduct and document a structural condition survey of the reactor vessel sump area.

Commitment Item 57 specified that enhancements will be made to the Structures Monitoring Program to include the primary shield and reactor vessel support areas.

Commitment Item 69 specified that that the Structures Monitoring Program will examine below-grade concrete when it is exposed by excavation for signs of degradation from aggressive chemical attack or corrosion of embedded steel, during the period of extended operation. Periodic monitoring of ground water chemistry (pH, chlorides, sulfates) will continue to be performed during the period of extended operation to ensure the environment remains non-aggressive. The frequency of monitoring ground water chemistry (pH, chlorides, sulfates) will be at least once every 5 years.

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, scheduled and completed work orders, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program enhancement and program commitments specified in the SER were incorporated into implementing plant procedures.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Items 3, 32, 42, 57, and 69.

4. Item 4, Continued Monitoring and Participation in Industry Initiatives with Regard to

Baffle/Former and Barrel/Former Bolt Performance Commitment Item 4 specified that the licensee continue to monitor and participate in industry initiatives with regard to baffle/former and barrel/former bolt performance to support aging management for the Unit 1 bolting.

The inspectors reviewed the implementing procedures, and interviewed the plant personnel responsible for this program. The inspectors verified that the licensee is continuing to participate in industry activities. The licensee is actively engaged in the Pressurized Water Reactor (PWR) Reactor Internals Inspection and Evaluation Guideline development as part of the Materials Reliability Project (MRP-227).

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 4.

5. Item 5, Continued Participation in Industry Investigations of Aging Effects Applicable

to Reactor Vessel Internals Commitment Item 5 specified that the licensee continue to participate in industry investigations of aging effects applicable to reactor vessel internals. Aging management activities or surveillance techniques resulting from these initiatives will be incorporated, as required, as enhancements to the Reactor Vessel Internals Program.

The inspectors reviewed the implementing procedures, and interviewed the plant personnel responsible for this program. The inspectors verified that the licensee is continuing to participate in industry activities.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 5.

6. Item 6, Void Swelling in the Reactor Internals Program

Commitment Item 6 specified that the licensee incorporate applicable results of industry initiatives related to void swelling in the Reactor Vessel Internals Program.

The inspectors reviewed the related procedures, related ARs; and interviewed the plant personnel responsible for this program. The inspectors verified that the licensee is continuing to participate in industry activities and remain cognizant of industry initiatives related as they relate to void swelling.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 6.

7. Item 7, Leak Before Break (LBB)

Commitment Item 7 specified that plant process control procedures (design control, repair/replacement, and welding) will be revised to ensure that repair or replacement of Class 1 piping components within the scope of LBB analysis for welded connections or Cast Austenitic Stainless Steel (CASS) would require a new LBB analysis based on replacement process and/or material properties.

The licensee implemented a commitment change to reflect that welding procedure revisions were not pursued. Instead, LBB ramifications have been addressed in the Section XI, Repair and Replacement section of the Engineering Design Input Checklist (QF-0515A) by noting that the repair and replacement process must be used prior to welding, grinding, or modifying LBB piping. This is equivalent to revising each of the welding procedures.

The inspectors reviewed the licensing basis, program basis document, commitment change evaluations, implementing procedures, related ARs, and interviewed the plant personnel responsible for this program. The inspectors verified that the program enhancement was incorporated into implementing plant procedures.

As a result of inspectors review, the licensee implemented a change to the above commitment change to reflect that plant process control plant procedures (design control, repair/replacement, and indication) will be revised to ensure that repair or replacement of Class 1 piping components within the scope of LBB analysis for welded connections or CASS would require a new LBB analysis based on replacement process and/or material properties. The licensee initiated and inspectors reviewed CCE 2010-007, Commitment Change Evaluation, dated August 20, 2010, and AR 01179491, PCR 1175267 Not Issued, Conflicts with CCE 2010-003, dated August 20, 2010. The inspectors determined this change to the original commitment change was minor.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 7.

8. Item 8, Material Reliability Project (MRP) for Reactor Vessel Internals (RVI)

Commitment Item 8 specified that the licensee will implement the NRC-approved industry activities resulting from the MRP, as appropriate, to manage any applicable aging effects identified through the Electric Power Research Institute (EPRI) MRP effort.

This commitment could not yet be completed as the NRC has not approved EPRI MRP-227. The licensee had closed tracking on this commitment with their submission of a Reactor Vessel Internals Program for NRC review under Commitment Item 29. After discussion with the inspectors, the licensee submitted a letter, NRC 2010-0135, to clarify that this commitment had not been completed, consolidating it with Commitment Item 29, and changing the due date to within 180 days following approval of the program by the NRC. This performance deficiency is considered minor as the licensee had in place other open CAP documents to track incorporation of the NRC approved guidance.

