ML11122A014

Audit Report Regarding the Davis-Besse Nuclear Power Station License Renewal Application

ML11122A014
Person / Time
Site:	Davis Besse
Issue date:	06/01/2011
From:	Harris B License Renewal Projects Branch 1
To:	Allen B FirstEnergy Nuclear Operating Co
Harris, B K
References
TAC ME4640
Download: ML11122A014 (93)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20555-0001 June 1.2011 Mr. Barry S. Allen Vice President, Davis-Besse Nuclear Power Station FirstEnergy Nuclear Operating Company 5501 North State Route 2 Oak Harbor. OH 43449

SUBJECT:

AUDIT REPORT REGARDING THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640)

Dear Mr. Allen:

By letter dated August 27, 2010, FirstEnergy Nuclear Operating Company (FENOC), 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-3 for the Davis-Besse Nuclear Power Station (DBNPS).

On February 25, 2011, the staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) completed the onsite audit of aging management programs. The audit report is enclosed.

If you have any questions, please contact me by telephone at 301-415-2277 or bye-mail at brian. harris2@nrc.gov.

/1 Sincerely.

Brian K. Harris, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

As stated cc w/encl: Listserv

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket No: 050-00346 License No: NPF-3 Licensee: FirstEnergy Nuclear Operating Company Facility: Davis-Besse Nuclear Power Station Location: 5501 North State Route 2 Oak Harbor, OH 43449 Dates: February 14-25, 2011 Reviewers: B. Harris, Project Manager, Division of License Renewal (DLR)

R. Auluck, Branch Chief, DLR D. Pelton, Branch Chief, DLR A. Buford, Structural Engineer, DLR M. Homiack, Mechanical Engineer, DLR B. Lehman, Structural Engineer, DLR D. Brittner, Mechanical Engineer, DLR A. Istar, Structural Engineer, DLR A. Sheikh, Structural Engineer, DLR C. Doutt, Sr. Electrical Engineer, DLR R. Kalikian, Mechanical Engineer, DLR D. Nguyen, Electrical Engineer, DLR J. Wise, Mechanical Engineer, DLR R. Li, Electrical Engineer, DLR C. Hunt, Mechanical Engineer, Division of Component Integrity (DCI)

A. Obodoako, Mechanical Engineer, DCI Y. Pan, Consultant, Southwest Research Institute (SWRI)

K. Axler, Consultant (SWRI)

T. Mintz, Consultant (SWRI)

L. Howard, Consultant (SWRI)

E. Trillo, Consultant (SWRI)

L. Miller, Consultant (SWRI)

D. Naus, Consultant (Oak Ridge National Lab)

Y. Garud, Consultant (Argonne National Lab)

Approved By: Rajender C. Auluck, Chief Aging Management of Structures, Electrical, and Systems Branch Division of License Renewal David L. Pelton, Chief Aging Management of Plants Systems Branch Division of License Renewal Antonio F. Dias, Chief Aging Management of Reactor Systems and Guidance Update Branch Division of License Renewal

Introduction A 10-day audit was conducted by the U.S. Nuclear Regulatory Commission (NRC) at the Davis-Besse Nuclear Power Station (DBNPS), (the plant) in Oak Harbor, OH on February 14-25, 2011. The purpose of this audit was to examine the FirstEnergy Operating Company (the applicant) aging management programs (AMPs) and related documentation for DBNPS and to verify the applicant's claim of consistency with the corresponding Generic Aging Lessons Learned (GALL) Report (NUREG-1801, Rev. 1) AMPs. As described in the GALL Report, the NRC staff's (or the staff) evaluation of the adequacy of each generic AMP is based on its review of the following 10 program elements in each AMP: 1) scope of program;

2) preventative actions; 3) parameters monitored or inspected; 4) detection of aging effects;

5) monitoring and trending; 6) acceptance criteria; 7) corrective actions; 8) confirmation process;

9) administrative controls; and 10) operating experience.

Exceptions to the GALL AMP elements will be evaluated separately as part of the staff's review of the DBNPS license renewal application (LRA) and documented in the staff's Safety Evaluation Report.

The Standard Review Plan (SRP) for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800, Rev. 1) provides the staff guidance for reviewing a LRA. The SRP allows an applicant to reference in its LRA, the AMPs described in the GALL Report. By referencing the GALL AMPs, the applicant concludes that its AMPs correspond to those AMPs which are reviewed and approved in the GALL Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL Report program. The applicant's determination should be documented in an auditable form and maintained onsite.

During this audit, the staff audited AMP elements 1-6, & 10 (scope of program, preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and operating experience). These elements of the applicant's AMPs were claimed to be consistent with the GALL Report and were audited against the related elements of the associated AMP described in the GALL Report, unless otherwise indicated in this audit report. Elements 7-9 (corrective actions, confirmation process, and administrative controls),

were audited during the Scoping and Screening Methodology audit conducted on January 24-28, 2011, and are evaluated separately. The staff audited all AMPs that the applicant stated were consistent with the GALL Report AMPs.

During this audit, if an applicant took credit for a program in the GALL Report, the staff verified that the plant program contains all the elements of the referenced GALL Report program. In addition, the staff verified the conditions at the plant were bounded by the conditions for which the GALL Report program was evaluated.

In performing this audit, the staff examined the applicant's LRA, program bases documents and related references, interviewed various applicant representatives, and conducted walkdowns of several plant areas. In total, 34 AMPs were reviewed and 32 breakout (discussion) sessions with applicant representatives were conducted. This report documents the staff's activities during this audit.

ENCLOSURE

-2 Existing Program consistent with GALL LRA AMP B.2.1, 10 CFR Part 50, Appendix J In the LRA, the applicant states that AMP XI.S4, "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 and 10 and the description of the program as contained in the FSAR Supplement. Program elements 7-9 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 walkdown, 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:

"containment," "corrosion," "concrete," "degradation," "loss of material," "inspect," 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 I

Revision I Document Title I Date

• 1. Program Basis Davis-Besse 10 CFR Part 50, Appendix J Revision 01 I Document Program Basis Document I 2. Testing

• Containment Leakage Rate Testing Program Revision 07 I Program 11/30/2010

~Administrative DB-PF-00205 "Containment Leakage Test Revision 05 Prqgram Program" .11/15/2010

4. Nuclear NOP-ER-200B "Appendix J Testing Program" Revision 00 I

• operation 12/16/200B i Procedure

.. - ..

15. Acceptance DB-PF-10310 "Containment Integrated Leakage Revision 06 Test Procedure Rate Test" 05/30/200B I 6. Surveillance DB-PF-03009 "Containment Vessel and Revision 06

• Test Procedure Shielding~lJildir1g Visual Inspection" 03/04/2009

7. Surveillance DB-PF-0300B "Containment Local Leak Rate Revision 15 i Test Procedure Test" 01/11/2011 B. Condition CR-04-03022 "The U.S. Nuclear Regulatory Revision NIA Report Commission has issued an Information Notice 04/29/2004

• (IN) 2004-09, stating " ... occurrences of

.. . .

i corrosion In freestanding metalliC containments

• "

- 3 Relevant Documents Reviewed (cont'd)

Revision I Document Title Date

9. Condition CR-02-02528 "During a walkdown by the NRC Revision N/A Report Region III Inspector of the Containment Vessel - 06/11/2002 steel interface with the lower containment elevations has "pulled-back" from the concrete and permitted corrosion to occur in the gap.

This was not identified during the inspections on containment (1) Why was the containment Vessel to concrete interface not included as a target or inspection area in the Extent of Condition Area. (2) What is the effect of the corrosion on the integrity of the containment

• vessel? I I 10. Condition CR-08-32643 "P101 Module PAP3F exceeds  ! Revision N/A

• Report LLRT leakage criteria."

• 01/05/2008

11. Condition

• CR-08-33392 "DR2012 (pen #13) failed its as Revision N/A

. Report

• found local leak rate test." 01/14/2008

12. Condition CR-08-46289 "D-B Engineering Programs had Revision N/A Report yellow cornerstones identified in their 2nd 09/15/2008 Ouarter 2008 Program Health Report - i Appendix J program personnel, backup owner 1 named but not qualified.

• 13. Condition CR-09-52244 "Yellow Cornerstone for D-B Revision N/A I Report Appendix J Program 4th Ouarter 2008 Program Health Report."

01/20/2009

• 14. Program Program Health Reports:

i Health Reports 2007 - 03,04 2008 - 01,02,03,04 2009 - 01,02,03

• 15. Nuclear FENOC Program Health Report Program Revision 06 Operating 02/26/2010 Business Practice 116. BECHTEL BN-TOP-1 "Testing Criteria for IRL T of Primary Revision 01

• Topical Report Containment Structures for NPP" 11/01/1972 I 17. Operating NOP-ER-2008 "Appendix J Testing Program" Revision 00 i Procedure 12/16/2008

18. Surveillance Surveillance Order: 200144128 by using

• Start:

Test procedure OP-PF-3009 "Containment Vessel 10/25/2007 and Shielding Building Visual Inspection" End:

01/24/2008

19. Drawing Containment Vessel Plan & Section Revision 07 01/09/2004

~---------~.-~----------------------------------~~

- 4 During the audit of program elements 1-6, the staff found that:

Elements 1-6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the 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 objective of the 10 CFR Part 50, Appendix J Program is to provide assurance that leakage from the containment structure will not exceed the maximum allowable containment leakage rates. The applicant established the maximum allowable containment leakage rates, La, at Pa (38 psig) as 0.75La for Type A Test, and 0.60La for Type Band C Tests. The regulatory basis for the Davis-Besse Nuclear Power Station Appendix J Program includes 10 CFR Part 50, a

Appendix J Option B, and NEI 94-01, Rev. (Industry Guidance for Implementing Performance Based Option of 10 CFR Part 50, Appendix J). During the audit, the applicant provided the staff with the most recent Containment Leak Rate Testing Program, Rev. 07, document. The last two Type A, Integrated Leak Rate Tests results were 0.0127 wt. %/day and 0.1671 wt. %/day performed on May 5, 2000, (12RFO), and April 8, 2003, (13RFO), respectively. The measured leak rates are well below the acceptance criteria of 0.75La (0.375 wt. %/day). It was demonstrated that the two consecutive periodic Type A Tests had acceptable performance history. Therefore, Type A Test frequency was extended to at least once per 10 years per the optional performance-based requirements of Option B to 10 CFR Part 50, Appendix J.

In order to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the following subject:

Provide qualifications of the personnel performing the visual examinations of the exterior surface of steel containment, and both sides of the shield building to be consistent with the recommendations in element 5 "degradation of aging effects" of GALL AMP XI.S4.

The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Based on this audit the staff:

Verified that LRA program elements 1-6 are consistent with corresponding program elements in the GALL Report AMP; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and

- 5 Verified that the description provided in the FSAR Supplement is an adequate description of the program.

Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP 8.2.2, Aboveground Steel Tanks Inspection In the LRA, the applicant states that AMP B.2.2, "Aboveground Steel Tanks Inspection Program," is an existing program with an enhancement 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 and 10, and the description of the program as contained in the USAR Supplement. Program elements 7-9 are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report will be addressed in the SER.

The proposed enhancement to the program affects LRA program elements 1, 3, 4, 5, and 6.

This enhancement expands on the existing program element by adding a volumetric examination of tank bottom to detect evidence of loss of material due to crevice, general, or pitting corrosion, or to confirm a lack of aging effects. This enhancement will include establishing the examination technique, the inspection locations, and the acceptance criteria.

Unacceptable inspection results will be entered into the corrective action program.

In Table A-1 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 staff also conducted an independent search of the applicant's operating experience database using the keywords: "steel," "tank,"

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 staffs search of the applicant's operating experience database.

Relevant Documents Reviewed Revision /

Document Title Date I

1. LRPD-05 Aging Management Program Evaluation Results Revision 1 i

. Attachment 2.1 for Aboveground Steel Tanks Il'lspection 8/19/2010 I.

I 2. CR-08-39295 Minor Paint Blemishes on Fire Water Storage No Revision i Tank Exterior 4/28/2008 I 3. CR-04-04158 FWST Corrosion Indications Found No Revision 6/23/2004 I 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.

-6 During the audit, the staff found that:

Elements 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; Sufficient information was not available to determine whether elements 1, 2, and 4 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program element numbers 1, 2, and 4 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In element 1 of the LRA AMP, the stainless steel borated water storage tank is not included. The staff noted that LRA Table 3.2.2-4, row number 117 states that for stainless steel borated water storage tank exposed to air-outdoor (external) there is no aging effect and no AMP is proposed. The AMP walkdown revealed that the tank is coated with insulation material. In element 1 of the GALL Report AMP it states that the program includes periodic inspections of steel tanks to manage the effects of corrosion on the intended function of these tanks. Given that stainless steel can crack when exposed to the air-outdoor environment or chlorides leached from the insulation, it is not clear to the staff why the stainless steel borated water storage tank is not included in the scope of this AMP.

In element 2 of the LRA AMP, it does not state that sealant or caulking was utilized at the external interface between the tank and concrete or earthen foundation for in-scope tanks. In the GALL Report AMP it states that sealant or caulking at the external interface between the tank and concrete or earthen foundation mitigates corrosion of the bottom surface of the tank by minimizing the amount of water and moisture penetrating the interface, which would lead to corrosion of the bottom surface. It is not clear to the staff that these statements are consistent because the LRA does not state whether the fire water storage tank, diesel fuel oil storage tank, and borated water storage tank have sealant or caulking installed at the external interface between the tank and concrete or earthen foundation. It is also not clear to the staff how the applicant effectively manages aging of the bottom surface of the tanks if sealant or caulking was not installed at the base.

In element 4 of the LRA AMP it states that volumetric examination of the tank bottoms will be conducted prior to the period of extended operation and that the frequency of tank bottom volumetric inspections will be based on the findings of the inspection performed prior to the period of extended operation. It is the current staff position that potential corrosion of tank bottoms is determined by conducting ultrasonic testing thickness measurements of the tank bottoms whenever the tank is drained and at least once within five years of entering the period of extended operation. It is not clear to the staff that these statements are consistent because it is not clear what minimum number of tank bottom thickness measurements will be conducted during the period of extended operation.

-7 During the audit of program element 10, 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 will consider issuing an RAI for the following subject:

In element 10 of the LRA AM P it states that an inspection of the exterior of the diesel oil storage tank in 2002 revealed rust and corrosion at the base flange of the tank and corroded bolts at the lower access plate at the base of the tank. It is not clear to the staff how this plant-specific operating experience was used to inform how aging will be managed during the period of extended operation because the LRA does not state the cause of the corrosion.

The staff also audited the description of the LRA AMP provided in the USAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the USAR Supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the USAR Supplement program description, the staff will consider issuing an RAI for the following subject:

The staff noted that the USAR Supplement does not reflect the fact that in-scope tank bottom thickness measurements will be performed whenever the tanks are drained and at least once within five years of entering the period of extended operation.

Based on this audit the staff:

Verified that LRA program elements 3, 5, and 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1, 2, and 4 for which additional information or additional evaluation is required before consistency can be determined; Identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; Identified the need for additional information regarding the adequacy of the program description in the USAR Supplement.

-8 Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP B.2.4, Bolting Integrity Program In the LRA, the applicant states that AMP B.2.4, "Bolting Integrity Program," is an existing program with exceptions that is consistent with the program elements in GALL Report AMP XI.M18, "Bolting Integrity." To verify this claim of consistency the staff audited the LRA AMP.

This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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 elements 1 and 2. In the GALL Report AMP, these program elements rely on industry recommendations as well as those described in NUREG-1339 "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants," Electric Power Research Institute (EPRI) NP-5769, "Degradation and Failure of Bolting in Nuclear Power Plants," and EPRI TR-104213, "Bolted Joint Maintenance and Application Guide." The industry's technical basis for the program for safety-related bolting and guidelines for material selection and testing, bolting preload control, lSI, plant operation and maintenance, and evaluation of the structural integrity of bolted joints are outlined in EPRI NP-5769, with the exceptions noted in NUREG-1339. Alternatively, this program element in the LRA states that the Bolting Integrity Program does not explicitly address the guidelines outlined in EPRI NP-5769 or those further delineated in NUREG-1339. However, the applicant's Bolting Integrity Program does rely on the recommendations of the manufacturer, the vendor and the industry in general, as contained in EPRI documents TR-104213 and TR-111471.

The second exception affects LRA program element 5. In the GALL Report AMP, this program element recommends weekly or biweekly follow up inspections of bolted connections that are reported to be leaking. Alternatively, this program element in the LRA states that periodic inspection is performed through the External Surfaces Monitoring Program or Structures program rather than the weekly or biweekly follow up inspections as recommended in the GALL Report. Leaks that are conditions adverse to quality (challenge to a system or component function) are entered into the FENOC Corrective Action Program, which is relied upon to ensure evaluations are performed and appropriate corrective actions are applied. Depending on the magnitude and significance of the leak, corrective actions may include periodic monitoring and trending of leakage. Leaks that do not constitute a condition adverse to quality are documented and entered into the Work Management Process. Operators performing daily rounds, maintenance personnel in the plant, system engineers performing walkdowns and other personnel passing through accessible plant areas provide additional resources to identity leaks that could result in a challenge to system or component intended functions. The applicant further states that their operating experience has not shown a need for a preset inspection frequency (daily, weekly and biweekly) applicable to all cases involving bolting of pressure-retaining components.

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: "bolting," "joints," and "nut."