Based on the above, the inspectors concluded the licensee initiated appropriate actions to address Commitment Item 8.

9. Item 9, Program Designated Bolting

Commitment Item 9 specified that the Periodic Surveillance and Preventive Maintenance (PSPM) Program would be used to replace a program for managing the periodic replacement of Unit 1 steam generator inspection port bolts.

The inspectors reviewed the licensing basis, PSPM Program documentation and verified that periodic maintenance tasks were in place with the appropriate frequency to meet the fatigue life limits of the Unit 1 steam generator inspection port bolts.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 9.

10. Items 10, 11, 12, 30, and 46, Reactor Vessel Surveillance Program.

Commitment Item 30 specified that the licensee would implement an enhanced Reactor Vessel Surveillance Program for Unit 1 prior to period of extended operation.

Commitment Item 10 specified that the licensee would directly validate the integrity of the RPV with the testing of the capsule installed on Unit 2 in 2002 when neutron fluence level calculations require.

Commitment Item 11 specified that during the period of extended operation, reactor vessel surveillance capsules will be removed in accordance with the schedule contained in the most recently NRC-approved Pressurized Water Reactor Owners Group (PWROG) Master Integrated Reactor Vessel Surveillance Program (MIRVP) document.

Commitment 11 had originally stated: Capsule A2 (Unit 1) will be removed at a target end of extended life fluence of 3.7 x 10E19 n/cm2. Commitment Item 11 was changed to the present wording by Next Era letter 2010-004 sent to the NRC on January 19, 2010.

Commitment Item 12 specified that the licensee would revise the upper shelf energy evaluation prior to the period of extended operation.

Commitment 46 specified that the licensee would continue during the period of extended operation to implement the low-low leakage loading fuel management pattern to minimize the limiting weld fluence and continue operation with Hafnium absorber assemblies in service until the resolution of the Unit 2 intermediate-to-lower shell girth weld PTS issue via an alternative analysis methodology. Only the continued low-low leakage loading fuel management pattern implementation was applicable to Unit 1. The continued operation with Hafnium absorber assemblies commitment was only applicable to Unit 2 and therefore implementation was not verified during this inspection.

The NRC SER (NUREG 1839) stated in Section 3.0.3.2.17 that the PBNP Reactor Vessel Surveillance Program was approved based, in part, on participation in and data from the PWROG MIRVP which is also known as the MIRVSP. The MlRVP is a program designed to provide the data required to monitor the neutron embrittlement of the reactor vessel beltline region of 16 reactor vessels fabricated by Babcock and Wilcox. The licensee participates in the MIRVP.

The inspectors noted that FSAR Section 15.4.1, Reactor Vessel Irradiation Embrittlement TLAA, stated in the subsection on Reactor Vessel Pressurized Thermal Shock that the Master Curve Methodology showed that the RPV limiting weld metal meets PTS screening criteria out to end of extended life and beyond. The inspectors questioned the appropriateness of these FSAR statements since the Master Curve Methodology had not been approved by the NRC for use on either unit of PBNP. On August 12, 2010, the licensee initiated AR 1178961 to analyze the statements. The AR generated an FSAR change request to remove the statements from the FSAR. This request was implemented and on August 25, 2010, the inspectors noted that the statements had been removed from the FSAR.

The inspectors noted that Technical Requirements Manual (TRM) Section 2.2, Subsection 3, RV Material Surveillance Program, seemed to indicate that only one capsule would be removed in accordance with the most recently NRC-approved PWROG MIRVSP document. The inspectors questioned why the instruction did not seem to apply to the other capsules. The licensee initiated AR 1178836 and AR 1179086 which directed that TRM 2.2, Table 2 be clarified to ensure that all capsule removal schedules would be referenced to the most recently NRC-approved PWROG MIRVSP document.

The inspectors interviewed licensee personnel and reviewed the licensing basis, program basis document, planned and completed work orders, corrective action program documents, PWROG MIRVP documentation, and implementing procedures.

The inspectors verified that the program and program enhancements required for license renewal commitments were in place for Unit 1. The inspectors verified that implementing procedures and program documents directed that the RPV integrity would be directly validated and all reactor vessel surveillance capsules will be removed in accordance with the most recently NRC-approved Pressurized Water Reactor Owners Group (PWROG) Master Integrated Reactor Vessel Surveillance Program (MIRVP)documents during the period of extended operation. The inspectors verified that the licensee revised the upper shelf energy evaluation prior to the period of extended operation. The inspectors verified that implementing procedures and program documents directed that the low-low leakage loading fuel management pattern will be continued to be implemented for Unit 1 during the period of extended operation.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Items 10, 11, 11, 30 and 46 for Unit 1.