-9 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 Revision I Document Title Date

1. LRPD-05, i Aging Management Program Evaluation Results Revision 1 Attachment 2.3 09/2010

2. DB-MM-09266

• Torquing Plant Procedure

,

Revision 8 12/14/2007

3. C-ME-099.99 Generic Minimum Thread Engagement Revision 0 009

• 11/29/2001 I

'4. LRPD-04 Operating Experience Review Results and Revision 2 Summary, Section 3.3.8 8/23/2010 I

5. DB-MS-01007 Erection and Bolting of Structural Steel Revision 0  !

1/22/1993

6. M-453-Q Design Specification for Operational Phase for Revision 6 the Installation of ASME Section III 10/31/2008

7. C-403Q Design Specification for Operational Phase for Revision 2 i

Erecting Structural Steel and Miscellaneous 11/23/1981 Metal for the Toledo Edison Company for DB Nuclear Power Station Unit 1

8. CR-06-00059 Broken Bolt on EDG #2 No Revision

01/10/2006

9. CR-07-15024 Explosion Release Fastener Broken on Blowout No Revision Panel 7A. #4 Mechanical Penetration Room #

2/22/2007

10. CR-05-00743 Corroded 1 Broken Anchor Bolt in Hanger No Revision

1/25/2005

11. CR-06-00135 Containment Spray Pump Spool Piece Issues No Revision

1/18/2006

12. CR-07-13331 DB-MU32 Flow Controller Stuck Open Slightly No Revision due to Cap Screw Failure #

1/24/2007 During the audit, the staff found that:

Elements 4 and 6 are consistent with the corresponding elements of the GALL Report AMP; Aspects of elements 1, 2, and 5 not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the

- 10 aspects of elements 1, 2, and 5, associated with the exceptions will be addressed in the SER; and Sufficient information was not available to determine whether elements 2 and 3 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 elements 2 and 3 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In element 2 of the LRA AMP it states that certain instances were identified where lubricants containing molybdenum disulfide (MoS 2 ) were approved for use but the operating experience review did not show cases where the MoS 2 lubricant had caused degradation, In the GALL Report AMP it states that the use of MoS 2 as a lubricant has been shown to be a potential contributor to stress corrosion cracking (See) and should not be used, It is not clear to the staff that these statements are consistent because a more thorough clarification is needed on how the applicant will ensure that the components using MoS 2 will not degrade or crack while in service, In element 3 of the LRA AMP it states that inspection of structural bolting is accomplished through the Structures Monitoring Program, In the GALL Report AMP it states that high strength structural bolts and fasteners (A YS > 150 ksi) should be monitored for see, It is not clear to the staff that these statements are consistent because the applicant does not address how aging effects of high strength (AYS >150 ksi) bolting will be managed in its LRA bases documents, During the audit of program element 10, 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 FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable, Based on this audit the staff:

Verified that LRA program elements 4 and 6 and aspects of LRA program elements 1, 2, and 5 not associated with the exceptions are consistent with the corresponding program elements in the GALL Report, The staff's evaluation of the aspects of elements 1, 2, and 5, associated with the exceptions, will be addressed in the SER;

- 11 Identified certain aspects of LRA program elements 2 and 3 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the FSAR Supplement is an adequate description of the program.

New Plant-Specific Program LRA AMP B.2.5, Boral Monitoring Program In the LRA, the applicant states that AMP B.2.5, "Boral Monitoring Program," is a new plant-specific program which was evaluated in accordance with Appendix A 1, Section A 1.2.3 of the SRP-LR. The staff audited the LRA AMP against the acceptance criteria in the SRP-LR for the elements of an AMP. The staff also used License Renewal Interim Staff Guidance Report LR-ISG-2009-001, "Aging Management of Spent Fuel Pool Neutron-Absorbing Materials Other Than Boraflex," which added AMP XI.M40, "Monitoring of Neutron-Absorbing Materials Other Than Boraflex" to the GALL Report, to inform its review of the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 are audited as part of the scoping and screening methodology audit.

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 keyword, "Bora/."

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 Revision I Document Title Date

1. LRPD-05 Boral Monitoring Program Revision 1 .9 During the audit, the staff found that:

Elements 1, 2, and 5 of the LRA AMP were consistent with the acceptance criteria for the corresponding elements in the SRP-LR; and Sufficient information was not available to determine whether elements 3, 4, and 6 of the LRA AMP were consistent with the acceptance criteria for the corresponding elements in the SRP-LR.

- 12 In order to obtain the information necessary to verify whether the LRA program elements 3, 4, and 6 are consistent with the acceptance criteria in the SRP-LR, the staff will consider issuing RAls for the following subjects:

SRP-LR Section A.1.2.3.4, states that detection of aging effects should occur before there is a loss of the structure and component intended functions. The parameters to be monitored or inspected should be appropriate to ensure that the structure and component intended functions will be adequately maintained for license renewal under all CLB design conditions. This includes aspects such as method or technique (e.g., visual, volumetric, surface inspection), frequency, sample size. data collection and timing of new or one-time inspections to ensure timely detection of aging effects.

The LRA does not provide program specific information (e.g., parameters monitored, detection of aging, acceptance criteria) discussed and addressed in recent adverse industry operating experience with neutron absorber materials and staff guidance (Le., NRC Information Notice 2009-26, "Degradation Of Neutron-Absorbing Materials in the Spent Fuel Pool," and GALL Report AMP XI,M40, "Monitoring of Neutron-Absorbing Materials Other Than Boraflex."

During the audit of program element 10, the staff found that:

The operating experience identified by the staff's independent data base search is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff).

The staff also audited the description of the LRA AMP provided in the USAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the USAR Supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the USAR Supplement program description, the staff will consider issuing an RAJ for the following subject:

The staff noted that the USAR Supplement does not reflect the fact that testing of Boral will occur both prior to and during the period of extended operation.

Based on this audit the staff:

Verified that LRA program elements 1, 2, and 5 are consistent with the acceptance criteria for the corresponding program elements in the SRP-LR, while identifying certain aspects of LRA program elements 3, 4, and 6 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Identified the need for additional information regarding the adequacy of the program description in the USAR Supplement.

- 13 Existing Program consistent with GALL LRA AMP B.2.6, Boric Acid Corrosion In the LRA, the applicant states that AMP B.2.6, "Boric Acid Corrosion" is an existing program that is consistent with the program elements in GALL Report AMP XI.M10 "Boric Acid Corrosion." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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," "degradation,"

"rust," "bolt," "inspection," and "pitting."

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 Revision I Document Title Date

1. LRPD-05 Aging Management Program Evaluation Results Revision 1 Boric Acid Control Program Not dated

12. NOP-ER-2001 I Boric Acid Control Program Revision 8 Not dated

3. BAC.02 EN-DP- Boric Acid Corrosion Control Inspections Revision 11 i 01501 11/29/2006

. 4. LER 2002-002 Licensee Event Report Davis-Besse Nuclear No Rev. No.

00 Power Station, Unit No.1 Date of Occurrence 04/29/2002 1 02/27/2002 I 5. CR-02-01846 Condition Report No Rev. No.

04/09/2009

6. CR-09-56995 Condition Report Rev. 7, Chg.3 Not dated i 7. NPF-3. SN 1 Confirmatory Action Letter Response - Root No Rev. No.

• 1270 Cause Analysis Report 04/18/2002 8.2008-1-DB Quarterly Program Health Report (for 1SI Quarter No Rev. No.

of 2008) Not dated

9. 2008-3-DB Quarterly Program Health Report (for 3ro Quarter No Rev. No. I of 2008) Not dated The applicant's program included additional details that augmented the program elements 1-6.

The additional details support the program by including site-specific procedures for evaluating boric acid leakage, considerations for detecting corrosion under insulation, and the maintenance of a boric acid leakage database used for trend analysis.

- 14 During the audit, the staff found that:

Elements 1-6 of the lRA AMP were consistent with the corresponding elements of the GAll Report AMP; During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the 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 USAR Supplement. The staff found this description to be consistent with the description provided in the SRP-lR and, therefore, acceptable.

Based on this audit the staff:

Verified that lRA program elements 1-6 are consistent with corresponding program elements in the GAll Report AMP; Verified that the operating experience is sufficient to indicate that the lRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; Verified that the description provided in the USAR Supplement is an adequate description of the program Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP B.2.7, Buried Piping and Tanks Inspection In the lRA, the applicant states that AMP 8.2.7, "Buried Piping and Tanks Inspection Program,"

is an existing program with enhancements that is consistent with the program elements in GAll Report AMP XI.M34, "Buried Piping and Tanks Inspection." To verify this claim of consistency the staff audited the lRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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. This enhancement expands on the existing program element by adding (1) the emergency diesel fuel oil storage tanks and (2) bolting for buried fire protection system piping to scope the program.

The second enhancement affects lRA program element 4. This enhancement expands on the existing program element by adding (1) a requirement that an inspection of coated and wrapped

- 15 buried piping or tank be performed within 10 years prior to entering the period of extended operation, (2) a requirement that an additional inspection of coated and wrapped buried piping or tank be performed within 10 years after entering the period of extended operation, (3) a requirement that an inspection of uncoated cast iron buried piping be performed within 10 years prior to entering the period of extended operation, (4) a requirement that an additional inspection of uncoated cast iron buried piping be performed within 10 years after entering the period of extended operation, (5) a requirement that an inspection of buried fire protection system bolting be performed when the bolting becomes accessible during opportunistic or focused inspections, and (6) a requirement that the inspection of buried piping be conducted using visual (VT-3 or equivalent) inspection methods with approximately ten linear feet of piping exposed for inspection.

In Table A-1 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: "buried," "underground," "piping," "tank,"

"coating," and "wrap."

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 Revision I Document Title Date

1. LRPD-05 Aging Management Program Evaluation Results Revision 1 Attachment 2.5 for Buried Piping and Tanks Inspection 08/12/2010

2. NOP-ER-2007 Buried Pipe Integrity Program Revision 0 i 11/25/2008 I i 3. CR-08-48540 Coating Damage on 24-inch Blowdown Pipe No Revision I I 10/27/2008 I I 4. CR-08-48288 Leaking Pipe Found No Revision I 10/22/2008 I 5. CR-08-44647 Coating Holidays and Surface Pits Found on No Revision i

EDG 1 Buried Fuel Oil Line 08/11/2008

6. CR-02-02339 Cathodic Protection No Revision 05/29/2002 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, the staff found that:

Elements 1, 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP;

- 16 Sufficient information was not available to determine whether elements 2 and 4 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program elements 2 and 4 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In element 2 of the LRA AMP, the applicant does not describe its cathodic protection system. Although the preventive actions program element of GALL AMP XI.M34 does not discuss cathodic protection, it is the current staff position that cathodic protection is an important preventive measure for steel piping. The staff will consider requesting that the applicant state whether the service water system and emergency diesel generator fuel oil storage tanks are cathodically protected, state the availability of the cathodic protection system, and state whether annual ground potential surveys of the cathodic protection system are conducted and what acceptance criteria are utilized.

In element 2 of the LRA AMP, the applicant does not describe the quality of its backfill.

Although the preventive actions program element of GALL AMP XI.M34 does not discuss the quality of backfill, it is the current staff position that the presence of rocks and sharp objects in the backfill around buried pipes is a leading precursor of degradation of buried piping. The staff will consider requesting that the applicant provide details on the quality of the backfill (e.g., size of backfill particles, restrictions on debris, type of backfill material) in the vicinity of in-scope buried pipes based on plant-specific installation specifications and results of inspections conducted to date.

In element 4 of the LRA AMP, the applicant stated that it will conduct an inspection for each of a coated/wrapped buried piping or tank, and an uncoated cast iron piping segment within the 10-year period prior to entering the period of extended operation and again within ten years after entering the period of extended operation. Although this is consistent with the detection of aging effects program element of GALL AMP XI.M34, it is the current staff position that given the plant-specific operating experience, quality of backfill, quality of coatings, and availability of cathodic protection, the sample size proposed by the applicant may not provide a reasonable basis for assurance that the piping will meet its intended license renewal function(s). The staff will consider requesting that the applicant state the minimum number of inspections that will be conducted every ten years starting ten years prior to the period of extended operation.

Given that the applicant stated that approximately ten feet of pipe will be exposed in each direct visual inspection of excavated buried in-scope piping, the staff will consider requesting that the applicant state the minimum inspection length.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent database search is not bounded by industry operating experience; 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.

- 17 In order to obtain the information necessary to verify whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAls for the following subjects:

Element 10 of the LRA AMP describes two instances of coating degradation, a 1995 example associated with a fuel oil piping leak and a 2008 example associated with a condensate demineralizer backwash line. In addition, the LRA also describes the discovery of four different coating holidays. It is not clear to the staff how this plant-specific operating experience was used to inform how aging will be managed during the period of extended operation because the LRA does not state the cause of the degradation of the coatings.

In order to evaluate the applicant's buried and underground piping inspection programs, the staff must be aware of plant-specific operating experience which might include examples beyond those listed in the LRA. The staff will consider requesting that the applicant provide a list and brief summary of any leaks or adverse conditions (e.g., coating damage that directly exposes the piping or tank to the environment, presence of any coarse material in backfill within 6 inches of the pipe or tank, unexpected corrosion or damage to piping walls or component pressure boundaries) which have occurred in buried piping or tanks at the station in the past five years that were entered in its corrective action program but not included in the LRA.

The staff also audited the description of the LRA AMP provided in the USAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the USAR Supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the USAR Supplement program description, the staff will consider issuing an RAI for the following subject:

The staff noted that the USAR Supplement does not state that preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings and cathodic protection. The staff also noted that the USAR Supplement does not state that the inspection frequency is based on operating experience.

Based on this audit the staff:

Verified that LRA program elements 1, 3, 5, and 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 2 and 4 for which additional information or additional evaluation is required before consistency can be determined; Identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; and Identified a need for additional information regarding the adequacy of the program description in the USAR Supplement.

- 18 Existing Program consistent with GALL with Exceptions andlor Enhancements LRA AMP 6.2.8, Closed Cooling Water Chemistry Program In the LRA, the applicant states that AMP XI.M21 , "Closed Cooling Water Chemistry Program,"

is an existing program with an exception that is consistent with the program elements in GALL Report AMP XI.M21, "Closed-Cycle Cooling Water System." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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 elements 3, 4,5, and 6. In the GALL Report AMP, these program elements recommend performance or functional testing for aging management.

Alternatively, these program elements in the LRA state the program does not include performance or functional testing. The LRA states that the program has been determined to be effective in maintaining the intended functions of the components in the closed cooling water systems without the use of performance or functional testing. The LRA also states that the program includes corrosion coupons to measure corrosion rates at select locations and inspections of opportunity are conducted when the system is opened for maintenance.

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: "cavitation,"

"copper," "degradation," 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 Revision I Document Title Date

1. LRPD-05, Closed Cooling Water Chemistry Program Revision 1 Attachment 2.6b 08/09/2010

2. DBPM-CHEM- Auxiliary System StrategiC Water Chemistry Plan Revision 7 0003 11/20/2008

! 3. DB-CH-06900 Operational Chemical Control Limits Revision 31 08/20/2009

4. EPRI 1007820 Closed Cooling Water Chemistry Guideline Revision 1 04/2004

5. CR 09-53172 Historical Elevated Sulfate in Component i No Revision Cooling Water System . 02/06/2009

6. CR 08-46805 Emergency Diesel #2 Jacket Water Nitrite High No Revision Out of Specification 09/24/2008 I

- 19 During the audit, the staff found that:

Elements 1 and 2 are consistent with the corresponding elements of the GALL Report AMP; Aspects of elements 3, 5, and 6 not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the aspects of elements 3, 4, 5, and 6 associated with the exceptions will be addressed in the SER; and Sufficient information was not available to determine whether element 4 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 4 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing an RAI for the following subject:

In element 4 of the LRA AMP, it states that the One-Time Inspection Program is used to augment the Closed Cooling Water Chemistry Program. It is the current staff position that visual inspections should be conducted whenever the system boundary is opened, and a representative sample of components be selected based upon likelihood of corrosion or cracking and inspected at least once in 10 years. It is not clear to the staff that these statements are consistent, because it appears that the applicant does not plan to conduct periodic visual inspections with minimum inspection intervals for selected samples, but rather one-time inspections will be conducted under One-Time Inspection Program.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff); 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 USAR 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 and 2 and aspects of LRA program elements 3, 5, and 6 not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the aspects of program elements 3, 4, 5, and 6 associated with the exceptions will be addressed in the SER.

- 20 Identified 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 USAR Supplement is an adequate description of the program Existing Program consistent with GALL LRA AMP 8.2.10, Cranes and Hoists Inspection Program In LRA, the applicant states that AMP B.2.1 0, "Cranes and Hoists Inspection Program," is an existing program 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 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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 walkdown, interviewed the applicant's staff, and reviewed onsite documentation provided by the applicant. The staff also conducted an independent data base search of the applicant's operating experience database using the keywords: "bolt,"

"crane," "damage," "inspection," "preload," and "wear."