11. Item 13, ASME Section XI, Subsections IWB, IWC, and IWD Inservice Inspection Program Commitment Item 13 specified that the licensee would implement an enhanced ASME Section XI, Subsections IWB, IWC, and IWD Inservice Inspection Program prior to the period of extended operation.

Enhancements to the ASME Section XI, Subsections IWB, IWC, and IWD Inservice Inspection Program include revisions to existing activities credited for license renewal to ensure that inspections for the applicable aging effects are performed and any noted indications are appropriately evaluated. Additionally, applicable process control documents were to be revised to ensure that new LBB analyses are performed following use of the Section XI flaw evaluation option or repair/replacement of Class 1 welds and CASS within the scope of the LBB analysis.

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, non-destructive examination records, and related condition reports; and interviewed the plant personnel responsible for this program. The inspectors verified that the program and enhancements were in place involving revisions to existing activities credited for license renewal, to ensure that inspections for the applicable aging effects are performed and any noted indications are appropriately evaluated.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 13.

12. Item 14, ASME Section XI, Subsections IWE and IWL Inservice Inspection Program Commitment Item 14 specified that the existing ASME Section XI, Subsections IWE and IWL Inservice Inspection Program would be enhanced prior to the period of extended operation, which included modifications to procedures for air lock door inspections.

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, examination records, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program enhancements were in place.

The inspectors also reviewed documentation related to cancellation of the pre-stressed concrete containment tendon Aging Management Program for license renewal, LR-AMP-031-TENDON. The TLAA resolution for loss of preload as applicable to containment tendon loss of pre-stress analysis was resolved in accordance with 10 CFR 54.21(c)(1)(ii). The inspectors interviewed the responsible ISI plant personnel to verify an assessment of the results of the tendon pre-stressing force measurements are performed in accordance with ASME Section XI, Subsection IWL. The inspectors verified that this change was appropriate.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 14.

13. Item 15, ASME Section XI, Subsections IWF Inservice Inspection Program Commitment Item 15 specified that the licensee would implement an enhanced ASME Section XI, Subsection IWF Inservice Inspection Program. Enhancements to the ASME Section XI, Subsection IWF Inservice Inspection Program include revising existing implementing documents to include cracks as recordable conditions for component supports.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, examination records, and related ARs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program and program enhancements were in place.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 15.

14. Items 16, 60, Bolting Integrity Program Commitment Item 16 specified that the licensee implement an enhanced bolting integrity program prior to the period of extended operation. Commitment Item 60 specified four specific Bolting Integrity Program enhancements.

The Bolting Integrity Program credits seven separate AMPs for PBNP license renewal.

The seven AMPs are:

(1) ASME Section XI, Subsections IWB, IWC, and IWD Inservice Inspection program;

(2) ASME Section XI, Subsections IWE and IWL Inservice Inspection Program;

(3) ASME Section XI, Subsection IWF Inservice Inspection Program;

(4) Systems Monitoring Program,

(5) Structures Monitoring Program,

(6) Reactor Vessel Internals Program; and

(7) periodic surveillance and preventive maintenance program. The aging effects/mechanisms managed by and the AMR reports that credit the Bolting Integrity Program.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, scheduled and completed work orders, completed receipt inspections, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program enhancement and specific program commitments were incorporated into implementing plant procedures.

Based on review of the timeliness and adequacy of the licensees actions the inspectors determined that the licensee met Commitment Items 16 and 60.

15. Items 17 and 65, Boraflex Monitoring Program Commitment Item 17 specifies that the licensee implement an enhanced Boraflex Monitoring Program prior to the period of extended operation. Commitment Item 65 specified five specific Boraflex Monitoring Program enhancements.

Through License Amendment Request Number 247, initiated July 24, 2008, the licensee implemented a Commitment Item change to reflect that Boraflex was no longer credited for spent fuel pool storage criticality control.

On March 5, 2010, the NRC issued Point Beach Nuclear Plant Amendment No. 236 to DPR-24 (Unit 1) and Amendment No. 240 to DPR-27 (Unit 2) that reflected Boraflex was no longer credited for spent fuel pool storage criticality control.

The inspectors reviewed the licensing basis correspondence, associated license amendments, and the associated NRC safety evaluation. The inspectors confirmed that Boraflex was no longer credited for spent fuel pool storage criticality control, and the Boraflex Monitoring Aging Management Program was discontinued.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee discontinued Commitment Items 17 and 65.

16. Item 18, Boric Acid Corrosion Program Commitment Item 18 specified that the licensee would implement an enhanced Boric Acid Corrosion Program prior to the period of extended operation.