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 Revision I I Document Title Date

1. LRPD-05, Cranes and Hoists Inspection Program Revision 1 Attachment 3.1 08/09/2010

2. CRA.11, PM Polar Crane Inspection No Revision i 0830 #

06/10/2010

3. CRA.11, PM Intake Gantry Crane Inspection No Revision  !

! 6136 #

11/13/2009 I 4.LRA Davis-Besse Nuclear Power Station License No Revision Renewal Application # I 08/2010 i

5. CR-09-61625 Condition Report - Intake Gantry Crane I ~o Revision I Degradation

. 07/15/2009 I

- 21 Relevant Documents Reviewed (cont'd)

Revision I I

Document Title Date

6. CR-07-19553 Condition Report - Fuel Bridge Selsyn Indexing No Revision Chain Found Broken  ! #  !

I 05/11/2007 During the audit, the staff found that:

Elements 2, 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; Element 4 of the LRA AMP was not strictly consistent with the corresponding elements of the GALL Report AMP but that sufficient information was available to allow the staff to determine that this element of the LRA AMP is equivalent to the corresponding elements of the GALL Report AMP. Specifically, through a review of additional detail in the applicant's program document (LRPD-05, Attachment 3.1), interviews with applicant staff, and the performance of a walkdown, the staff verified that bolts, nuts, rivets, and other fasteners are inspected for loss of preload by this program; and Sufficient information was not available to determine whether element 1 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 LRA program element 1 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing an RAI for the following subject:

In element 1 of the LRA AMP it does not indicate if loss of preload is addressed in this program. In the GALL Report AMP XI.M23 it states that the aging effect of loss of preload of botted connections is managed by this program. It is not clear to the staff that these statements are consistent because the applicant has not identified loss of preload as aging effect that will be managed by this program.

During the audit of program element 10, 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 data base 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 USAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the USAR Supplement was an adequate description of the LRA AMP.

- 22 In order to obtain the information necessary to verify the sufficiency of the USAR Supplement program descriptions, the staff will consider issuing an RAI for the following subject:

The SRP-LR states that the USAR supplement description of this program should include that the number and magnitude of lifts made by the hoist or crane will be reviewed. The LRA program USAR supplement is based on the ANSI B30 series guidance but does not address a review of the number and magnitude of lifts made by a hoist or crane.

Based on this audit the staff:

Verified that LRA program elements 2-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 1 for which additional information or additional evaluation is required before consistency can be determined; 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 Identified a need for additional information regarding the adequacy of the program description in the USAR Supplement.

New Program consistent with GALL LRA AMP 6.2.11, Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Inspection In the LRA, the applicant states that AMP B.2.11, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Inspection," is a new one-time inspection that will be consistent with the 10 elements of an effective aging management program as described in NUREG-1801,Section XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements", as clarified by LR-ISG 2007-02. The applicant committed to implementing this program by April 22, 2017 in LRA Appendix A, Table A-1, "Davis-Besse License Renewal Commitments." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1 6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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: "cable connections," "loosening," and "corrosion."

Further, the staff performed a search of operating experience for the period 2000 through November 2009. Databases were searched using various key word searches and then reviewed by technical auditor staff. Databases searched include Generic Letters, Bulletins, Regulatory Issue Summaries, Licensee Event Reports, Event Notification, Inspection Findings, and Inspection Reports.

- 23 The table be'low 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 Revision I Document Title Date I

1. LRPD-05 l Aging Management Program Evaluation Results, Electrical Cable Connections Not Subject to EQ Requirements Inspection Rev. 1 I 2. LRAMR-E01

• Screening and Aging Management Review of Rev. 2 i Electrical Component Commodity Groups

13. LRPI-04 Operating Experience Review Results and Rev. 2 i Summary I 4. CR-02-06936 SwitchyardlTransformer - Relay House  ! 10/02/2002 i Basement Ground Box Oxidized I I 5. CR-04-03124 Main Transformer Thermal Anomaly on B Phase 05/04/2004

!

i Bushing L6. CR-04-05398 Isophase Bus Ground Faults 09/02/2004 I 7. CR-09-61025 Loss of J Bus, Catastrophic Failure of *.1 Bus 06/25/2009 Potential Transformer

8. CR-09-53547 Water Intrusion in to Bus E-21A 02/13/2009

9. CR-02-06788 Possibility of Boric Acid Degradation Neutral 09/26/2002 I Conductor in Conduit During the audit of program elements 1-6, the staff found that:

Elements 1, 2, 4, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL AMP as modified by ISG-2007-02, "Change to GALL AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." This Interim Staff Guidance recommended a one-time inspection instead of a periodic inspection; Sufficient information was not available to determine whether element 3 of the LRA AMP was consistent with the corresponding element of the GALL AMP. In order to obtain the information necessary to verify whether the LRA program element 3 is consistent with the corresponding elements of the GALL AMP, the staff will consider issuing RAls for the following subjects:

GALL AMP XI,E6, under element 3, states that a representative sample of electrical cable connections is tested. The technical basis for the sample selection is documented. In the basis document LRPD-05 under the same element, the applicant states that the technical basis for the sample selection will be documented. It is not clear to the staff that these statements are consistent because the applicant has not developed the technical basis and/or the criteria for sample selection.

In the basis document LRPD-05, under element 3, the applicant states that the inspections will include detection of loosened bolted connections due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and

- 24 oxidation. It further states that the fol/owing factors will be considered for sampling:

connections type (Le., bolted splices, bolted terminations, lug terminations, bolted cable connections). Splices (butt or bolted), crimp-type ring lugs, connectors, and terminal blocks are described as the most common types of connections in the program description of GALL AMP XI.E6, Rev. 2. The staff believes that loosening of cable connections may occur in different types of connections and may not be limited only to bolted connections.

The staff conducted a plant walkdown of the switchyard in support of the license renewal application. During a plant walkdown, the staff observed cable bus connections in a terminal housing connecting cable bus, bus tie transformers and the 4160 V essential switchgear buses. The applicant indicated to the staff that these cable buses were not subject to aging and an AMP was not needed because they are not located in an adverse localized environment. The staff agreed with the applicant that the insulation material of cable bus is not subject to aging because they are not located in an adverse localized environment. However, cable bus connections (metallic material) may experience increase resistance of connection due to loosening of bolted connections caused by repeated thermal cycling of connected loads. The staff will consider issuing RAls to resolve cable bus connection issue. The staff also identified rust on the switchyard overhead cable support structures and questioned the applicant whether this condition was acceptable. The applicant created Condition Report (CR) Number 11-89726 to document the staff identified condition in the switchyard.

The staff reviewed the UFSAR A.1.11 supplemental description for the program, which states that the one-time inspection uses thermography (augmented by the optional use of contact resistance testing) to detect loose or degraded connections. The staff noted that a one-time inspection is to provide additional confirmation to support industry operating experience that shows electrical cable connections have not experienced a high degree of failures and that existing installation and maintenance practices are effective. The example description of this program is described in NUREG-1800, Rev. 2 (SRP-LR) Table 3.0-1. The purpose of the one-time inspection is to confirm by inspection that either aging of cable connections is not occurring and/or that the existing preventive maintenance program is effective such that a periodic inspection is not required. The program description is not consistent with those in NUREG-1800, Rev. 2, Table 3.0-1.

During the audit of program element 10, 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.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement.

Pending resolution of the item described above, the staff found the applicant's program

- 25 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, 2, 4, 5, and 6 are consistent with the corresponding program elements in the GALL AMP while identifying certain aspects of LRA program element 3 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the UFSAR Supplement is an adequate description of the program.

New Program consistent with GALL LRA AMP 6.2.12, Electrical Cables and Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program In the LRA, the applicant states that AMP 8.2.12, "Electrical Cables and Connections Not Subject To 10 CFR 50.49 Environmental Qualifications Requirements Program," is a new program that is consistent with the program elements in GALL AMP XI.E1, "Electrical Cables and Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements."

The applicant committed to implementing this program prior to the period of extended operation in LRA Appendix A Table A-1, "Davis-Besse License Renewal Commitments." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the UFSAR Supplement. Program elements 7-9 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: "cable" 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 Revision I Document Title Date

1. LRAMR-E01 Screening and Aging Management Review of Rev. 2 Electrical Component Commodity Groups 06/22/2010

2. LRPD-05 Aging Management Program Evaluation Results Rev. 1 06/22/2010

- 26 Relevant Documents Reviewed (cont'd)

Revision I I Document Title Date

/3. LRPD-04 Operating Experience Review Results and Rev. 2 Summary 08/23/2010 During the audit, the staff reviewed the Screening and Aging Management Review of Electrical Component Commodity Groups document and noted that the Limiting 60-year Radiation is 6.81 x 106 Rads. The staff also verified the limiting 60-year temperature for all of the applicant's cable materials.

During a break out meeting, the staff questioned and verified that the sample size of cable inspection will include all inaccessible cables within adverse localized environment.

During the audit, the staff indentified operating experience that indicated wires were damaged by heat during performance of solenoid replacement. The staff noted that wiring was scheduled to be replaced during the following outage. The staff also noted that in a similar Condition Report, degraded cable insulation was identified by the applicant during maintenance testing for the #1 TPCW motor refurbishment.

During the audit of program elements 1-6, the staff found that:

Elements 1-6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

During the audit of program element 10, the staff found that:

The operating experience identified by the 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 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;

- 27 Verified that the description provided in the UFSAR Supplement is an adequate description of the program.

New Program consistent with GALL LRA AMP 8.2.13, Electrical Cables and Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Used In Instrumentation Circuits Program In the LRA, the applicant states that AMP 8.2.13, "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 AMP XI.E2, "Electrical Cables and Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Used In Instrumentation Circuits." The applicant committed to implementing this program prior to the period of extended operation in LRA Appendix A Table A-1. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the UFSAR Supplement. Program elements 7-9 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: "cable" and "corrosion."

The table below lists the documents which were reviewed by the staff and found relevant to the audit. These documents were either provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Revision I Document Title I Date

1. LRAMR-E01 Screening and Aging Management Review of I Rev. 2 Electrical Component Commodity Groups i 06/22/2010

2. LRPD-05 Aging Management Program Evaluation Results Rev. 1 06/22/2010

3. LRPD-04 Operating Experience Review Results and Rev. 2 Summary 08/23/2010 During the audit, staff verified that high voltage, low-level Radiation Monitoring System cables are included in the EQ Program by reviewing the list of all instrumentation cable within scope of GALL AMP XI.E2. The staff also toured the Control Room Emergency Vent System, Radiation Monitor, and High Radiation Cables.

During the audit, the staff indentified operating experience that indicated the Nuclear Instrument detector triax cable connectors are subject to noise. The staff noted that the applicant declared Nuclear Instrument 1 and 2 inoperable and will take action to replace cables.

- 28 During the audit of program elements 1-6, the staff found that:

Elements 1-6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

During the audit of program element 10, the staff found that:

The operating experience identified by the staff's independent database search and supplemented by the applicant is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff);

The operating experience identified by the staff's independent database search and supplemented by the applicant is sufficient to allow the staff to verify 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.

Existing Program consistent with GALL LRA AMP 8.2.14, Environmental Qualification (EQ) Of Electric Components Program In the LRA, the applicant states that AMP B.2.14, "Environmental Qualification (EQ) Of Electric Components," is an existing program that is consistent with the program elements in GALL AMP X.E1, "Environmental Qualification (EQ) Of Electric Components." The applicant committed to implementing this program prior to the period of extended operation in LRA Appendix A Table A-1. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the UFSAR Supplement. Program elements 7-9 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 keyword: "cable."

- 29 The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were either provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed 1 Revision I Document Title Date

11. LRPD- 05 Environmental Qualification (EQ) of Electric Rev. 1 i Components Program I 2. FL-SA-09-098 Snapshot Assessment Plan Environmental 12/18/2009  !

Qualification Program

3. SA2001-0097 EQ Program Self Assessment

4. DB EQ PHR EQ Health Report 2009-Q1 DB EQ PHR 2009 Q2 DB EQ PHR 2009 Q3 DB EQ PHR 2009 Q4 DB EQ PHR 2010 Q1 DB EQ PHR 2010 j Q2 j DB EQ PHR 2010 Q3 DB EQ PHR 2010 i Q4 I 5. DB-SA-05-08 Focus Self Assessment Report 11/03/2005

16. ESI-EQT-1001 Engineering Support Training Environmental Rev. 1 Qualification 10/20/2005

7. ESP- Environmental Qualification Student Study Rev. 1

. ENVIRQUAL-FEN Guide 4/16/2010

8. NOP-CC-5301 Environmental Qualification Program Rev. 2 09/01/2010

9. NG-EN-00306 Environmental Qualification Program Rev. 10 12/18/2008

10. DB1-008C EQ Package Change Notice Rev. 0 I 08/07/2008 i 11. NOP-CC- Calculation No. C-ECS-202.01-003 Rev. 3

• 30020-01 06/18/2008

12. NOP-CC- Calculation No. C-ECS-202.01-001 I Rev. 3 30020-01 04/23/2008 During the audit, the staff evaluated applicant's calculation of EQ zone total integrated radiation dose values for a 60-year plant life. The staff verified algorithms used to develop EQ radiation dose. The staff also verified algorithms used to develop EQ temperature calculations. During

- 30 the EQ breakout meeting, staff requested that the applicant demonstrate its method in calculating real-time Arrhenius weighted average temperature. The applicant claimed that Arrhenius time-weighted average temperature will be higher and more conservative than the Arrhenius real time average temperature for that day. The applicant also claimed that calculation uses approximately seven years of measured temperature data to establish the normal aging temperature for material over a range of activation energies from 0.5 eV to 3.0 eV.

Staff reviewed the applicant's snapshot assessment plan EQ program and noted that the assessment report identified 3 strengths and 5 recommendations. Among the strengths are the applicant's plan maintenance in temperature monitoring and its trending of non-EQ functional locations that could represent a precursor to relate EQ related issues. One of the recommendations asked the applicant to consider sending representation to Nuclear Utility Group on Environmental Qualification meetings to share industry operating experiences and the use of Westinghouse Lifetime Temperature Monitors to trend temperature throughout the plant to validate environmental conditions defined in EQ documentation.

The staff also noted that in Self-Assessment No. 2001-0097 report, one of the recommendations was to develop detailed proceduralized guidance or course objectives that dictate the requirements for EQ training. The applicant's assessment of EQ health report (2009-Q1 to 2010-Q4) indicated its EQ program consistently scored green which equates the highest performance and on occasion white, which is the second highest performance rating.

During the EQ breakout meeting, the staff questioned the applicant regarding Davis-Besse's EQ training program for its staff. The staff reviewed the training manual used as a basic training tool for the entire applicant's engineering staff to be EQ qualified. The staff also evaluated the applicant's operating procedure for temperature monitoring. The staff noted that the site EQ program owner monitors actual temperatures in the environmental zones and coordinated with design engineering for revisions to the design environments. The staff also noted that temperature trending results should be documented in the site EQ program documents according to procedure.

During the audit of program elements 1-6, the staff found that:

Elements 1-6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AM P.

During the audit of program element 10, 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);

The operating experience identified by the staff's independent database search and supplemented by the applicant is sufficient to allow the staff to verify 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; Verified that the description provided in the UFSAR Supplement is an adequate description of the program.

Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP 8.2.15, External Surfaces Monitoring In the LRA, the applicant states that AMP B.2.15, "External Surfaces Monitoring," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M36, "External Surfaces Monitoring." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report will be addressed in the SER.

The first enhancement affects LRA program element 1. This enhancement expands on the existing program element by adding into the scope of the program systems that credit the External Surfaces Monitoring Program for license renewal, but which do not have Maintenance Rule intended functions.

The second enhancement affects LRA program elements 1 and 4. This enhancement expands on the existing program element by adding a condition to cover the inspection of surfaces that are inaccessible or not readily visible during either plant operations or refueling outages, such as surfaces that are insulated, by conducting inspections. Those surfaces will be inspected opportunistically during the period of extended operation.

The third enhancement affects LRA program elements 1, 3, 4 and 6. This enhancement expands on the existing program element by adding the inspection of elastomers and polymers exposed to air-indoor uncontrolled or air-outdoor environments, but not replaced on a set frequency or interval, for evidence of cracking and change in material properties (hardening and loss of strength). In addition, the applicant plans to conduct inspections and surveillances of the control room emergency ventilation system air-cooled condensing unit cooling coil tubes and fins and the station blackout diesel generator radiator tubes and fins for evidence that could result in a heat transfer reduction under this enhancement.

In Commitment 8 of LRA Table A-1, the applicant committed to implement these enhancements prior to April 22, 2017.

- 32 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: "corrosion,"

"degradation," "rust," "inspection," and "pitting."

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 Revision I Document Title Date

11. LRPD-05 Aging Management Program Evaluation Results Revision 1 i External Surfaces Monitorin~ Program Not dated

• 2. NOBP-ER-3003 FENOC System Performance Monitoring Revision 4 Program 01/22/2010

3. NOBP-ER- System Walkdown Check List Revision 0

.3003-02 Not dated

4. NOBP-ER-3009 FENOC Plant Health Report Program . Revision 3 I 10/31/2008

5. CR-02-06498 Condition Report No Rev. No.

09/23/2002

6. CR-02-04923 Condition Report No Rev. No.

i 08/17/2002

7. NOP-LP-2001 Cause Analysis, Apparent Cause Investigation No Rev. No.

03 for CR 02-06498 11/40/2002 i During the audit, the staff found that:

Elements 1-6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base 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 USAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

- 33 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 USAR Supplement is an adequate description of the program.

Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP 8.2.16, Fatigue Monitoring Program In the LRA, the applicant states that AMP B.2.16, "Fatigue Monitoring Program," 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 and the description of the program as contained in the USAR Supplement described in LRA Section A.1.16, "Fatigue Monitoring Program". Program elements 7-9 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 2, 5, and 6. This enhancement expands on the existing program elements by adding options to deal with fatigue sensitive locations projected to exceed a cumulative usage factor (CUF) of 1.0.

The second enhancement affects LRA program element 3. This enhancement expands on the existing program element by proposing to monitor any transient where the 60-year projected cycles were used in an environmentally-assisted fatigue evaluation and to establish an administrative limit that is equal to or less than the 60-year projected cycles.

In Table A-1, item number 9 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," "leak," "crack," "CUF," and "EAF."

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.