The inspectors reviewed the licensing basis, implementing procedures, work orders, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program and program enhancements for inspecting components upon which boric acid may have leaked, were in place.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 18.

17. Items 19 and 58, Buried Services Monitoring Program Commitment Item 19 specified that the licensee develop and implement a Buried Services Monitoring Program prior to the period of extended operation. Commitment Item 58 specified that a susceptible location in the fire protection system (i.e.,

uncoated/unwrapped piping) will be scheduled to be inspected once prior to the period of extended operation and at least every 10 years during the period of extended operation.

Based upon findings from these fire protection system inspections, additional inspection locations could include coated and/or uncoated buried piping in the fire protection system, service water system and fuel oil system.

The licensee implemented a commitment change to Commitment Item 58 to reflect that a susceptible location in the fire protection system (i.e., coated or uncoated/unwrapped piping) will be scheduled to be inspected once prior to the period of extended operation and at least every 10 years during the period of extended operation. Based upon findings from these fire protection system inspections, additional inspection locations could include coated and/or uncoated buried piping in the fire protection system, service water system and fuel oil system. The reason to include coated piping in the population of susceptible piping to be inspected prior to the period of extended operation is to include the piping installed during original construction. The only uncoated piping was installed within the past eight years. Therefore, the uncoated piping has only a limited time in the ground and therefore would not exhibit any aging of note.

The inspectors reviewed the licensing basis, program basis document, commitment change evaluation, implementing procedures, scheduled and completed work orders, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program and the additional program commitment were incorporated into implementing plant procedures.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Items 19 and 58.

18. Item 20 and 55, Cable Condition Monitoring Program Commitment Item 20 specified that the licensee provide a new Cable Condition Monitoring Program in accordance with NUREG-1801,Section XI.E1, Electrical Cables And Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements, and accordance with, but includes exceptions to, Sections XI.E2, Electrical Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, and XI.E3, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements.

Commitment Item 55 specified that a representative sample of in-scope, inaccessible non-EQ medium-voltage cables not designed for submergence subject to significant moisture and significant voltage will be tested prior to the end of the current license period and once every ten years during the period of extended license as part of the Cable Condition Monitoring Program.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, inspection results, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that visual inspections of a representative sample of accessible electrical cables and connections in adverse localized environments, testing of nuclear instrumentation circuits and testing of a representative sample of in-scope, medium-voltage cables not designed for submergence had been completed and scheduled in the Periodic Maintenance Program.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Items 20 and 55.

19. Item 21, Closed-Cycle Cooling Water System Surveillance Program Commitment Item 21 specified that the licensee would implement an enhanced Closed-Cycle Cooling Water System Surveillance Program prior to period of extended operation.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, water chemistry controls, and related Corrective Action Program documents; and interviewed the plant personnel responsible for this program. The inspectors verified that the program and program enhancements were in place for: (1)maintenance of system corrosion inhibitor concentrations to minimize degradation; (2)periodic or one-time surveillance testing and inspections to evaluate system and component performance; and

(3) inspection methods include visual testing, ultrasonic testing, and eddy current testing.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 21.

20. Item 22, Fire Protection Commitment Item 22 specified the licensee would implement an enhanced Fire Protection prior to the period of extended operation. Enhancements to the Fire Protection Program included revisions to various implementing documents to add specific inspections, and monitoring and trending requirements. The inspectors verified that new implementing documents were established to implement inspections of selected components and of the fire suppression piping.

The inspectors reviewed the licensing basis, program basis document, and existing implementing procedures. The inspectors verified that the above enhancements were incorporated into the existing program documents and implementing procedures. The inspectors specifically verified that procedures LR-AMP-010-FP and 0PT-FP-004 contained the appropriate procedural steps needed to implement the enhancements of the program.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 22.

21. Item 23, Flow Accelerated Corrosion (FAC)

Commitment Item 23 specified that the licensee would implement an enhanced Flow-Accelerated Corrosion Program prior to the period of extended operation.

Enhancements included revisions to plant procedures and to add specific components to the scope of the program, ensure congruence with the guidelines of NSAC-202L-R3, and provide better references to the input data sets. Enhancements also included clarification of the program requirements for SG nozzles and reducers, and more stringent controls placed on program basis documents and software.

The program implements the EPRI guidelines in NSAC-202L-R3 for an effective FAC Program and includes:

(a) an analysis using a predictive code such as CHECWORKSTM to determine critical locations;

(b) baseline inspections to determine the extent of thinning at these locations;

(c) follow-up inspections to confirm the predictions; and

(d) repairing or replacing components, as necessary.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, and related ARs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program and program enhancements were in place.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 23.