- 34 Relevant Documents Reviewed Revision I I Document Title Date

1. LRPD-05 I AMP Evaluation Report - Fatigue Monitoring i Revision 2 Attachment 5.2 i Program I 06/22/2010

2. LRPD-03 TLAA - Metal Fatigue I Revision 2

. 08/04/2010 i 3. LRPD-04 Operating Experience Review Results and Revision 2 Summary 06/22/2010 i 4. EN-DP-00355 Determination of Allowable Operating Transient Revision 4 i Cycles 02/26/2008 I (Including Attachments 1 and 2)

! 5. EN-DP-00355 I AOTC Status Log Revision 3 I Attachment 3 02/19/2008 i 6. AD 1840.01 AOTC Status Log Revision 9 04/24/1990

7. NG-NA-00350 Transient Assessment Revision 1 10/15/2002

8. NA-QC-00356 Transient Assessment Program Revision 2  !

8113/2009 9.DB-SS-05-12 Snapshot Self Assessment of Allowable Operating 10/11/2005 Transient Cycles Program

10. LRPD-02 TLAA and Exemption Evaluation Results Revision 3 7/30/2010

, 11. USAR Updated Safety Analysis Report - DBNPS Unit Revision 27 No.1 06/2010

. 12. LER 2002-009 Degradation of the High Pressure Injection Revision 2 i 02 Thermal Sleeves

• 05/17/2006 113. L-08-034 Summary of Design and Analyses of the Weld 02/08/2008 i

Overlays for Pressurizer and Hot Leg Nozzle Large Bore Dissimilar Metal Welds for Alloy 600 I Mitigation, with Attachment

. 14. CR-03-01846 Steam Generator Welded Tube Plug Transient 03/07/2003 Cycle Counting Issues

15. CR-03-02929 EN-DP-00355 - 13 Cycle Limit For Transient 9 04/15/2003 (Rapid Depressurization) Exceeded

16. CR-11-90057 NRC LRA - Fatigue Monitoring Documents 02/24/2011 Require Updates 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. The staff also conducted a limited audit of the plant-specific time-limited aging analyses (TLAAs) in the LRA that credit the Fatigue Monitoring Program. Observations from this TLAA portion of the audit will be supplemented with further review and additional RAls. As part of the audit, the staff discussed the applicant's use of LRA AMP B2.16 to manage cracking or flaw growth for the following TLAAs: LRA Sections 4.7.1.1 "Fatigue Flaw Growth" (4.7.4 "High Pressure Injection 1 Makeup Nozzle Thermal Sleeves," 4.7.5.1 "Reactor Coolant System Loop 1 Cold Leg Drain Line Weld Overlay Repair," and 4.7.5.2 "OTSG 1-2 Flaw Evaluations.") The staff noted that the AMP B2.16 is

- 35 applicable to CUF calculations/analyses whereas these TLAAs require non-CUF type analyses.

The staff noted that it would require the applicant to update its current licensing basis in accordance with 10 CFR 54.29, and to add an enhancement justifying the application of AMP 82.16 to disposition the non-CUF type analyses. The staff will consider an RAI to resolve the issue discussed.

During the AMP audit, the staff found that:

Sufficient information was not available to determine whether elements 1-6 of the lRA AMP were consistent with the corresponding elements of the GAll Report AMP.

In order to obtain the information necessary to verify whether the lRA program elements 1 through 6 are consistent with the corresponding elements of the GAll Report AMP, the staff will consider issuing RAls for the following subjects:

In element 1 of the lRA AMP, it did not identify any component locations other than those from NUREG/CR-6260 for the effect of reactor coolant environment on fatigue usage. In GAll Report AMP, it states that the sample set of components to be monitored for fatigue and for fatigue usage calculations, where environmental effects of the reactor coolant are expected, should include plant-specific component locations of the reactor coolant pressure boundary if they are more limiting than those considered in NUREG/CR-6260 investigation. It is not clear to the staff whether that these two statements are consistent or equivalent because sufficient information was not available to confirm if NUREG/CR-6260 locations were bounding for the applicant's fatigue evaluation with environmental effects.

In element 2 of the lRA AMP, it states that the systematic counting of plant transient cycles will be used to ensure that the design cycles are not exceeded, thereby ensuring that component fatigue usage limits are not exceeded. In GAll Report AMP it states that the fatigue TLAAs may become invalid if the numbers of actual plant transients were to exceed the numbers used in the fatigue analyses. It is not clear to the staff whether the "design cycles" monitored by the lRA AMP are those used in the fatigue analysis.

In element 3 and the enhancement of the lRA AMP, it states that the AMP will monitor any transient where the 60-year projected cycles were used in an environmentally assisted fatigue evaluation. In GAll Report AMP it states that the program monitors a" plant design transients, and the respective number of occurrences, that cause cyclic strains, which are Significant contributors to the fatigue usage factor, for each component. It is not clear to the staff whether these two statements are consistent or equivalent because the scope of monitoring, as stated in the lRA AMP 82.16, does not include all components subject to the effect of reactor coolant environment and transients of fatigue significance.

In element 4 of the lRA AMP, it does not discuss the updates of fatigue usage calculations. In the GAll Report AMP it states that the program provides for updates of the fatigue usage calculations on an as-needed basis if an allowable cycle limit is approached, or in a case where a transient definition has been changed, unanticipated new thermal events are discovered, or the geometry of components have been modified.

It is not clear to the staff that the two statements are consistent because cycle counting

- 35 alone and its comparison with design cycles may not be sufficient for timely detection of a condition adversely impacting the CUF, and the program is not specific about what corrective action is initiated to ensure that the CUF remains below the allowable limit.

During the audit, the staff noted that Attachment 5.2 of supporting document LRPD-05 indicates that updates of fatigue usage calculations are not necessary unless the number of accumulated fatigue cycles approaches the number of design cycles and that the fatigue monitoring program provides for periodic assessment of the number of accumulated cycles.

In element 5 and the enhancement of LRA AMP, it states that the an administrative limit that is equal to or less than the 50-year projected cycles will be established In GALL Report AMP it states that trending is assessed to ensure that the fatigue usage factor remains below the design limit during the period of extended operation. It is not clear to the staff whether the administrative limit on cycles will be sufficient to ensure timely action because the design cycle limit for a specific component/location may be less than the 50-year projected cycles.

In element 5 of the LRA AMP, it states that the program ensures the tracking and accounting of cycle counts remain below design limits. In GALL Report AMP, it states that the acceptance criterion is to maintain the cumulative usage factor below the design limit. It is not clear to the staff whether the GALL Report AMP requirement is met using cycle counting without confirming that (a) the severity of transients is bounded by the severity assumed in the various fatigue TLAAs and (b) 50-year projected cycles maybe more than the design cycle limits.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base 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 will consider issuing RAls for the following subjects:

The operating experience described in LRA AMP notes that during the Cycle 13 refueling outage (March 2004), the applicant discovered that the existing Fatigue Monitoring Program (identified as AOTC by the applicant) had not been updated or reviewed for a period of approximately four years. In response, the Corrective Action Program was used to document deficiencies and procedure changes were implemented in the AOTC program. The operating experience (OE) notes that the procedure changes have been effective in collecting, documenting, and evaluating required transient data.

However, staff found that the latest documents/records under the AOTC program contained several inconsistencies.

- 37 During its audit, the staff reviewed the applicant's operating experience and condition reports and noted that in-service fatigue issues, such as thermal sleeve cracking and welded plug cracking, had occurred and were identified by the existing program. The staff found the LRA AMP OE discussion of its fatigue monitoring experience lacks specific examples and sufficient details to justify the effectiveness of the existing Fatigue Monitoring Program from plant-specific experience and to demonstrate that timely identification of observed fatigue degradation was achieved, and the corrective actions taken to prevent the recurrence of such failures.

The staff also audited the description of the LRA AMP provided in the USAR Supplement in LRA Section A.1.16. 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; 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 USAR Supplement is an adequate description of the program.

Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP B.2.17, Fire Protection Program In the LRA, the applicant states that AMP B.2.17, "Fire Protection Program," is an existing program, with exceptions, that is consistent with the program elements in GALL Report AMP XI.M26, "Fire Protection." To verify this claim of consistency the staff audited the LRA AMP.

This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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 elements 1, 3, 4, 5, and 6. In the GALL Report AMP, these program elements include management of aging effects on the intended function of the halon and CO2 fire suppression systems. Alternatively, this program element in the LRA states that there are no fixed halon or CO2 suppression systems within the protected area.

The second exception affects LRA program element 6. In the GALL Report AMP, this program element recommends that there is no corrosion in the fuel supply line for the diesel driven fire pump. Alternatively, this program element in the LRA states that the degradation of the diesel fire pump fuel line is noted during functionality and operability tests of the diesel pump that occur periodically. Any evidence of degradations or problems with the inspections or tests as a

- 38 result of degradation would be identified and evaluated through the corrective action process prior to loss of intended function. In addition, the "One-Time Inspection" Program characterizes the internal surface condition of the fuel oil supply line (tubing) for confirmation of the effectiveness of the "Fuel Oil Chemistry Program."

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: "fire," "doors," and "seals."

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 Revision I Document Title Date

1. LRPD-05, Aging Management Program Evaluation Results Revision 1 i Attachment 2.8 09/2010 I 2. NG-DB 00302 DBNPS Fire Protection Program Procedure Revision 6 10/14/2008

! 3. FHAR Fire Hazard Analysis Report Manual Revision 22 06/2008

4. DB-FP-04030 Post Maintenance Visual Inspection of Revision 1 Penetration Seals and Barriers 05/06/2002

5. DB-FP-04038 Ten Percent (10%) Penetration Seal Visual Revision 5 Inspection 08/03/2009

6. DB-FP-04047 Diesel Fire Pump Test Procedure Revision 10 01/28/2009 i 7. DB-FP-04049 Diesel Fire Pump Tests Procedure Revision 12 05/02/2008

8. DB-FP-04028 Appendix A: Fire Door 18 Month Inspection, Revision 4 Periodic Test Procedure 12/22/2008

.9. DB-FP-04036 Appendix R: Fire Door 18 Month Inspection, Revision 6 Periodic Test Procedure 04/16/2009 110. DB-FP-04023  ! Fire Rated Barrier Visual Inspection Revision 12 01/25/2009 i 11. CR 09-63037 Cracks in Fireproofing in CSS#1 08/11/2009

12. CR 09-57716 Void Found in Penetration 04/22/2009

! 13. CR 09-55965 Door 216A is Missing a Screw 03/24/2009

14. CR 09-53813 Degraded Condition Door 02/19/2009

15. CR 09-52019 3M Fireproofing Has Degraded Surface 01/15/2009

16. CR 08-50819 Fuel Oil Leak on Diesel Fire Pump 12/13/2008

17. CR 08-49200 Penetration Found in UNSAT 11/08/2008

18. CR 07-30637 Penetration Failed Ins~ection 11/27/2007

19. CR 07-14252 Failed Fire Barrier in 314 02/09/2007

- 39 Relevant Documents Reviewed (cont'd)

Revision I Document Title Date

20. CR 06-11944 Penetration 127E /427-W2-128 12/28/2006

21. CR 03-00038 Failed Fire Penetration Seal Inspection 01/04/2003 During the audit, the staff found that:

Element 2 is consistent with the corresponding element of the GALL Report AMP; and Aspects of elements 1, 3, 4, 5, and 6 not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the aspects of elements 1, 3, 4, 5, and 6 associated with the exceptions will be addressed in the SER.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base 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 USAR 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 element 2 and aspects of LRA program elements 1, 3, 4, 5, and 6 not associated with the exceptions are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the aspects of elements 1, 3, 4, 5, and 6 associated with the exceptions will be addressed in the SER.

Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; Verified that the description provided in the USAR Supplement is an adequate description of the program.

- 40 Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP 8.2.18, Fire Water Program In the LRA, the applicant states that AMP XI.M27, "Fire Water Program," is an existing program, with enhancements, that is consistent with the program elements in GALL Report AMP XI.M27, "Fire Water System." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 are audited as part of the scoping and screening methodology audit.

The first enhancement affects LRA program elements 3 and 4. This enhancement expands on the existing program element by adding a program requirement to perform periodic ultrasonic testing for wall thickness of representative above-ground water suppression piping that is not periodically flow tested but contains, or has contained, stagnant water.

The second enhancement affects LRA program element 4. This enhancement expands on the existing program element by adding a program requirement to perform at least one opportunistic or focused visual inspection of the internal surface of buried fire water piping and of similar above-ground fire water piping, within the five-year period prior to the period of extended operation, to confirm whether conditions on the internal surface of above-ground fire water piping can be extrapolated to be indicative of conditions on the internal surface of buried fire water piping.

The third enhancement affects LRA program element 4. This enhancement adds requirements to perform representative sprinkler head sampling or replacement prior to 50 years in-service, and at 1a-year intervals thereafter, in accordance with National Fire Protection Association (NFPA) 25 or until there are no untested sprinkler heads that will see 50 years of service through the end of the period of extended operation.

The fourth enhancement affects LRA program element 4. This enhancement adds requirements, if certain conditions are met, to perform opportunistic fire water supply and water based suppression system internal inspections each time a fire water supply or water-based suppression system is breached for repair or maintenance.

In LRA Section A.3, Table A-1 of the LRA, the applicant committed to implement these enhancements on April 22, 2017.

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 keywords: "corrosion,"

"degradation," and "microbiological."

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.

- 41 Relevant Documents Reviewed Revision I Document Title Date

1. LRPD-05, Fire Water Program Revision 1 Attachment 2.8a 08/17/2010

2. NG-DB-00302 DBNPS Fire Protection Program Revision 6 10/14/2008

! 3. NFPA 25 Inspection, Testing and Maintenance of Water- 2002 Edition Based Fire Protection Systems 01/31/2002 P-04033 Annual Fire Protection System Flush Revision 5 04/22/2009

5. DB-FP-04035 5 Year Flow Test Revision 4 05/15/2008

6. CR-04-04158 Fire Water Storage Tank No Revision

08/03/2004 The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff found that Elements 2, 3, 4, 5, and 6 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 1 of the LRA AMP is consistent with the corresponding element of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program element 1 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing the following RAI for the following subject:

In element 1 of the LRA AMP it states that cracking due to stress corrosion cracking of copper alloy with greater than 15% zinc will be managed using the same testing and inspection activities that identify and manage loss of material. In the GALL Report AMP it states that the program will manage loss of material due to corrosion, microbiological influenced corrosion (MIC), or biofouling. It is not clear to the staff that these statements are consistent because the LRA does not provide sufficient information to determine how cracking is being appropriately managed.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base search is sufficient to allow the staff to verify that the LRA AMP,

- 42 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 USAR 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 2,3,4,5, and 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 1 for which additional information or additional evaluation is required before consistency can be determined; 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 FSAR Supplement is an adequate description of the program.

EXisting Program consistent with GALL LRA AMP B.2.19, Flow-Accelerated Corrosion In the LRA, the applicant states that AMP B.2.19, "Flow-Accelerated Corrosion," is an existing program that is consistent with the program elements in GALL Report AMP XI.M17, "Flow-Accelerated Corrosion." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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: "flow accelerated," "cavitation,"

and "erosion."

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 Revision I Document Title Date

1. LRPD-05 Aging management Program Evaluation Results Revision 1 .9 for Flow Accelerated Corrosion 08/20/2010

2. No Document Flow Accelerated Corrosion Report for the No Revision No. Fifteenth Refueling Outage 06/22/2008

- 43 Relevant Documents Reviewed (cont'd)

I Revision I Document Title Date

3. No Document Flow Accelerated Corrosion Report for the No Revision No. Fourteenth Refueling Outage 2006

4. CR-06-8128 FAC Program Deficiency Evaluation No Revision 10/16/2006

5. CR-06-00855 Wall Thinning in 6-inch EBD-12 Elbow No Revision 03/13/2006

6. CR-05-02570 Flow Accelerated Corrosion Program No Revision Enhancements from Dominion Benchmarking 05/04/2005 During the audit, the staff found that:

Elements 1-6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the 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 reviewed the operating experience described in condition report CR-06-8128 associated with a steam leak discovered in 2006 on the moisture separator reheater number 1, first stage reheat drain. The staff reviewed the condition report and found that the cause of the steam leak was due to wall thinning of the drain line as a result of under-predicted degradation rates on the piping system by CHECWORKS. The applicant initiated a corrective action by performing an independent review of the modeling data within the CHECWORKS software package used by the Flow-Accelerated Corrosion Program. The applicant stated that the program was enhanced by providing a second level of verification of the data entered into CHECWORKS to improve the quality of the model.

The staff also audited the description of the LRA AMP provided in the USAR 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;

- 44 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 USAR Supplement is an adequate description of the program.

Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP 8.2.20 Fuel Oil Chemistry Program In the LRA, the applicant states that AMP 8.2.20, "Fuel Oil Chemistry," is an existing program, with exceptions, that is consistent with the program elements in GALL Report AMP XI.M30, "Fuel Oil Chemistry." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the prog ram as contained in the USAR Supplement. Program elements 7-9 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 programs elements 1 and 6. In the GALL Report AMP program element 1 recommends managing the conditions that cause corrosion of the diesel fuel tank internal surfaces in accordance with technical specifications and the guidelines of ASTM Standards 01796,02276,02709,06217, and 04057. Program element 6 recommends using ASTM 06217 and Modified 02276, Method A as guidance for determination of particulates.

The modification to 02276 consists of using a filter with a pore size of 3.0 IJm, instead of 0.8 IJm. Alternatively, this program element in the LRA states that the program does not explicitly use ASTM 06217. The applicant stated that it uses ASTM 02276 versus ASTM 06217 for guidance on the determination of particulate contamination. The applicant further stated that ASTM 02276 is used, with an acceptance criterion of a total particulate contamination of less than 10 milligrams per liter (mg/l).