22. Item 24, Fuel Oil Chemistry Control Program Commitment Item 24 specified that the licensee would implement an enhanced Fuel Oil Chemistry Control Program prior to the period of extended operation.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, chemistry results, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program and program enhancements for draining water from diesel fuel tanks and periodically taking ultrasonic measurements of day tanks were in place. Additionally, the licensee implemented a commitment change to replace stability testing with particulate testing for microbiological activity.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 24.

23. Items 25, 45, and 59, One-Time Inspection Program Commitment Item 25 specified that the licensee would develop and implement a One-Time Inspection Program prior to the period of extended operation. Commitment 45 specified that the licensee would incorporate one-time visual inspection and hardness measurements for selective leaching prior to the period of extended operation.

Commitment 58 specified that the licensee would conduct eddy current inspections under the One-Time Inspection Program of the tubing of one Residual Heat Removal (RHR) heat exchanger prior to the period of extended operation. The One-Time Inspection Program provides for examinations of representative materials in environments that are not expected to experience aging effects in order to verify that this is the case.

The inspectors reviewed the licensing basis, program basis document, sampling methodology, completed work orders, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that selective leaching inspections and eddy current testing of the 1A RHR heat exchanger had been incorporated in the program and completed.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Items 25, 45 and 59.

24. Item 26, Open-Cycle Cooling Water System Surveillance Program Commitment 26 specified that the licensee would implement an enhanced Open-Cycle Cooling Water System Surveillance Program prior to period of extended operation.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, water chemistry and bio-fouling controls, and related Corrective Action Program documents; and interviewed the plant personnel responsible for this program.

The inspectors reviewed the regular maintenance activities that had been approved as an alternative to periodic heat transfer verification testing for each of the heat exchangers identified in the exception. The inspectors verified that the program and program enhancements were in place to ensure:

(1) surveillance and control of biofouling;

(2) periodic and one-time surveillance testing and inspections to evaluate system and component performance;

(3) inspection methods include heat transfer testing, visual testing, ultrasonic testing, and eddy current testing; and

(4) routine inspection and Maintenance Program activities to ensure that aging effects do not impair component intended function. The inspectors verified that the testing and maintenance activities appropriately implemented the actions.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 26.

25. Items 27, 56 and 64 Periodic Surveillance and Preventive Maintenance Program Commitment Item 27 specified that the licensee would implement an enhanced Periodic Surveillance and Preventive Maintenance Program prior to the period of extended operation. Commitment Item 56 specified that the licensee periodically conduct visual inspections of the bus ducts to inspect for signs of insulation cracking, corrosion, debris, excessive dust buildup, evidence of moisture and water intrusion, or discoloration of insulation as part of the Periodic Surveillance and Preventive Maintenance Program.

Commitment Item 64 specified that as part of the Periodic Surveillance and Preventive Maintenance Program, records of deferrals, cancellations, and frequency changes for call-ups credited for license renewal as aging management or replacement activities will be retained in an auditable and retrievable form.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, a sample of various periodic maintenance requests, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program and program enhancements to incorporate inspections required for license renewal commitments were in place. The inspectors verified that bus duct inspections had been performed and periodic tasks were in place for future inspections.

The licensee also demonstrated that an electronic report was in place that provided documentation of deferrals, cancellations, and frequency changes for call-ups credited for license renewal.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Items 27, 56 and 64.

26. Items 28, 52, and 53, Reactor Coolant System Alloy 600 Inspection Program Commitment Item 28 specified that the licensee would develop and implement a Reactor Coolant System Alloy 600 Inspection Program prior to the period of extended operation.

This commitment was to be met by developing a Reactor Coolant System Alloy 600 Inspection Program based on Section XI.M11, Nickel-Alloy Nozzles and Penetrations.

Of NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," dated April 2001.

Enhancements to the Reactor Coolant System Alloy 600 Inspection Program include:

incorporation of acceptance criteria for RPV head visual inspections, development of new implementing documents to meet the commitments made in response to NRC Bulletin 2002-02, NRC Bulletin 2003-02 and the requirements of NRC Order EA-03-009, and the performance of susceptibility assessments and development of corrective action plans and /or inspections for nickel-based components and welds not addressed under the evaluations performed for reactor vessel head penetrations.

Commitment 52 states that the licensee will use the interim report "PWR Materials Reliability Project Interim Alloy 600 Safety Assessment for US PWR Plants (MRP-44),

Part 1: Alloy 82/182 Pipe Butt Welds," and its final version as part of the basis for the Reactor Coolant System Alloy 600 Inspection Program.

Commitment 53 states that the licensee will submit the Reactor Coolant System Alloy 600 Inspection Program 24 - 36 months prior to the period of extended operation for staff review and approval to determine if the program demonstrates the ability to manage the effects of aging per 10 CFR 54.21 (a)(3).

The licensee submitted the Reactor Coolant System Alloy 600 Inspection Program on October 6, 2008 for staff review and approval to determine if the program demonstrates the ability to manage the effects of aging per 10 CFR 54.21 (a)(3).

The inspectors reviewed the licensing basis, program basis document, implementing procedures, and related ARs; and interviewed the plant personnel responsible for this program. The inspectors verified that the submitted program met the requirements in these commitments.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Items 28, 52 and 53.

27. Item 29. Reactor Vessel Internals Program Commitment Item 29 originally specified that the licensee would implement an enhanced Reactor Vessel Internals Program prior to the period of extended operation.

This commitment was revised to specify that the licensee would implement an enhanced Reactor Vessel Internals Program 180 days following the review and approval of the program by the NRC (See NRC 2010-0068, dated April 23, 2010). It will be a Reactor Vessel Internals Program that conforms to the provisions of the NRC SE that will be issued upon completion of its review. NRC approval is contingent upon approval of EPRI MRP-227. AM 3-44 will be revised as appropriate based upon the contents of the NRC SEs issued as a result of the review and approval of EPRI MRP-227 and subsequently, AM 3-44.

The Reactor Vessel Internals Program is an existing program based on EPRI MRP-227.

Enhancements to the Reactor Vessel Internals Program include determination and implementation of augmented inspection requirements necessary to ensure that the RVI components will maintain the capability to perform their intended functions during the period of extended operation.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, and related ARs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program meets current industry guidance and tracking is in place for incorporating any changes resulting from NRC review of the industry guidance.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 29.

28. Items 31, 50, and 68, Steam Generator Integrity Program Commitment Item 31 specified that the licensee implement an enhanced Steam Generator Integrity Program prior to the period of extended operation.

Commitment Item 50 specified that as part of the Steam Generator Integrity Program, visual inspections of accessible areas to verify the integrity of steam generator secondary-side components will be performed at least every six years, with one steam generator being inspected every three years on an alternating basis. Any indications of degradation or unacceptable conditions will be evaluated through the Corrective Action Program, including the extent of condition.

The licensee implemented a commitment change to Commitment Item 50 to reflect that steam generator secondary side inspections revised to every six effective full power years.

Commitment Item 68 specified that the licensee will age-manage the steam generator feed-rings, J-nozzles, and feed-ring supports using the Water Chemistry Control Program and the Steam Generator Integrity Program.

The inspectors reviewed the licensing basis, program basis document, commitment change evaluations, implementing procedures, scheduled and completed work orders, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program enhancement and program commitments were incorporated into implementing plant procedures.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Items 31, 50 and 68.

29. Items 33 and 62, System Monitoring Program Commitment Item 33 specified that the licensee would implement an enhanced Systems Monitoring Program prior to the period of extended operation. Commitment Item 62 specified that all systems within the scope of license renewal containing components requiring an aging management review and that credit the Systems Monitoring Program for managing the effects of aging on the external surfaces of the components will be walked down at a minimum frequency of once per operating cycle, within the limits of accessibility. It also specified specific enhancements for supervisory review and evaluation.

The inspectors reviewed the licensing basis, the System Monitoring Program basis documentation, implementing procedures, planned and completed work orders, related corrective action documents, and interviewed the plant personnel responsible for this program. The inspectors verified that the licensee conducted periodic inspections of the fire protection system and the service water system, and that the licensee had enhanced the program as specified in the SER. The inspectors verified that supervisors of each system would perform a review and document the results to ensure that the accessible portions of each system are walked down at a minimum frequency of once per operating cycle.

The inspectors verified that the licensee evaluated inaccessible areas of various systems to ensure that walked down contain the same material(s) and the same or more severe environment(s) as those portions that are considered inaccessible. The inspectors also verified that the system engineers had the appropriate qualifications to perform walk-downs, and that operating experience is used appropriately per procedure.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Items 33 and 62.

30. Item 34, Tank Internal Inspection Program Commitment Item 34 specified that the licensee would develop and implement a Tank Internal Inspection Program prior to the period of extended operation.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, inspection results, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program and program enhancements for increased sampling to verify corrective actions were in place.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 34.

31. Item 35. Thimble Tube Inspection Commitment Item 35 specified that the licensee would implement an enhanced Thimble Tube Inspection Program prior to the period of extended operation. Enhancements to the Thimble Tube Inspection Program include correcting program deficiencies concerning inspection deferrals, calculation methodology, and document retention. This program requires periodic eddy current testing of thimble tubes and contains criteria for determining sample size, inspection frequency, flaw evaluation, and corrective action, in accordance with NRC Bulletin 88-09.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, and related ARs; and interviewed the plant personnel responsible for this program. The inspectors verified that program and associated enhancements were in place.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 35.