The second exception affects LRA program elements 1, 3 and 6. In the GALL Report AMP program element 1 recommends managing the conditions that cause corrosion of the diesel fuel tank internal surfaces in accordance with technical speCifications and the guidelines of ASTM Standards 01796,02276,02709,06217, and 04057. Program elements 3 and 6 recommend using ASTM 01796 and 02709 for determination of water and sediment contamination in diesel fuel. Alternatively, this program does not explicitly use ASTM 01796, but uses ASTM 04176 or 02709 instead. The applicant stated that ASTM 01796 which provides guidance for water and sediment determination in No. 40 diesel fuel, is not used. It was further stated that ASTM 04176 is used for guidance on the determination of fuel oil appearance and ASTM 02709 is used for guidance on determination of water and sediment contamination. Further, the applicant stated that ASTM 04176 or ASTM 02709 is used with the acceptance criteria of clear and bright with appropriate color, or water and sediment contamination less than 0.05 percent by volume, respectively.

The third exception affects LRA program element 3. In the GALL Report AMP this program element recommends the use of ASTM Standard 02276, Method A for the determination of particulates. The modification consists of using a filter with a pore size of 3.0 IJm, instead of 0.8 IJm. Alternatively, this program does not use a filter pore size of 3 IJm; instead, a filter with 0.8 IJm pore size is used. The applicant further stated that the 0.8 IJm filter is more conservative

- 45 than the 3 j.Jm because it allows for a larger sample of particulates because smaller particles are retained.

The fourth exception affects LRA program element 4. In the GALL Report AMP this program element states that compliance with diesel fuel oil standards mentioned in element 3 (parameters monitored or inspected) and periodic multi-level sampling provide assurance that fuel oil contaminants are below unacceptable levels. Alternatively, this program does not perform multi-level sampling of the fuel oil storage tanks. Rather, composite samples are taken from three separate locations in the lower portion of the emergency diesel generator fuel oil storage tanks, where contaminants may collect.

The fifth exception affects LRA program element 2. In the GALL Report AMP this program element recommends the use of biocides, stabilizers, and corrosion inhibiters. Alternatively, this program does not include the addition of biocides, stabilizers, or corrosion inhibitors to the fuel oil for the emergency diesel generators. The applicant stated that the combination of ensuring specified physical and chemical properties of new fuel oil are within limits and periodic cleaning and draining of the tanks has been shown to mitigate corrosion inside the tanks and fuel oil degradation. The applicant also stated that if necessary, fuel oil additive may be used at the program owner's discretion.

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: "fuel oil," "tank,"

and "diesel."

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 Revision J Document Title Date

1. LRPD-05 Aging Management Program Evaluation Results Revision 1

2. DB-CH-OOOOB Diesel Fuel Oil Program Revision 12 06/29/2010

13. DB-OP-06273 Diesel Fuel Oil Transfer Revision 20 09/21/2010

14. FO.07a-DB-CH Operational Chemical Control Limits Revision 33

.06900 11/19/2009

• 5. FO.09.a-DB- Emergency Diesel Generator Fuel Oil Storage Revision 12 I CH-03023 Tank 2 Monthly Analysis 05/15/2009

,6. FO.09.d-DB Emergency Diesel Generator 2 Fuel Oil Day Revision 1 CH-03041 Tank Drain Sample 12/1BI200B I 7. FO.09.e-DB Emergency Diesel Generator Fuel Oil Storage Revision 00  !

. CH-03042 Tank 1 Drain Sample 09/09/200B I B. FO.09.g-DB New EDG Fuel Oil Analysis Revision 00  !

CH-03044 12/13/200B I

- 46 Relevant Documents Reviewed (cont'd)

Revision I Document Title Date

9. FO.09.j-DB-CH Station Blackout Diesel Fuel Oil Day Tank Revision 08 04043 Monthly Analysis 09/28/2007 During the audit the staff found that:

Element 5 and aspects of elements 1, 2, 3, and 6, not associated with the exceptions, are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the aspects of elements 1, 2, 3, 4, and 6, associated with the exceptions, will be addressed in the SER; and Sufficient information was not available to determine whether element 4 of the LRA AMP was consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program element 4 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing a RAI for the following subject:

In element 4 of the LRA AMP, the draining and cleaning frequency is not consistent with the 10 year draining and cleaning frequency for diesel fuel tanks recommended by the GALL Report. Instead, the LRA states that draining and cleaning of the DB-T47 and DB-T21 0 tanks are performed on a 12-year interval.

In addition, the LRA AMP does not explicitly state and it is not clear to the staff whether volumetric inspections of degradation identified by visual inspections of tank internal surfaces will be performed. The applicant committed to providing the staff with the additional information.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base 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 USAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the USAR Supplement was an adequate description of the LRA AMP.

- 47 In order to obtain the information necessary to verify the sufficiency of the USAR Supplement program description, the staff will consider issuing RAls for the following subject:

LRA Section A.1.20 "Fuel Oil Chemistry Program", does not specify the specific ASTM Standards to be used. Specifying the ASTM Standards to be used ensures that there is an adequate description of the critical elements of the Fuel Oil Chemistry AMP to provide assurance that the program will be properly executed during the period of extended operation.

Based on this audit the staff:

Verified LRA program element 5 and aspects of LRA program elements 1, 2, 3, and 6, not associated with the exceptions, are consistent with the corresponding program elements in the GALL Report. The staffs evaluation of the aspects of elements 1, 2, 3, 4, and 6, associated with the exceptions, will be addressed in the SER; Identified 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 Identified a need for additional information regarding the adequacy of the program description in the FSAR Supplement.

New Program consistent with GALL LRA AMP B.2.21, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program In the LRA, the applicant states that AMP B.2.21, "Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Program," is a new program that is consistent with the program elements in GALL Report AMP XI.E3, "Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements." The applicant committed to implementing this program by April 22,2017, in LRA Appendix A, Table A-1. To verify this claim of consistency the staff audited the LRA AMP.

This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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 various keywords such as:

"manhole," "duct," "water," "submergence," "cable," "underground," and "vault."

Further, the staff performed a search of operating experience for the period 2000 through November 2010. Databases were searched using various key word searches and then reviewed by technical auditor staff. Databases searched included Generic Letters, Bulletins,

- 48 Regulatory Issue Summaries, Licensee Event Reports, Event Notification, Inspection Findings, and Inspection Reports.

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were either 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 i

1. LRPD-05 Inaccessible Medium-Voltage Cables Not Attachment 4.3 Subject to 10 CFR 50.49 Environmental Revision 1 i Qualification Requirements Program i

2. NORM-ER-3112 Cable Monitoring Revision 1

[

07/31/2008

3. Inspection Davis Besse Nuclear Power Station NRC Revision: N/A  !

Report . Problem Identification and Resolution Inspection 01/30/2005 05000346/200401 Report 7

4. Condition SHRR- Testing Review for 4.16kV System Revision: N/A

• Report 08/26/2002 i 02-05000 I 5. Condition Low Insulation Resistance for Make-up Pump Revision: N/A

, Report 02-08474 Motor Feed 10/22/2002 i

• 6. Condition Breakers HA08 and HAAE4 Tripped Revision: N/A I I Report 04-02575 04/07/2004

• 7. Condition NRC Problem Identification and Resolution Revision: N/A Report 04-07843 Inspection - Corrective Actions Adequacy for 12/16/2004 Underground Wetted Cables i

8. Condition Service Water Pump 3 Cable Damage. Revision: N/A i Report 09-62604 07/31/2009 ,

• 9. Condition NRC Problem Identification and Resolution Revision: N/A i Report 05-01499 LOG1-4635 Corrective Actions Adequacy for 02/25/2005 i Underground Wetted Cable

[11. Integrated Davis Besse Nuclear Power Station Integrated Revision: N/A

• Inspection Report Inspection Report 10/21/2009 i 05000346/2009 004 I

12. Integrated i Davis Besse Nuclear Power Station Integrated Revision: N/A

• Inspection Report

• Inspection Report 04/27/2010 I i 05000346/2010 i

002 I

13. Integrated Davis Besse Nuclear Power Station Integrated Revision: N/A Inspection Report Inspection Report 01/13/2010 I 05000346/2009 005 i

14. Response to Response to NRC Generic Letter 2007-01 Revision: N/A GL 2007-01 05/08/2007

- 49 Relevant Documents Reviewed (cont'd)

Document Title Revision I Date

15. Work Order PM 8025 Manhole Water Levels Revision: N/A

• 200313715 06/03/2009

16. Work Order i PM 4297 MH3001, 04,05,41, and 42 Inspection Revision: N/A 200315786 L 06/30/2010

17. Work Order i PM 4296 Inspect Site Manholes MH3024, 26, Revision: N/A

• 200215004 127,28, MHSA1, A2, MHSB1, and B2 02/25/2008

[18. Work Order i PM4295 MH3007, 11, 12, 13, 14, 15, 16, 17, Revision: N/A

• 200214311 i and 18. 07/9/2007

19. Work Order PM4294 MH3008, 09,10,21,22,23,25,30,31, Revision: N/A 200241467 32,33,34,35,36,37,99, and 101 08/15/2008 20.2010-4 Davis Besse System Health Report Revision: N/A 02/14/2010

21. NOP-LP-2100 Operating Experience Program Revision: 4 06/23/2009

22. Condition Electrical Manhole MH3045 - Cables Revision: N/A Report10-70666 Submerged During the audit of program elements 1-6, the staff found that:

Sufficient information was not available to determine whether elements 1-6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program elements 1-6 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

The application of GALL Report AMP XI. E3 to medium voltage cables was based on the operating experience available at the time Revision 1 of the GALL Report was developed. However, industry operating experience subsequent to GALL Report Revision 1 indicates that the presence of water or moisture can be a contributing factor in inaccessible power cables failures at lower service voltages (400 V to 2 kV).

Applicable operating experience was identified in licensee responses to Generic Letter (GL) 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," which included failures of power cable operating at service voltages of less than 2 kV where water was considered a contributing factor. The staff also noted that the significant voltage screening criterion (subject to system voltage for more than energized 25% of the time) was not applicable for all of the inaccessible power cable failures noted.

Industry operating experience provided by NRC licensees in response to GL 2007-01 has shown: (a) that there is an increasing trend of cable failures with length in service, (b) that the presence of water/moisture or submerged conditions appears to be the predominant factor contributing to cable failures. The staff has determined, based on the review of the cable failure data, that an annual inspection of manholes and a cable test frequency of at least every 6 years (with evaluation of inspection results to

- 50 determine the need for an increased inspection frequency) is a conservative approach to ensuring the operability of power cables and, therefore, should be considered. The use of test and inspection frequencies in the determination of the need for adjustment of test and inspection frequencies should also be considered.

In addition, industry operating experience subsequent to GALL Report Revision 1 has shown that some NRC licensees may experience cable manhole water intrusion events, such as flooding or heavy rain, that subjects cables within the scope of program for GALL Report AMP XI.E3 to significant moisture. The staff has determined that event driven inspections of cable manholes, in addition to a 1-year periodic inspection frequency, is a conservative approach and, therefore, should be considered.

Based on the above, the applicant's aging management program may not be consistent with GALL AMP XI.E3 or SRP-LR Section A.1.2.3.1 0 in that as additional operating experience is obtained, lessons learned are evaluated and the program adjusted as needed. Therefore, additional information is required by the staff to verify the applicant's conclusion that the effects of aging will be managed adequately so that the in-scope inaccessible power cable intended functions will be maintained during the period of extended operation.

During the audit of program element 10, the staff found that:

The operating experience 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 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 will consider issuing RAls for the following subjects:

• Corrective actions to be implemented for manhole MH3045 to prevent in-scope inaccessible cable from being exposed to significant moisture (cable submergence) during the period of extended operation.

• Work orders for manhole inspections do not specifically require documentation if in-scope inaccessible cables are found submerged.

• Sump pumps used to drain in-scope manholes may not be located in in-scope manholes and may not be inspected/functionally tested under LRA AMP B.2.21.

• Information detailing in-scope cable replacements and schedule for any additional in-scope inaccessible cable replacements or monitoring (testing)

- 51 The staff also audited the description of the LRA AMP provided in the USAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the USAR Supplement was an adequate description of the LRA AMP.

In order to obtain the information necessary to verify the sufficiency of the USAR Supplement program description, the staff will consider issuing RAls for the following subjects:

The applicant's USAR supplement did not reflect the information in LRA SRP Table 3.0-1 Revision 2, in the following areas:

• Cable test frequency (at least every 6 years)

• Manhole inspection frequency (at least once every year)

• Inspection and test frequencies established using plant-specific operating experience

• Expanded inaccessible power cable scope (greater than or equal to 400 V)

• Elimination of the significant voltage criterion

• Structural inspection

• Event driven inspections 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 AMP while identifying certain aspects of LRA program elements 1-6 for which additional information or additional evaluation is required before consistency can be determined; Identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; and Identified a need for additional information regarding the adequacy of the program description in the USAR Supplement.

Existing Program consistent with GALL LRA AMP 8.2.22, Inservice Inspection (lSI) Program -IWE In the LRA, the applicant states that AMP B.2.22, "Inservice Inspection (lSI) Program -IWE," is an existing program that is consistent with the program elements in GALL Report AMP XI.S1, "ASME Section XI, Subsection IWE." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement A.1.22. Program elements 7-9 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:

"containment," "sand pocket," and "corrosion."

- 52 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 Revision I Document Title Date

1. SL-007564 Davis-Besse Nuclear Plant, Engineering

• Revision 2 Assessment Report, Containment Vessel 05/16/2003 Corrosion, prepared by Sargent & Lundy

2. Serial Letter Inservice Inspection Summary Report of Cycle 06/23/2004

.3057 13 and 13th Refueling Outage Activities for the i Davis-Besse Nuclear Power Station

. 3. DB-PF-03009 Surveillance Test Procedure, Containment Rev. 6 Vessel and Shield Building Visual Inspection

• 03/04/2009

4. CR-10-72660 Evaluation of Structures Walkdown of the Annulus Sand Pocket outside steel containment

5. CR-02-02528 . Extent of Issue Condition Issues for Steel 06/11/2002 i Containment Vessel

6. CR-04-03022 Evaluation of IN 2004-09 for Similar Concerns at 04/29/2004 Davis-Besse

7. LRPD-04 Operating Experience Review Results and 08/23/2010 Summary During the audit of program elements 1-6, the staff found that:

Elements 2, 3, 4, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufncient information was not available to determine whether element 1 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 1 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing RAI for the following subject:

In LRA AMP it states that elements 1 through 6 are consistent with the corresponding elements of the GALL Report AMP. According to GALL Report AMP, integral attachment to steel containment (piping penetrations) is included in the scope of the program. However, program basis document for the AMP states that piping penetrating the containment is attached to the containment vessel via flued heads or sleeves. It is not clear to the staff that piping penetrations are included in the scope of the program.

During the audit of program element 10, 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

- 53 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 will consider issuing RAls for the following subjects:

During the audit, the staff reviewed documentation that indicated presence of standing water in the annulus sand pocket region. The standing water appears to be recurring issue of ground water leakage. In addition, areas of corrosion were observed on the containment vessel. In addition, during the audit the staff reviewed photographs that indicate peeling of clear coat on the containment vessel annulus area, and degradation of the moisture barrier, concrete grout, and sealant in the annulus area that were installed in 2002-2003. Therefore, staff plans to issue an RAI.

During the site audit, the NRC staff reviewed documentation that indicated the potential for borated water leakage to the top of steel containment. The staff plans to request the applicant to provide plans for inspecting the inaccessible portion of the steel containment which may be exposed to borated water.

The staff reviewed documentation during the audit concerning the inspection of steel containment; however, it was not clear from these documents if the applicant inspection credits coating on the inside surface of the containment for corrosion protection. The staff plans to request the applicant to address this issue in response to an RAI.

The staff also audited the description of the LRA AMP provided in the USAR 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; 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 USAR Supplement is an adequate description of the program.

- 54 Existing Program consistent with GALL LRA AMP B.2.23, Inservice Inspection (151) Program -IWF In the LRA, the applicant states that AMP B.2.23,"lnservice Inspection (lSI) Program -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 and 10 and the description of the program as contained in the FSAR Supplement. Program elements 7-9 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:

"Inservice Inspection," "corrosion," "support," "defective," "IWF," and "Vf."

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 Revision I Document Title Date i 1. LRPD-05, lSI Program - IWF Revision 1 1 i Attachment 3.4 08/23/2010

2. LRPD-05, Bolting Integrity Program Revision 11 Attachment 2.3 08/23/2010

3. CR-04-03022 NOP-LP-2001-06 (Licensee investigation as a 07/09/2004 result of NRC-issued Information Notice (IN) i 2004-09)

I 4. CR-02-06925 SHRR Walkdowns of Aux Boiler/Aux Steam: 08/1512002 i Leakage and Badly Corroded Pipe Support

15. CR-04-07125 Snubber Visual Examination and Inservice 11/23/2004 Inspection Concerns

! 6. CR-06-00781 CC-36-HBC-2-H7 Sway Strut 03/07/2006

. 7. CR-06-01684 SW Hanger # SW-41-HBC-46-H3 and SW-41 04/07/2006 and CR-06-01683 HBC-47-H7 (similar reports) i 8. CR-05-00547 QC - Corrosion on Snubber Pipe Clamp Parts 01/21/2005

9. C-CSS-100.00 Bolting-Minimum Thread Engagement 04/15/1996 11 B

10. Letter 3278 lSI Summary Report - Cycle 14 and Refueling 07/21/2006 Outage 14R (14RFO)

11. L-08-136 lSI Summary Report - Cycle 15 and Refueling 05/14/2008 Outage 15R(15 RFO)

12. L-10-127 lSI Summary Report - Cycle 16 and Refueling 09/27/2010 Outage 16R (16RFOt I

- 55 Relevant Documents Reviewed (cont'd)

Revision I Document Title Date

13. NOP-CC-5710 Nuclear Operating Procedure - ASME Section 07/26/2007 XI Inservice Inspection (lSI) Program 14.ISIS-3 Third 10-year Inspection Schedule Revision 3 05/13/2008 I 15.ISIP-3 Third 10-year Inspection Plan Revision 4

. 05/13/2008 I

• 16. DB-PF-00104 Davis Besse Administrative Procedure- Revision 12 Inservice Inspection Program 05/27/2009 I During the audit of program elements 1 - 6, the staff found that:

Elements 1,2,3,4, and 6 of the LRA AMP were not strictly consistent with the corresponding elements of the GALL Report AMP but that sufficient information was available to allow the staff to determine that these elements of the LRA AMP are equivalent to the corresponding element of the GALL Report AMP; Sufficient information was not available to determine whether element 5 of the LRA AMP was consistent with the corresponding elements of the GALL Report AMP.

The basis for the staffs determination that elements 1, 2, 3, 4, and 6 of the LRA AMP are equivalent to the corresponding GALL Report AMP is:

GALL AMP XI.S3, "ASME Section XI, Subsection IWF," elements 1,2,3,4 and 6 address supports for ASME Class 1, 2, and 3 piping and components supports that are not exempt from examination in accordance with IWF - 1230 and MC supports. The lSI Program - IWF does not include MC supports or vibration isolation elements. This exclusion is acceptable because the plant has no ASME Class MC supports and has not identified any non-metallic vibration isolation elements. Also, the lSI Program -IWF program basis document does not explicitly specify structural bolting in the scope of the program, but credits the use of the IWF program for structural bolting in section B.2.4, "Bolting Integrity Program." The staff finds this acceptable because bolting is included in the ASME IWF program by reference.

Element 5 of the GALL Report states that when lSI examinations of component supports discover verified changes of conditions from prior examination, such changes should be recorded in accordance with ASME Section X,I Subsection IWA-6230. The LRA AMP does not address how the program will document discovered changes in component condition from previous examinations. It is not clear to the staff whether the LRA AMP is consistent with the GALL Report because the GALL Report recommends recording discovered changes in component condition using IWA-6230 and the LRA AMP and basis documents do not specify if and how changes in component condition will be recorded.

- 56 During the audit of program element 10, 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 FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Based on this audit the staff:

Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 1-6 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 USAR Supplement is an adequate description of the program.

EXisting Program consistent with GALL LRA AMP B.2.24, Inservice Inspection Program In the LRA, the applicant states that AMP B.2.24, "Inservice Inspection Program," is an existing program that is consistent with the program elements in GALL Report AMP XI.M1, "ASME Section XI Inservice Inspection, Subsections IWB, IWe, IWD." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the FSAR Supplement. Program elements 7-9 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 data base search of the applicant's operating experience database using the keywords: "degradation," "weld," 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 staff's search of the applicant's operating experience database.

- 57 Relevant Documents Reviewed Revision I Document Title Date

, 1.LRPD-05 Aging Management Program Evaluation Results . Rev. 2

• Attachment 1.1 Inservice Inspection Program 08/02/2010 i

2. LRPD-04 Operating Experience. Review Results and Rev. 2 Summary 08/23/2010 3.IS1.11 Third 10 Third Ten Year Inservice Inspection Program Rev. 4 year inspection 05/13/2008 plan ISIP-3 REV i 04 I

. 4. ISI.11_ISIP-3 Third Ten Year Inservice Inspection Program Rev. 5  !

R5 06/09/2009 I

5. DB-PF-00104 Davis Besse Administrative Procedure Rev. 12 Inservice Inspection Program 05/27/2009 I

6. EN 45764 Event Notification Report No Revision 03/13/2010 1

17. EN 42437 Event Notification Report No Revision 03/21/2006

8. EN 38732 Event Notification Report No Revision 02/27/2002

9. CR-03-01796 Condition Report: Potential Violation of ASME XI No Revision Inspection Interval Requirements 03/06/2003 I

10. CR-03-02168 Condition Report: PT Indication by PH-11 No Revision 03/17/2003 I During the audit of program elements 1-6, the staff found that:

Elements 2, 3, 4, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether elements 1 and 5 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program element numbers 1 and 5 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In element 1 of the LRA AMP it states that some augmented inspections will be implemented in the Inservice Inspection Program. In the GALL Report AMP it states that in certain cases, the ASME Inservice Inspection Program is to be augmented to manage the effects of aging for license renewal. It is not clear to the staff what augmented inspections are to be included in the lSI program at this site and thus it is not clear that these statements are consistent.

In element 1 of the LRA AMP it states that the components described in ASME Section XI Subsections IWB-1220, IWC-1220, and IWD-1220 are exempt from the examination requirements of Subsections IWB-2500, IWC-2500, and IWD-2500 per the

- 58 Third Ten Year Inservice Inspection Program Plan. In the GALL Report AMP it states that the components described in Subsections IWB-1220, IWC-1220, and IWD-1220 are exempt from the volumetric and surface examination requirements, but not exempt from visual exam requirements of Subsections IWB-2500, IWC-2500, and IWD-2500. It is not clear to the staff that these statements are consistent because the statement made by the applicant is consistent with Revision 1 of the GALL and not with the current view of the staff.

In element 5 of the LRA AMP it states that the evaluation of flaws may result in re-inspection or sample expansion. In the GALL Report AMP it states that flaw conditions that are acceptable for continued use are to be reexamined during the next 3 inspection periods of IWB-2110, IWC-2410, and IWD-241° for Class 1,2, and 3 components respectively. It is not clear to the staff that these statements are consistent because no information is readily available in this AMP or supporting documents to show whether additional examinations will be performed on flaw conditions that are acceptable for continued use.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Based on this audit the staff:

Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 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 FSAR Supplement is an adequate description of the program.

- 59 Existing Program consistent with GALL LRA AMP B.2.26 Lubricating Oil Analysis Program In the LRA, the applicant states that AMP 8.2.26. "Lubricating Oil Analysis Program," is an existing program that is consistent with the program elements in GALL Report AMP XI.M39, "Lubricating Oil Analysis". To verify this claim of consistency the staff audited the LRA AMP.

This audit report considers program elements 1-6 and 10 and the description of the program as contained in the FSAR Supplement. Program elements 7-9 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 data base search of the applicant's operating experience database using the keywords: "lubricating oil", "particulate,"

and "water contamination".

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed I Revision I Document Title I Date i 1. DB-GK5 CMP Component Monitoring Plan DB-GK5 CMP 02/13/2009 I

• 2. CR-08-50851 High Particle Counts in the Backup Service 12/15/2008 Water Pump Motor Oil

3. NOP-ER-4001 FENOC Condition MonitorinQ Rev. 01

4. Self Davis-Besse Ongoing Self-Assessment Report 04/03/2004 Assessment Lubrication Monitoring and Analysis Program

1. 2002-0100 (LMAP), Decernber 8, 2003-Februarv 23, 2004

, 5. DB-CH-06900 Operational Control Limits Rev. 31

6. DB-MM-01009 Lubricant Sampling Methods Rev. 4 I 7. DB-OP-06208 Lube Oil Transfer, Purification, and Storage Rev. 6 System

8. DB-MN-00004 Control Of Lubricants Rev. 6

9. NORM-ER-3516 Main Turbine Lube Oil System Rev. 0

10. CR-02-05703 EDG Oil Changes 09/09/2002 i 11. CR-03-02753 DH Pump #2 Inboard Bearing Oil Sample 03/24/2003 i Discolored and Contains Trace Copper i 12. CR-03-08386 Decay Heat Pump #1 High Oil Particulate Level 02/05/2004

, 13. CR-04-04932 Elevated Particulate Count in the #2 EDG 07/02/2004 Generator Bearings I

14. CR-06-01997 Water Contamination of Main Turbine Generator 04/20/2006 I Lube Oil

15. CR-08-43109 Elevated Particle Counts in Oil of Pump Inboard 07/11/2008 Bearing reservoir I

- 60 Relevant Documents Reviewed (cont'd)

Revision I Document Title I Date I 16. CR-08-45042 Elevated Particle Counts in MDFP Bearing Oil 08/18/2008 During the audit, the staff found that:

Elements 1- 5 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 6 of the LRA AMP was consistent with the corresponding element of the GALL Report AMP.

In order to obtain the information necessary to verify w,hether the LRA program element number 6 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In element 6 of the GALL Report AMP it states that water and particle concentration should not exceed limits based on equipment manufacturer's recommendations or industry standards. Additionally, the GALL Report states that phase-separated water in any amount is not acceptable. Water contamination of oil can cause an environment that is conducive to loss of material or reduction of heat transfer. Areas of stagnant oil flow are susceptible to water accumulation that has the potential to go undetected with standard industry testing techniques. Describe what steps are being taken to detect for the presence of phase-separated water in lubricating oil systems or justify the preventative actions taken, in lieu of testing, to prevent such an occurrence from happening.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base 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 USAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

- 61 Based on this audit the staff:

Verified that LRA program elements 1-5 are consistent with corresponding program elements in the GALL Report AMP while identifying certain aspects of LRA program element 6 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the USAR Supplement is an adequate description of the program.

Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP B.2.27, Masonry Wall Inspection Program In the LRA, the applicant states that AMP B.2.27, "Masonry Wall Inspection," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.S5, "Masonry Walls." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER. A brief summary of the enhancements is included below and the adequacy of each enhancement is discussed in the SER.

The first enhancement affects LRA program element 1. This enhancement expands on the existing program element by adding a list of structures within the scope of license renewal that credit the Masonry Wall Inspection Program for aging management.

The second enhancement affects LRA program element 5. This enhancement expands on the existing program element by adding the documentation requirements of 10 CFR 54.37, including the submittal of records of structural evaluations to records managements.

The third enhancement affects LRA program element 6. This enhancement expands on the existing program element by adding guidance that observed degradation must be evaluated to ensure that the current evaluation basis is still valid. Corrective action is required if the degradation is sufficient to invalidate the evaluation basis.

In Table A-1, item 12 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 staff also conducted an independent search of the applicant's operating experience database using the keywords: "spalling,"

"degradation," "cracking," and "concrete."

- 62 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 Revision I Document Title Date

1. LRPD-05, Aging Management Program Evaluation Results I Revision 1

• Attachment 3.8 - Masonry Wall Inspection i

2. LRPD-04 i Operating Experience Review Results and . Revision 2 Summary i 8/23/2010

3. EN-DP-01511 Guidelines for Maintenance Rule Evaluation of Revision 0 Structures

4. NOP-ER-3004 FENOC Maintenance Rule Program Revision 1

5. MS DG-26.0 i Maintenance Rule Evaluation Worksheet 03/11/2008

!

• Attachment A . Turbine Building - North Vestibule, Elev. 585, i

Room 330

16. MS DG-26.0 Maintenance Rule Evaluation Worksheet 08/04/2006

• Attachment A  ! Auxiliary Building - Corridor to Mechanical i Penetration Room #3, Elev. 585, Room 304

7. CR-03-07502 Deteriorating Concrete Block in Room 318 09/09/2003 i 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 1-3, and 5 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 of the LRA AMP were consistent with the corresponding element of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program elements 4 and 6 are consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In element 4 of the LRA AMP basis document it states that inspection frequencies can vary between 4 to 8 years depending on the location and environment, susceptibility to degradation, and the age of the structure. In the GALL Report AMP it states that in general masonry walls should be inspected every five years, with provision for more frequent inspections based on operating experience. It is not clear to the staff that these statements are consistent because the LRA AMP inspection interval is longer than the GALL recommended interval and no technical justification for the extension is provided in the LRA.

In element 6 of the LRA AMP basis document it states that acceptance criteria are established such that corrective actions are initiated prior to a loss of function. The GALL Report AMP states that corrective actions should be taken if the extent of cracking and steel degradation is sufficient to invalidate the evaluation basis. It is not clear to the

- 63 staff that these statements are consistent because the LRA AMP does not provide any guidance related to what type or extent of degradation would lead to corrective actions or a reevaluation.

During the audit of program element 10, 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 USAR 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 USAR Supplement is an adequate description of the program.

EXisting Program consistent with GALL with Exceptions and/or Enhancements LRA AMP 8.2.30, One-Time Inspection In the LRA, the applicant states that AMP B.2.30, "One-Time Inspection," is a new program with enhancements that is consistent with the program elements in GALL Report AMP XI.M32, "One-Time Inspection." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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 to the program affects LRA program element 1. This enhancement expands on the existing program element by including visual inspections to detect and characterize the material condition of aluminum, copper alloy (including copper alloy> 15%

zinc), stainless steel, and steel (including gray cast iron) components exposed to condensation or diesel exhaust. The one-time inspections will provide direct evidence as to whether, and to

- 64 what extent, cracking, loss of material, or reduction in heat transfer has occurred. Materials in these environments are either plant-specific or not addressed by another aging management program, or a plant-specific program is identified in NUREG-1801.

The second enhancement to the program affects LRA program elements 1, 3, and 4. This enhancement expands on these existing program elements by including visual and physical examination, such as manipulation and prodding, of elastomers (flexible connections). This visual and physical examination will supplement the External Surfaces Monitoring Program and provide direct evidence as to whether, and to what extent, hardening and loss of strength due to thermal exposure, ultraviolet exposure, and ionizing radiation of elastomers has occurred. This enhancement is in response to recent NRC concerns (raised during license renewal audits) that visual examination may not be adequate to identify hardening and loss of strength for elastomers prior to a loss of function.

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: "corrosion,"

"degradation," "rust," "inspection," and "pitting."

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 Revision I Document Title i Date i 1. LRPD-05 Aging Management Program Evaluation Results Revision 1 I Attachment 2.11 One-Time Inspection . Not dated i 2. CR-03-08419 Condition Report No Rev. #

10102/2003 3.CR-04-06353 Condition Report No Rev. #

10/14/2004

4. CR-04-02983 Condition Report No Rev. #

04/28/2004

5. CR-05-00293 i Condition Report No Rev. #

I 01/17/2005 The staff conducted its audit of LRA program elements 1-6 based without considering aspects of program elements 1, 3, and 4 affected by the enhancements. The staff's evaluation of the aspects of elements 1, 3, and 4, associated with the enhancements will be addressed in the SER. Aspects of these elements not associated with the enhancements were evaluated and are described below.

- 65 During the audit, the staff found that:

Elements 2, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether elements 1, 3, and 4 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program elements 1, 3, and 4 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing an RAI for the following subjects:

The LRA states that a one-time inspection program will be used to manage the aging effects of elastomers instead of using a program with periodic inspections such as recommended by GALL. In element 1, 3, and 4 of the LRA AMP it states that the inspections will include visual and physical examinations that include manipulation and prodding of elastomers. However, it is not clear to the staff that a one-time inspection program will adequately manage the aging effects of elastomers. It is not clear to the staff how aging effects will be managed for inaccessible elastomeric products which are not accessible for physical manipulation to detect loss of ductility and aging effects specific to elastomeric materials.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base 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 USAR 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 2, 5, and 6 and aspects of elements 1, 3, and 4 are consistent with the corresponding program elements in the GALL Report. The staffs evaluation of the aspects of elements 1, 3, and 4, associated with the enhancements will be addressed in the SER.

Identified certain aspects of LRA program elements 1, 3, and 4 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and

- 66 Verified that the description provided in the USAR Supplement is an adequate description of the program.

Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP B.2.31, Open-Cycle Cooling Water Program In the LRA, the applicant states that AMP XI,M20, "Open-Cycle Cooling Water," is an existing program with an exception that is consistent with the program elements in GALL Report AMP XI,M20, "Open-Cycle Cooling Water System." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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 5. In the GALL Report AMP, this program element recommends that testing and inspections are done annually and during refueling outages.

Alternatively, this program element in the LRA states, inspection frequencies are based on operating conditions and past history in accordance with Generic Letter 89-13.

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: "biofoul,"

"cavitation," "degradation," "microbiological," and "corrosi."

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 Revision /

Document Title I Date

. 1. LRPD-05, Open-Cycle Cooling Water Program Revision 1 Attachment 2.12 8/13/2010

2. SWRPM NRC Generic Letter 89-13 Service Water Revision 0 Reliability Program Manual 7/29/2004 l3. NRC GL 89-13 Service Water System Problems Affecting Revision 0 Safety Related Equipment 7/18/1989

14. SN 1-904 Response to Generic Letter 89-13, Service No Revision i

Water System Problems Affecting Safety #

Related Equipment 1/30/1990

5. SN 1-966 Final Response to Generic Letter 89-13, Service i No Revision I ~2/23/1991 Water System Problems Affecting Safety Related Equipment

- 67 Relevant Documents Reviewed (cont'd)

Revision I Document Title Date

6. SN 1-1022 . Supplemental Response to Generic Letter 89 No Revision i 13, Service Water System Problems Affecting #

• Safety Related Equipment 9/9/1993

7. SN 2678 Commitment Change Summary Report No Revision I

11/15/2000 I

8. DB-CH-06900 Operational Chemical Control Limits Revision 31 812012009

9. CR 09-59292 ECCS Room Cooler # 2 Shows Marginal Signs No Revision I of Biofouling #

5/15/2009

10. CR 08-34301 i Low UT Thickness Reading on Service Water to No Revision i

IAFW #

1/25/2008 I

11. CR 08-33590 I 15RFO - Silt Found in the AFW Train 2 Supply No Revision i I Piping #

1/16/2008 112. CR 07-24287 SW Piping Wall Thickness Found Below Mill No Revision Tolerance Acceptance Criteria #

i 7/27/2007

13. CR 03-06576 CATI-Auxiliary Feedwater Components Should No Revision be in GL 89-13 Program #

8/14/2003 During the audit, the staff found that:

Elements 2, 3, 4, and 6 are consistent with the corresponding elements of the GALL Report AMP.