32. Item 36, Water Chemistry Control Program Commitment Item 36 specified that the licensee would implement an enhanced Water Chemistry Control Program prior to the period of extended operation.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, chemistry results, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that program enhancements for increased sampling to verify corrective actions were in place. Additionally, the licensee implemented a commitment change to incorporate requirements from the latest EPRI TR 1014986, PWR Primary Water Chemistry Guidelines, Revision 6, and EPRI TR 1016555, PWR Secondary Water Chemistry Guidelines, Revision 7. No issues of significance were identified; however, as a result of inspector questions, the licensee initiated procedure change requests to clarify references to these guidelines.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 36.

33. Item 37, Environmental Qualifications Commitment Item 37 specified that the licensee would implement an enhanced Environmental Qualifications (EQ) Program prior to the period of extended operation.

The enhancements to the EQ Program included new procedures, operating experience, and reorganization of activities.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, assessments, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors also reviewed the self-assessment report completed in 2006 and 2010, and the corrective actions resulting from the assessment.

The inspectors verified that program implementing documents contain the appropriate License Renewal references. The inspectors verified that the licensee has conducted an assessment of all EQ components which include field verification and completion of EQ checklists reviews, which evaluates operating experience.

Based on the review of the timeliness and adequacy of the licensees actions and assessment for the program, the inspectors determined that the licensee met Commitment Item 37.

34. Item 38, Fatigue Monitoring Program Commitment Item 38 specified that the licensee implement an enhanced Fatigue Monitoring Program prior to the period of extended operation.

The inspectors reviewed the licensing basis, the program basis document, implementing procedures, program health report, and related CRs; and interviewed the plant personnel responsible for this program. The inspectors verified that the program enhancements were incorporated into the implementing plant procedure.

The inspectors also reviewed the licensees evaluation of external operating experience related to Regulatory Issue Summary 2008-30, Fatigue Analysis of Nuclear Power Plant Components, dated December 16, 2008, including the confirmatory analyses performed to demonstrate that the fatigue cumulative usage factor, calculated using six components of the stress tensor in accordance with Subsection NB of the ASME code, was less than one for plant operation through the period of extended operation.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 38.

35. Item 39, Submit a Reactor Vessel Internals Program Commitment Item 39 stated that a reactor vessel internals program would be submitted to the NRC for review and two years prior to entering into the period of extended operation.

A commitment change per letter NRC 2008-0067 dated August 29, 2008, changed the date to one year prior to commencement of renewed operation as the industry reviews of EPRI MRP topical report had not been completed. Commitment Item 39 was completed by submittal of the program via letter NRC 2009-0095.

The inspectors reviewed program basis document, implementing procedures, and related ARs; and interviewed the plant personnel responsible for this program.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 39.

36. Item 47, Not applicable to Unit 1; therefore, not further verified during this inspection.

37. Item 48, Not applicable to Unit 1; therefore, not further verified during this inspection.

38. Item 51, Monitoring Industry Activities for Small-Bore Piping Commitment Item 51 specified that the licensee would monitor on-going industry activities related to failure mechanisms for small-bore piping, and will evaluate changes to the licensees inspection activities based on industry recommendations. The ISI Program Coordinator is required by NP 7.4.13 to monitor on-going industry activities related to small-bore piping. This is done primarily through licensee personnel memberships in various industry working groups and committees, where relevant information is then communicated to the ISI Program Coordinator.

The inspectors reviewed the program basis documents, implementing procedures and related ARs; and interviewed the plant personnel responsible for this program to verify this information.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 51.

39. Item 63, Flow-Accelerated Corrosion Program Wall Thicknesses Commitment Item 63 specified that if degradation is detected by the Flow-Accelerated Corrosion Program such that wall thickness is less than or equal to 87.5 percent of nominal wall thickness for safety related piping additional examinations will be performed in adjacent areas to bound the thinning. For both safety-related and nonsafety-related piping, additional examinations will be performed in adjacent areas to bound the thinning if the remaining service life, based on the code minimum allowable wall thickness, is less than one operating cycle. The sample size will also be expanded for nonsafety-related piping if degradation is detected such that the wall thickness is less than or equal to 60 percent of nominal wall thickness. This covers situations where the code minimum allowable wall thickness may be less than 60 percent of nominal wall thickness for nonsafety-related piping.

The inspectors reviewed the licensing basis, program basis document, implementing procedures, and related ARs; and interviewed the plant personnel responsible for this program. The inspectors verified that this requirement had been incorporated into the Flow Accelerated Corrosion Program.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 63.