Aspects of element 5 not associated with the exception are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the aspects of element 5 associated with the exception will be addressed in the SER; and Sufficient information was not available to determine whether element 1 of the LRA AMP is consistent with the corresponding element of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program element 1 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing an RAI for the following subject:

In element 1 of the LRA AMP it states that copper alloy with greater than 15% zinc will be managed for cracking. In the GALL Report AMP it states that the Open Cycle Cooling Water Program addresses the aging of material loss and fouling due to micro- or macro-organisms and various corrosion mechanisms generally found in the open cycle cooling water system. It is not clear to the staff that these statements are consistent

- 68 because the LRA did not provide additional information on how cracking would be managed.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base 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 USAR 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 2, 3, 4, and 6 and aspects of LRA program element 5 not associated with the exception are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of the aspects of element 5 associated with the exception will be addressed in the SER; Identified certain aspects of LRA program element 1 for which additional information is required before consistency can be determined.

Verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging; and Verified that the description provided in the USAR Supplement is an adequate description of the program Existing Program consistent with GALL LRA AMP 8.2.33, PWR Water Chemistry Program In the LRA, the applicant states that B.2.33, "PWR Water Chemistry Program," is an existing program that is consistent with the program elements in GALL Report AMP XI.M2, "Water Chemistry." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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 data base search of the applicant's operating experience database using the keywords: "corrosion,"

"cracking," and "pitting."

- 69 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 Revision I I Document Title i Date

1. LRPD-05, PWR Water Chemistry Program Revision 2 Attachment 2.6a . 08/05/2010

2. DBPM-CHEM- Primary System Strategic Water Chemistry Plan Revision 3 0001 09/05/2008

3. DBOM-CHEM- Secondary System Strategic Water Chemistry Revision 4 0002 i Plan 02/12/2009

4. DB-CH-06900 I Operational Chemical Control Limits Revision 31 08/20/2009 II

5. EPRI 1014986 Pressurized Water Reactor Primary Water Revision 6

• Chemistry Guidelines, Volume 1 12/2007 i

6. EPRI1014986 I Pressurized Water Reactor Primary Water Revision 6 i

• Chemistry Guidelines, Volume 2 12/2007 I i

7. EPRI1016555 Pressurized Water Reactor Secondary Water Revision 7 Chemistry Guidelines 02/2009 8, DB-SA-09-052 Snapshot Assessment Plan, EPRI Secondary I No Revision Water Chemistry Guidelines Implementation i#

I I 07/2009

. 9.CR 09-56959

• Pressurizer Dissolved Oxygen Exceeds I No Revision i Specification ,#

I 04/08/2009 110. CR 08-50175 Spent Fuel Pool Sulfate Exceeds High Limit I No Revision

I i 11/26/2008 During the audit, the staff found that:

Elements 1, 2, 4, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether element 3 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program element 3 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing an RAI for the following subject:

In element 3 of the LRA AMP, it states that the PWR Water Chemistry Program is consistent with the Revision 5 of the EPRI Pressurized Water Reactor Secondary Water Chemistry Guidelines. In the GALL Report AMP, it states that the Water Chemistry Program relies on the EPRI PWR Secondary Water Chemistry Guidelines Revision 7. It

- 70 is not clear to the staff that these statements are consistent because the applicant is stating that it is using an older version of the EPRI PWR Secondary Water Chemistry Guidelines.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base 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 USAR 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. 2, 4, 5, and 6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program element 3 for which additional information or additional evaluation is required before consistency can be determined; Verified that the operating experience is sufficient to indicate that the lRA AMP, as implemented by the applicant. is sufficient to detect and manage; and Verified that the description provided in the USAR Supplement is an adequate description of the program.

Existing Program consistent with GAll with Exceptions and/or Enhancements lRA AMP 8.2.34, Reactor Head Closure Studs Program In the lRA, the applicant states that AMP B.2.34. "Reactor Head Closure Studs Program," is an existing program which. with enhancements. will be 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, program element 10 and the description of the programs as contained in the U SAR Supplement.

Program elements 7-9 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 enhancement proposed by the applicant affects LRA program element 2. This enhancement expands on the existing program element by adding the selection of an alternate stable lubricant that is compatible with the fastener material and the environment. A specific precaution against the use of compounds containing sulfur (sulfide). including molybdenum disulfide, as a lubricant for the reactor head closure stud assemblies will be included in the

- 71 program. In Table A-1 of Appendix A of the LRA, the applicant committed to implement this enhancement prior to the period of extended operation.

During the 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 such as: "bolt," "closure stud," "stress corrosion cracking", and "inspection."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were either provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Revision I I Document Title Date

! 1. LRPD-05, Reactor Head Closure Studs Program Revision 2 I Attachment 1.5 08/18/2010 i 2. NOP-ER-2001 Boric Acid Corrosion Control Program Revision 8 I 08/31/2009 i 3. RHCS.06 Davis-Besse Nuclear Power Station Unit #1 Revision 4 I Third Ten Year Inservice Inspection Program 05/13/2008

14. DB-MM-09089 Reactor Vessel Head Stud Removal and Revision 3 Reinstallation Mechanical Maintenance 02/21/2008 Procedure

5. L-08-136 Davis-Besse Nuclear Power Station Cycle 15 04/29/2008 and Refueling 15 Inservice Inspection Summary Report

6. CR 02-03316 Corrosion Report - Reactor Vessel Flange 07/19/2002 Corrosion The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancement.

During the audit, the staff found that:

Elements 1, 3, 4, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether element 2 of the LRA AMP was consistent with the corresponding element of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program element 2 is consistent with the corresponding element of the GALL Report AMP, the staff will consider issuing an RAI for the following subject:

The preventive actions program element of GALL, Rev. 2, AMP XI.M3, "Reactor Head Closure Stud Bolting," references the guidance outlined in RG 1.65 and NUREG-1339, RG 1.65, "Materials and Inspection for Reactor Vessel Closure

- 72 Studs," and NUREG-1339, "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants." AMP XI,M3 preventive actions includes using bolting material for closure studs that has measured yield strength less than 150 ksi. During its audit, the staff noted that LRPD-05, Attachment 1.5 states that the reactor head closure studs and nuts are manufactured from S-540, Grade 23 material. The LRA AMP does not include the preventative action for using stud materials with an actual measured yield strength level less than 150 ksi.

During the audit of program element 10, 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 USAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, it is 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 USAR Supplement is an adequate description of the program.

New Program consistent with GALL LRA AMP 8.2.36, Selective Leaching Inspection In LRA, the applicant states that AMP B.2.36, "Selective Leaching Inspection," 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 prior to the period of extended operation in LRA Table A-l, Commitment No. 18. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER

- 73 During the 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: "leach," "copper,"

"zinc."

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 Revision I Document Title Date

11. LRPD-05 Aging Management Program Evaluation Results Revision 1 i Attachment 2.13 for Selective Leaching Inspection 08/20/2010 I 2. CR-09-59363 Eddy Current Results on #3 TPCW Heat I No Revision

!

Exchanger E8-3 05/18/2009

/3. CR-07-18763 Tube Thinning Found on Turbine Plant Cooling No Revision Water Heat Exchanger E8-3 04/19/2007 During the audit, the staff found that:

Elements 1, 2, 3, 5, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and Sufficient information was not available to determine whether element 4 of the LRA AMP was consistent with the corresponding element of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program element 4 is consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In element 4 of the LRA AMP it states that the selective leaching inspection activities will be conducted just before the period of extended operation. In the GALL Report AMP it states that the inspection is conducted within the last five years prior to the period of extended operation. It is not clear to the staff that these statements are consistent because it is not clear when the selective leaching inspection activities will be conducted relative to the period of extended operation.

In element 4 of the LRA AMP it states that the selective leaching inspection activities include determination of the sample size based on an assessment of materials of fabrication, environment/conditions, time in service, and operating experience, as well as identification of the inspection locations in the susceptible system or component. In the GALL Report AMP it states that the inspection includes a representative sample of the system population with focus on the components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin, and twenty percent of the population with a maximum sample of 25 constitutes a representative sample size. It is not clear to the staff that these statements are consistent because it is

-74 not clear whether the extent and scope of the selective leaching inspection activities are consistent with the GALL AMP XI.M33 recommendation.

During the audit of program element 10, the staff found that:

The operating experience 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 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 will consider issuing an RAI for the following subject:

LRA Section B.2.36 states that the Selective Leaching Inspection Program is a new program that will be consistent with the 10 elements of GALL AMP XI.M33. In element 10 of the LRA AMP it includes a limited discussion of plant-specific operating experience. It is not clear to the staff how a review of future plant-specific and industry operating will be incorporated into the AMP.

The staff also audited the description of the LRA AMP provided in the USAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the USAR Supplement was an adequate description of the LRA AMP.

In order to obtain the information necessary to verify the sufficiency of the USAR Supplement program description, the staff will consider issuing an RAI for the following subject:

SRP Section A.1.2.3.10, "Operating Experience," states that the applicant should commit to a review of future plant-specific and industry operating experience to confirm the effectiveness of its aging management programs. The USAR Supplement does not include a commitment of a review of future plant-specific and industry operating experience. It is not clear to the staff whether the applicant commits to conducting the review or not.

Based on this audit the staff:

Verified that LRA program elements 1, 2, 3, 5, and 6 are consistent with corresponding program elements in the GALL Report AMP while identifying certain aspects of LRA program element 4 for which additional information or additional evaluation is required before consistency can be determined; Identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached;

- 75 Identified a need for additional information regarding the adequacy of the program description in the USAR Supplement New Program consistent with GALL LRA AMP B.2.37, Small Bore Class 1 Piping Inspection In the LRA, the applicant states that AMP B.2.37, "Small Bore Class 1 Piping Inspection," is a new program that is consistent with the program elements in GALL Report AMP XI.M35, "One-Time Inspection of ASME Code Class 1 Small-Bore Piping." The applicant committed to implementing this program on April 22, 2017, in Table A-1 of the LRA. To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the FSAR Supplement. Program elements 7-9 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: "cracking," "socket," and "weld."

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 Revision I Document Title Date

11. LRPD-05 Aging Management Program Evaluation Results Rev. 2

! Attachment 1.7 Small Bore Class 1 Piping Inspection 08/17/2010

2. LRA Davis Besse Nuclear Power Station License  ! No Revision  !

Renewal Application I 08/2010 I

3. LRPD-04 Operating Experience Review Results and I Rev. 2 Summary 08/23/2010

• 4. 02-08782 Condition Report: ASME Sec XI Class 1 P. B. No Revision

. Leak on 1-CCA-3 Line to RC47, Gasket 10/29/2002 Monitoring Line 1 5. 02-08795 Condition Report: ASME Sec XI Class 1 P.B. No Revision Leak on 1-CCA Line to RC46, Gasket 10/29/2002 Monitoring Line I 6. 06-01091 Condition Report: Axial Indication in RCP 1-1 No Revision Cold Leg Drain Line 03/18/2006 During the audit of program elements 1-6, the staff found that:

Elements 1, 2, 3, and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; and

- 76 Sufficient information was not available to determine whether elements 4 and 5 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program elements 4 and 5 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In element 4 of the LRA AMP it states that it has experienced two instances of cracking of small bore Class 1 piping possibly due to stress corrosion or thermal and mechanical loading, and therefore this one-time inspection is appropriate. In the GALL Report AMP it states that the inspection is designed to provide assurance in plants that have not experienced cracking of ASME Code Class 1 small-bore piping due to stress corrosion or cyclical (including thermal, mechanical, and vibration fatigue) loading, that aging of this piping is not occurring, or that the effects of aging are not significant. It is not clear to the staff that these statements are consistent because no information was provided to show the extent of these conditions, that the conditions have been fully mitigated, and that no repeat events have occurred for an extended period of time.

In element 5 of the LRA AMP it states that the one-time inspection will consist of volumetric examination of a representative sample of small bore piping locations that are susceptible to cracking. In the GALL Report AMP it states that "If the applicant has successfully mitigated any failures in its ASME Class 1 piping, the inspection should include 10% of the weld population or a maximum of 25 welds of each weld type (e.g.,

full penetration or socket weld) for each operating unit using a methodology to select the most susceptible and risk-significant welds." It is not clear to the staff that these statements are consistent because the applicant does not have specific information regarding the subject small bore piping weld population, and inspection sampling location and size. This information is required to evaluate consistency with the GALL Report program element.

In element 5 of the LRA AMP it states that the guidelines of EPRI Report 1011955 and the supplemental guidelines of EPRI Report 1018330 will be considered in selecting the sample size and locations for the Small Bore Piping inspections. In the GALL Report AMP it states that cracking resulting from thermal and mechanical loading or intergranular stress corrosion cracking should be managed by this program. It is not clear to the staff that these statements are consistent because no information is provided to show how any of the failure modes outside of thermal fatigue (Le., SCC and mechanical or vibration fatigue) will be considered using only the guidance of EPRI Report 1011955 and the supplemental guidelines of EPRI Report 1018330, or if other guidelines will be used in conjunction with the EPRI reports.

During the audit of program element 10, the staff found that:

The operating experience identified by the staff's independent data base search and supplemented by the applicant is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff);

The operating experience identified by the staff's independent data base search and supplemented by the applicant is sufficient to allow the staff to verify that the LRA AMP,

-77 as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR Supplement was an adequate description of the LRA AMP.

In order to obtain the information necessary to verify the sufficiency of the FSAR Supplement program description, the staff will consider issuing RAls for the following sUbjects:

In Table A-1 of the LRA, commitment 19 states that the Small Bore Piping Program will be implemented on April 22, 2017 which is the start date for the period of extended operations for this site. Table 3.0-1 of the GALL suggests that the one-time inspection of ASME Code Class 1 Small Bore-Piping Program should be implemented prior to period of extended operation. In addition,Section XI.M35 of the GALL states that "The one time inspection should be completed within the six year period prior to the period of extended operation." It is not clear to the staff how the commitment date stated in the LRA will allow them to complete this program prior to the period of extended operations.

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 applicant has committed to modify the FSAR Supplement so as to make the program description adequate.

Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP B.2.38, Steam Generator Tube Integrity Program In the LRA, the applicant states that AMP B.2.38, "Steam Generator Tube Integrity Program," is an existing program that is consistent with the program elements in GALL Report AMP XI.M19, "Steam Generator Tube Integrity Program." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and 10 and the description of the program as contained in the FSAR Supplement. Program elements 7-9 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 data base search of the applicant's operating experience database using the keywords: "stress corrosion cracking,"

"pitting," "wear," "rupture," "leak," and "corrosion."

- 78 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 Revision I Document Title Date

1. EPRI Report In-situ Pressure Test Guidelines Revision 3 TR-1014983

. 2. EPRI Report PWR Primary to Secondary Leak Guidelines Revision 3 i TR-1008219

3. NE197-06 Steam Generator Program Guidelines Revision 2

4. Regulatory Basis for Plugging Degraded PWR Steam Revision 1 Guide 1.121 Generator Tubes

• 5. DBPM-SGMP Steam Generator Management Program Manual Revision 11 PE-001

6. NOP-ER-2002 Steam Generator Management Program Revision 6

7. NOP-WM-4001 Foreign Materials Exclusion Revision 9

8. DB-PF-05058 Steam Generator Eddy Current Data Analysis Revision 8 Guidelines

9. CR-08-33469 15RFO OTSG Eddy Current Examination 01/15/2008 Identified Defects in the OTSG Tubing

10. CR-05-00963 OTSG 14 Mid-Cycle Eddy Current Results 01/31/2005

11. CR-03-09776 BWOG Notified of Cracking of Cold Leg Once 11/13/2003 Through Steam Generator (OTSG) Alloy 600 Tubing Experience

12. DB-SA-07-084 Snapshot Assessment DB-SA-07 -084 Report 12/21/2007

13. SA2004-0107 Focused Self Assessment Report 12/22/2004

14. EPRI Report Steam Generator Management Program: Steam Revision 3 TR-1019038 Generator Integrity Assessment Guidelines During the audit of program elements 1-6, the staff found that:

Sufficient information was not available to determine whether elements 1, 2, 3, 4, 5 and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program elements 1-6 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subject:

The staff has identified potential inconsistencies between NEI 97-06, Revision 2 and the standard steam generator technical speCifications which the applicant has adopted (through its adoption of TSTF-449). These inconsistencies were discussed in a public meeting on September 16, 2009 (refer to meeting summary dated October 6,2009 (ML092820119). Please confirm that your steam generator aging management program

- 79 has addressed these potential inconsistencies between NEI 97-06 and your technical specifications.

During the audit of program element 10, the staff found that:

The operating experience provided by the applicant and identified by the staff's independent data base 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 data base search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage aging effects during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Based on this audit the staff:

Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 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 FSAR Supplement is an adequate description of the program.

Existing Program consistent with GALL with Exceptions and/or Enhancements LRA AMP 8.2.39, Structures Monitoring Program In the LRA, the applicant states that AMP 8.2.39, "Structures Monitoring Program," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI,S6, "Structures Monitoring Program." To verify this claim of consistency the staff audited the LRA AMP. This audit report considers program elements 1-6 and the description of the program as contained in the USAR Supplement. Program elements 7-9 are audited as part of the scoping and screening methodology audit. Issues identified but not resolved in this report are addressed in the SER. A brief summary of the enhancements is included below and the adequacy of each enhancement is discussed in the SER.