40. Item 66, Code Case N-616 Commitment Item 66 specified that as a part of the ASME Section XI, Subsections IWB, IWC, and IWD Inservice Inspection Program, the requirements of Code Case N-616 will be supplemented by a VT-2 visual examination performed each outage for Class 1 systems and each inspection period for Class 2 and 3 systems with the insulation removed from the bolted connections. The connections are not pressurized during these examinations.

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, and related condition reports (CRs); and interviewed the plant personnel responsible for this program and verified that this requirement had been incorporated.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 66.

41. Item 67, Cast Austenitic Stainless Steel (CASS) Primary Loop Elbows Commitment Item 67 states that the licensee will use enhanced volumetric examination to detect and size cracks or a plant- or component-specific flaw tolerance evaluation to demonstrate that CASS primary loop elbows potentially susceptible to thermal embrittlement have adequate fracture toughness.

The inspectors reviewed documentation, including the flaw tolerance evaluation, and interviewed the plant personnel responsible for this program.

The reactor coolant loop A374 TP316 piping material is not CASS material and therefore not susceptible to thermal aging, but some of the A351 CF8M piping elbow material is susceptible due to the -ferrite content level. An evaluation was performed which demonstrated that even with thermal aging in the susceptible reactor coolant loop CASS piping material for Point Beach Units I and 2, the susceptible piping locations have been shown to be tolerant of large flaws. The evaluation is documented in Westinghouse LTR-PAFM-05-058, Flaw Tolerance Evaluation for Susceptible CASS Reactor Coolant Piping Components in Point Beach Units 1 and 2.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 67.

42. Item 70, Program Revisions for Selective Leaching Commitment Item 70 specified that following aging management programs will be revised to credit the One-Time Inspection Program to identify selective leaching of susceptible components:

• Open-Cycle Cooling (Service) Water System Surveillance Program

• Fire Protection Program

• Systems Monitoring Program

• Periodic Surveillance and Preventive Maintenance Program

• Structures Monitoring Program The inspectors reviewed the program basis documents, and verified that these programs had been appropriately revised.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 70.

43. Item 71, Evaluation, Repair or Replacement of ASME Section XI, Subsections IWE and IWL Commitment Item 71 specified that an evaluation, repair, or replacement requirement discussion will be included in the Acceptance Criteria element of the ASME Section XI, Subsections IWE and IWL lnservice Inspection Program of the LRA prior to the period of extended operation. If localized area thickness of the containment liner base metal is reduced by 50 percent or more of the nominal plate thickness, then every attempt should be made to correct by repair or replacement. If the repair or replacement option is impractical, an acceptance by engineering evaluation option may be pursued.

The inspectors reviewed the program basis document, implementing procedures, and related ARs; and interviewed the plant personnel responsible for this program. The inspectors verified that this requirement has been incorporated in the program.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 71.

44. Item 72, Localized Area Thickness Reductions of 50 percent or Greater Commitment Item 72 specified that if localized area thickness of the base metal is reduced by approximately 50 percent or more of the nominal plate thickness, then the re-examinations required by IWE 2420(b) will be continued in the succeeding inspection periods and the provisions of IWE-2420(c) will not be applied.

IWE-2420

(c) states that when the reexaminations required by IWE-2420(b) reveal that the flaws or areas of degradation or areas subjected to a repair replacement activity, remain essentially unchanged for three consecutive inspection periods, these areas no longer require augmented examination.

The inspectors reviewed the program basis document, implementing procedures, examination records and related ARs; and interviewed the plant personnel responsible for this program. The inspectors verified that this requirement has been incorporated in the program.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined that the licensee met Commitment Item 72.

b. Findings and Observations

No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On August 26, 2010, the inspectors presented the inspection results to the Site Vice-President, Mr. L. Meyer and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

L. Meyer, Site Vice President

T. A. Vehec, Plant General Manager

G. E. Vickery, Work Management Director

R. A. Bardo, Program Engineer

T. Branam, System Engineer

S. P. Brown, Program Engineering Manager

F. A. Flentje, Licensing Supervisor

S. Forsha, Program Engineer

W. B. Fromm, Licensing Project Manager

J. Golding, System Engineer

W. J. Hennessy, Licensing Project Manager

W. J. Herrman, Licensing

S. D. Kahl, Design Engineer

J. Keltner, System Engineering Supervisor

K. Koeppel, Program Engineer

R. Leider, Program Engineer

J. Loor, Design Engineer

T. D. Mielke, License Renewal Engineer

C. Mott, Chemistry Supervisor

R. Richards, Chemistry

B. Scherwinski, Licensing

E. A. Schmidt, Acting Program Engineering Supervisor

A. Watry, Program Engineer

LIST OF ITEMS

Opened, Closed, and Discussed

None Attachment