The first enhancement affects LRA program element 1. This enhancement expands on the existing program element by adding clarification to the following structures: Borated Water Storage Tank Foundation; Diesel Oil Storage Tank Foundation; Duct banks, cable and pipe trenches, and manholes located in the Yard; Emergency Diesel Generator Fuel Oil Storage Tanks Foundation; Fire Hydrant Hose Houses and Foundations; Fire Walls between Bus-Tie

- 80 Transformers, between Bus-Tie and Startup Transformer 01, and between Auxiliary and Main Transformers; Fire Water Storage Tank Foundation; Miscellaneous Diesel Generator Building Fire Wall; Service Water Discharge Structure; Station Blackout (SBO) Component Foundations and Structures in the Yard and Switchyard (Startup Transformers 01 and 02, Bus-Tie Transformers, 345kV Switchyard circuit breakers ACB34560, ACB34561, ACB34562, ACB34563, ACB34564, air break switch ASB34625, Relay House, "J" and "K" buses); and SBO Diesel Generator Building (including Transformer X-3051 Foundation and Radiator Skid Foundation) .

The second enhancement affects LRA program element 3. This enhancement expands on the existing program element by including aging effect terminology (e.g., loss of material, cracking, change in material properties, and loss of form).

The third enhancement affects LRA program element 3. This enhancement expands on the existing program element by listing ACI 349.3R-96, "Evaluation of Existing Nuclear Safety Related Concrete Structures," and ANSIIASCE 11-90, "Guideline for Structural Condition Assessment of Existing Buildings," as references and to indicate that they provide guidance for the selection of parameters monitored or inspected.

The fourth enhancement affects LRA program element 3. This enhancement expands on the existing program element by providing clarification that a "structural component" for inspection includes each of the component types identified within the scope of license renewal as requiring aging management.

The fifth enhancement affects LRA program element 3. This enhancement expands on the existing program element by noting that the Structures Monitoring Program procedure will be enhanced by requiring the responsible engineer to review site raw water pH, chlorides, and sulfate test results prior to the inspection to take into account the raw water chemistry for any unusual trends during the period of extended operation. Raw water chemistry data shall be collected at least once every five years. Data collection dates shall be staggered from year to year (summer-winter-summer) to account for seasonal variation.

The sixth enhancement affects LRA program element 3. This enhancement expands on the existing program element by adding a special provision to monitor below-grade inaccessible concrete components before and during the period of extended operation. A below-grade examination of an in-scope concrete structure below EI. 570 (groundwater elevation) will be performed prior to the period of extended operation and evaluated using acceptance criteria from NUREG-1801, XI. S6 Program Element 6.

The seventh enhancement affects LRA program element 3. This enhancement expands on the existing program element by specifying that, upon notification that a below-grade concrete structural wall or other in-scope concrete structural component will be accessible through excavation, a follow-up action is initiated to the responsible engineer to inspect the exposed surfaces for age-related degradation using acceptance criteria from NUREG-1801, XI.S6 program element 6.

The eighth enhancement affects LRA program element 4. This enhancement expands on the existing program element by listing ACI 349.3R-96, "Evaluation of Existing Nuclear Safety Related Concrete Structures," ANSIIASCE 11-90, "Guideline for Structural Condition

- 81 Assessment of Existing Buildings," and EPRI Report 1007933, "Aging Assessment Field Guide,"

as references and to indicate that they provide guidance for detection of aging effects.

The ninth enhancement affects LRA program element 5. This enhancement expands on the existing program element by including requirements to follow the documentation requirement of 10 CFR 54.37 and to submit records of structural evaluations to records management.

The tenth enhancement affects LRA program element 6. This enhancement expands on the existing program element by indicating that ACI 349.3R-96, "Evaluation of Existing Nuclear Safety-Related Concrete Structures," provides acceptable guidelines which will be considered in developing acceptance criteria for concrete structural elements, steel liners, joints, coatings, and waterproofing membranes.

In Appendix A, Table A3 of the LRA, the applicant committed to implement these enhancements prior to April 22, 2017.

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: "age or aging,"

"base," "blister/blistering," "boric acid," "brittle," "chloride," "coating," "concrete," "crack,"

"crevice," "damage," "degraded or degradation," "duct," "expansion jOint," "fastener," "fracture,"

"freeze-thaw," "groundwater," "insulation," "liner," "moisture," "pit," "rust," "seal," "settlement,"

"sulfate," and "water intrusion."

The table below lists the documents which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed

!

Revision I Document Title I Date

11. LRPD-05 Aging Management Program Evaluation Results Revision 1

! - Structures Monitoring Program 08/19/2010

2. DBE-10-0046 Cycle 16 Periodic Assessment for Maintenance Revision 0 Rule Evaluations of Structures OS/24/2010

3. EN-DP-01511 Design Guidelines for Maintenance Rule Revision 00 I Evaluation of Structures

! 4. NRPM27 Maintenance Rule Program Manual Revision 27 l 07/27/2009

15. NOP-ER-3004 FENOC Maintenance Rule Program Revision 1 03/04/2009

! 6. NOP-OP-2012 Groundwater Monitoring Revision 03 I

03/06/2009

7. LRPI*05 Structural Screening and Aging Management Revision 1 Review 04/22/2010

8. SL-008105 Davis-Besse Nuclear Power Station Engineering I Revision 0 Assessment Report Refuel Canal Leakage 06/2003

- 82 Relevant Documents Reviewed (cont'd)

Revision I Document Title Date

9. HI-992333 Structural Evaluation for Davis-Besse Spent Revision 0 Fuel Pool 09/13/2001 i The staff conducted its audit of LRA program elements 1-6 based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff found that:

Elements 1, 2, and 5 (scope, preventative actions, and monitoring and trending) of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP; In order to obtain the information necessary to verify whether the LRA program elements 3, 4, and 6 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In element 3 of the LRA AMP it states the chemical parameters of the groundwater are

=

considered to be aggressive (Le., chlorides 2780 ppm (max) and sulfates 1700 ppm =

(max)). In the GALL Report AMP it states that for plants with aggressive groundwater/soil (pH < 5.5, chlorides> 500 ppm, and sulfates> 1500 ppm) and/or where the concrete structural elements have experienced degradation a plant-specific AMP accounting for the extent of degradation should be implemented to manage aging during the period of extended operation. It is not clear to the staff how the Structures Monitoring Program, or other plant-specific program, will address aggressive groundwater infiltration to ensure that the resulting effects, especially in inaccessible areas, will be managed during the period of extended operation.

In element 4 of the LRA AMP it states that the structures are periodically monitored to identify degradation that could impair the functional performance of the structure by a Maintenance Rule Walkdown Team consisting of at least two individuals that are degreed engineers, or equivalent, and have at least five years experience in civil/structural engineering activities, or as determined by the Mechanical/Structural supervisor. In the GALL Report AMP it states that inspector qualifications are to be commensurate with industry codes, standards, and guidelines, with ACI 349.3R-96 and ANSI/ASCE 11-90 identified as providing an acceptable basis for addressing aging effects. It is not clear to the staff that qualifications of the inspection personnel are commensurate with industry codes, standards, and guidelines (e.g., Section 7 of ACI 349.3R-96).

In element 4 of the LRA AMP it states that concrete structures are periodically monitored at a frequency that can vary between 2 and 10 years through visual inspections to identify degradation that could impair the functional performance of the structure. In the GALL Report AMP structures within the scope of license renewal should be monitored on a frequency not to exceed 5 years. It is not clear to the staff that the concrete structures inspected on a frequency greater than 5 years are located in an environment,

- 83 or exhibit operational experience, that supports an inspection frequency greater than 5 years.

In element 6 of the LRA AMP it states that the inspection criteria used to assess the condition of the structures and structural components are found in the Maintenance Rule evaluation procedure for the Maintenance Rule Evaluation of Structures and plant basis documentation identifies acceptance criteria as: Y (Yes - Structure/Area/Room is acceptable), N (No - condition is not acceptable), U (unknown if condition is acceptable or not), and NA (not applicable for particular item). In the GALL Report AMP inspection programs for structures within the scope of license renewal should include quantitative limits with Chapter 5 of ACI 349.3R-96 listed as providing adequate acceptance criteria for concrete structures. It is not clear to the staff what quantitative acceptance criteria are utilized to assess the condition of the structures, and how the criteria relate to the criteria provided in Chapter 5 of ACI 349.3R-96.

During the audit of program element 10, 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 will consider issuing RAls for the following subjects:

Refueling Cavity Leakage A review of program basis documentation noted that during Maintenance Rule Evaluation of Structures inspections boric acid deposit indications were identified on the concrete and structural members below the elevation of the refueling cavity that apparently were coming from the reinforced concrete construction joints and shrinkage cracks. The staff is unclear that the effects of refueling cavity leakage on the containment internal structures have been adequately addressed and that the possible aging effects will be properly managed during the period of extended operation.

Spent Fuel Pool Leakage A review of plant basis documentation noted that during Maintenance Rule Evaluation of Structures inspections water had been noted to leak from the spent fuel pool, travel through the surrounding concrete, and appear in the ECCS pump room #1. During the walk down indications of cracking and staining were observed on the underside of the spent fuel pool and transfer pit (ceiling of Room 109). The staff is unclear that leakage of the borated water has not resulted in degradation of either the concrete or embedded

- 84 steel reinforcement of the spent fuel pool and that the possible aging effects will be properly managed during the period of extended operation.

Inspection of Shield Building during the Period of Extended Operation During a walkdown, indications of spa lied areas in the Shield Building were noted that led to discussions relative to inspection procedures and criteria utilized for the Shield Building. The staff is unclear how inspections of the Shield Building will be performed during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the USAR Supplement. The staff found this description to be consistent with the description provided in the SRP-LR and, therefore, acceptable.

Based on this audit the staff:

Verified that most of the LRA program elements 1-6 are consistent with the corresponding program elements in the GALL Report while identifying certain aspects of LRA program elements 3, 4, and 6 for which additional information or additional evaluation is required before consistency can be determined; Identified that additional information regarding operating experience is required before an indication regarding the sufficiency of the LRA AMP, as implemented by the applicant, to detect and manage aging can be reached; and Verified that the description provided in the USAR Supplement is an adequate description of the program.

Existing Program consistent with GALL with Exceptions and Enhancements LRA AMP B.2.40, Water Control Structures Inspection In the LRA, the applicant states that AMP B.2.40, "Water Control Structures Inspection," is an existing program with enhancements and exceptions that is consistent with the program elements in GALL Report AMP XI.S7, "RG 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 and 10 and the description of the program as contained in the USAR Supplement. Program elements 7-9 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. A brief summary of the enhancements and exceptions is included below and the adequacy of each enhancement and exception is discussed in the SER.

The first enhancement affects LRA program element 1. This enhancement expands on the existing program element by adding the service water discharge structure to the scope of the program.

The second enhancement affects LRA program element 3. This enhancement expands on the existing program element by adding parameters monitored to the program in accordance with

- 85 guidance provided in Section C.2 of RG 1.127 and ACI 201, "Guide for Making a Condition Survey of Concrete in Service."

The third enhancement affects LRA program element 4. This enhancement expands on the existing program element by adding requirements that water control structure periodic inspections are performed at least once every five years.

The fourth enhancement affects LRA program element 5. This enhancement expands on the existing program element by adding requirements to follow the documentation requirements of 20 CFR 54.37, including submittal of records and structural evaluations to records management.

The fifth enhancement affects LRA program element 6. This enhancement expands on the existing program element by adding ACI 349.3R-96, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" as a reference that will be considered when developing acceptance criteria for water control structures.

In Table A-1, item 21 of the LRA, the applicant committed to implement these enhancements prior to the period of extended operation.

The first exception affects LRA program elements 1, 3, and 4. In the GALL Report AMP, this program element recommends inspecting dams, spillway structures, reservoirs and safety and performance information for applicable aging effects. Alternatively, these program elements in the LRA state, that the associated program structural elements are not installed at Davis-Besse; therefore, the associated portions of the GALL Report program are not applicable.

The second exception affects LRA program element 4. In the GALL Report AMP, this program element recommends that acceptance criteria for earthen structures are consistent with programs falling within the jurisdiction of the Federal Energy Regulatory Commission (FERC) or U.S. Army Corps of Engineer programs. Alternatively, this program element in the LRA states that the earthen structures at the plant do not fall within the jurisdiction of FERC or the US Army Corps of Engineers; therefore, the associated portions of the GALL Report program are not applicable.

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: "degradation,"

"earthen," "spalling," "cracking," and "concrete."

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 Revision I Title Date

1. LRPD-05, Aging Management Program Evaluation Results Revision 1 .6 - Water Control Structures Inspection

- 86 Relevant Documents Reviewed (cont'd)

Revision I Document Title Date

2. LRPD-05, Aging Management Program Evaluation Results Revision 1

. Attachment 2.3 - Bolting Integrity Program

3. LRPD-04 Operating Experience Review Results and Revision 2 Summary 08/23/2010

4. EN-DP-01511 Guidelines for Maintenance Rule Evaluation of Revision 0 Structures

• 5. NOP-ER-3004 FENOC Maintenance Rule Program Revision 1

6. MS DG-26.0 Maintenance Rule Evaluation Worksheet 03/11/2008 Attachment A

• Turbine Building - North Vestibule, Elev. 585, I Room 330

7. DG-26 Design Guidelines for Maintenance Rule Revision 5 Evaluation of Structures 05/12/2006

8. CR 07-26185 Degradation Found on Rip-Rap Sides of the 09/06/2007 Forebay and Intake Canal

• 9. CR 02-08036 Water Seepage Into Circ Water Return Canal 10/14/2002

10. ER 1110-2-106 Department of the Army, Office of the Chief of 09/26/1979 Appendix D Engineers Recommended Guidelines for Safety Inspection of Dams 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 1,3,4 and 6 of the LRA AMP associated with the exceptions were not evaluated during this audit.

Aspects of these program elements that are not associated with the exceptions were evaluated and are described below During the audit, the staff found that:

Elements 2 and 5 of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP, and the aspects of elements 1 and 3 not associated with the exceptions are consistent with the corresponding program elements in the GALL Report.

The staff's evaluation of the aspects of elements 1, 3, 4 and 6 associated with the exceptions will be addressed in the SER; and Sufficient information was not available to determine whether elements 4 and 6 of the LRA AMP were consistent with the corresponding elements of the GALL Report AMP.

In order to obtain the information necessary to verify whether the LRA program elements 4 and 6 are consistent with the corresponding elements of the GALL Report AMP, the staff will consider issuing RAls for the following subjects:

In the LRA AMP it states that the site groundwater is aggressive and that a below-grade examination of concrete below the groundwater elevation will be conducted prior to the period of extended operation. In the GALL Report AMP it states that a plant-specific AMP should be implemented to manage concrete exposed to aggressive groundwater.

- 87 It is not clear to the staff that the planned inspection is sufficient to manage aging of concrete exposed to aggressive groundwater during the period of extended operation.

In element 6 of the LRA AMP it states that ACI 349.3R-96, "Evaluation of Existing Nuclear Safety-Related Concrete Structures" will be listed as a reference and considered in developing inspection acceptance criteria. In the GALL Report AMP it states that plant-specific acceptance criteria based on ACI 349.3R are acceptable. It is not clear to the staff that these statements are consistent because the applicant will only use the recommended document as a reference when creating the program acceptance criteria. If the applicant's acceptance criteria are going to vary from the recommended criteria, adequate technical justification should be provided.

During the audit of program element 10, 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 will consider issuing RAls for the following subjects:

In element 10 of the LRA AMP, the applicant described degradation of the intake canal earthen embankments due to settlement identified in 2007. The application and basis documents did not provide sufficient documentation of the corrective actions taken since 2007 and any planned corrective actions. The staff will consider issuing an RAI to address how the embankment degradation has been addressed and how the integrity of the embankment will be ensured during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the USAR 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 2 and 5, and aspects of LRA program elements 1 and 3 not associated with the exceptions, are consistent with the corresponding program elements in the GALL Report. The staff's evaluation of aspects of elements 1, 3, 4 and 6 associated with the exceptions will be addressed in the SER; Identified certain aspects of LRA program elements 4 and 6 for which additional information or additional evaluation is required before consistency can be determined;

- 88 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 USAR Supplement is an adequate description of the program.

June 1,2011 Mr. Barry S. Allen Vice President, Davis-Besse Nuclear Power Station FirstEnergy Nuclear Operating Company 5501 North State Route 2 Oak Harbor, OH 43449

SUBJECT:

AUDIT REPORT REGARDING THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640)

Dear Mr. Allen:

By letter dated August 27,2010, FirstEnergy Nuclear Operating Company (FENOC), 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-3 for the Davis-Besse Nuclear Power Station (DBNPS).

On February 25, 2011, the staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) completed the onsite audit of aging management programs. The audit report is enclosed.

If you have any questions, please contact me by telephone at 301-415-2277 or bye-mail at brian.harris2@nrc.gov.

Sincerely, IRA!

Brian K. Harris, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

As stated cc w/encl: Listserv DISTRIBUTION:

See next page ADAMS Accession No ML11122A014 OFFICE: LA:DLR PM:RPB1 :DLR BC:RPB1 :DLR PM:RPB1 :DLR NAME: YEdmonds BHarris BPham BHarris DATE: 05/16/2011 05/19/2011 06/01/2011 06/01/2011 OFFICIAL RECORD COpy

Letter to Barry S. Allen from Brian K. Harris dated June 1, 2011

SUBJECT:

AUDIT REPORT REGARDING THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640)

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