ML12101A061

Response to Request for Additional Information Reactor Vessel Internals Inspection Plan Review Request

ML12101A061
Person / Time
Site:	Kewaunee
Issue date:	04/02/2012
From:	Price J Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
12-151, LIC/JG/R0, TAC ME7727
Download: ML12101A061 (65)

Text

Dominion Energy Kewaunee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060 JF~oin ionll April 2, 2012 ATTN: Document Control Desk Serial No.12-151 U. S. Nuclear Regulatory Commission LIC/JG/RO Washington, DC 20555-0001 Docket No.: 50-305 License No.: DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REACTOR VESSEL INTERNALS INSPECTION PLAN REVIEW REQUEST (ME7727)

By application dated December 12, 2011 (reference 1), Dominion Energy Kewaunee, Inc. (DEK), requested NRC approval of an inspection plan for reactor vessel internal (RVI) components at Kewaunee Power Station (KPS). The proposed inspection plan fulfils two commitments required by Renewed Operating License DPR-43, Section 2.C(15)(b), to submit an inspection plan for reactor internals to the NRC staff for review and approval to augment the current inspections.

Subsequently, the Nuclear Regulatory Commission (NRC) staff transmitted a request for additional information (RAI) regarding the proposed inspection plan (reference 2).

Specifically, the staff requested a copy of Aging Management Program Technical Report AMP-KLR-1309A, "ASME Section Xl Inservice Inspection, Subsections IWB, IWC, and IWD Reactor Vessel Internals Inspections, Kewaunee Power Station." The requested report is enclosed with this letter.

If you have questions or require additional information, please feel free to contact Mr.

Jack Gadzala at 920-388-8604.

Very truly yours, J. Ia nc V4ceP esident - Nuclear Engineering

Enclosure:

Aging Management Program Technical Report AMP-KLR-1309A, "ASME Section Xl Inservice Inspection, Subsections IWB, IWC, and IWD Reactor Vessel Internals Inspections, Kewaunee Power Station," Revision 3, dated September 30, 2011.

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Serial No.12-151 RV Internals Inspection Plan Page 2 of 2

References:

1. Letter from J. Alan Price (DEK) to Document Control Desk (NRC), "Reactor Vessel Internals Inspection Plan Review Request," dated December 12, 2011.

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), Craig Sly (DEK), and Ganesh Cheruvenki (NRC), "ME7727 - Kewaunee - Reactor Vessel Internals Inspection Plan review - an Aging Management Program report is needed to prepare RAI items," dated March 2, 2012.

Commitments made by this letter: None cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. Karl D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station

Serial No.12-151 ENCLOSURE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REACTOR VESSEL INTERNALS INSPECTION PLAN REVIEW REQUEST Aging Management Program Technical Report AMP-KLR-1309A, "ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Reactor Vessel Internals Inspections, Kewaunee Power Station,"

Revision 3, dated September 30, 2011 (62 pages)

KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

TECHNICAL REPORT: KLR-1309A LICENSE RENEWAL PROJECT AGING MANAGEMENT PROGRAM ASME SECTION X1 INSERVICE INSPECTION, SUrBSECTIONS IWB, IWC, AND IWD REACTOR VESSEL INTERNALS INSPECTIONS KEWAUNEE POWER STATION Prepared byQD Q4A NRIHARDA. REIMER Date: _ _ _ _

Reviewed by * '

CHARLES, A TOMES Date: .. _ _ _

Reviewed by A w' P LUP E. BUKES Date Approved by., /A. t".4I.

WILL; M..PP Approved by 0- Date:  !,-Z -(i[

PAUL C. AITKEN Approved by ___"_____ . Date:

TIMOTHY P. O.LsON Effective Date: 0913012011.

Revision Number: 3

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS REVISION RECORD Page(s) Revision Revision Change Description Revised Number Date All 0 3/24/2010 Initial Issue Various 1 10/29/2010 DMRs 2758, 2816 Various 2 06/30/2011 Incorporation of MRP-227 Requirements per Charter ER-31 14 3 09/30/2011 Alignment with NRC Letter for Commitments 1 & 2 Page 2 of 62 Rev. 3 KLR-1309A, Rev. 3 Page 2 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS TABLE OF CONTENTS 1.0 P UR PO S E ...................................................................................................... 5 2.0 PRO G RAM DESCRIPTIO N ............................................................................... 5 3.0

SUMMARY

PROGRAM INFORMATION ........................................................... 7 4.0 EVALUATION OF NUREG-1800 AND MRP-227 PROGRAM ELEMENTS ...... 7 4.1 PROGRAM ELEMENT 1 - SCOPE OF PROGRAM ........ ............................................ 8 4.2 PROGRAM ELEMENT 2- PREVENTIVE ACTIONS ................................................. 10 4.3 PROGRAM ELEMENT 3-- PARAMETERS MONITORED/INSPECTED ......................... 11 4.4 PROGRAM ELEMENT 4- DETECTION OF AGING EFFECTS ................................... 11 4.5 PROGRAM ELEMENT 5- MONITORING AND TRENDING ...................................... 15 4.6 PROGRAM ELEMENT 6- ACCEPTANCE CRITERIA .................................................. 16 4.7 PROGRAM ELEMENT 7- CORRECTIVE ACTIONS ................................................. 17 4.8 PROGRAM ELEMENT 8 -- CONFIRMATION PROCESS ............................................... 18 4.9 PROGRAM ELEMENT 9- ADMINISTRATIVE CONTROLS ........................................... 18 4.10 PROGRAM ELEMENT 10 - OPERATING EXPERIENCE .......................................... 19 5.0 PROGRA M ENHANCEMENTS ......................................................................... 19 6.0 PROGRA M EXCEPTIONS ........... ..................................................................

7 20 7.0 C O NC LU S IO N .................................................................................................. . 20 8.0 R E FE R E NC ES ................................................................................................. 20 9.0 ATTA C HMENTS .............................................................................................. 22 Page 3 of 62 KLR-1309A, Rev.Rev. 33 Page 3 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS LIST OF TABLES Table Title Page Table 1 - Comparison to MRP-227 Assumptions ........................................... 13 Table 2 - Reactor Vessel Internals Evaluation ............................................ 23 Table 3 - Aging Management Program Enhancement and Inspection Implementation Schedule ................................................... 41 Table 4 - Detailed MRP-227 Reactor Vessel Internals - Component Inspection Requirem ents ................................................................. 42 LIST OF FIGURES Figure Title Page None Page 4 of 62 Rev. 3 KLR-1309A, Rev. 3 Page 4 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS 1.0 PURPOSE The purpose of the aging management program (AMP) report is to update the basis for the aging management program information summarized in the Kewaunee Power Station (KPS) renewed operating license granted under 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants" (Reference 8.1). The AMP information is applicable to systems, structures, and components (SSCs) that are in-scope, long-lived, passive, and perform a license renewal intended function.

This document implements commitments to the NRC to enhance the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program for managing aging effects on reactor internals and on limiting susceptible cast austenitic stainless steel reactor vessel internals components (Reference 8.7, Section 5.1 and 5.2).

In order to ensure the aging of reactor vessel internal components are adequately managed, the Nuclear Energy Institute initiated a commercial nuclear utility industry Materials Initiative. The result of this effort was NEI 03-08, which was issued through the Nuclear Strategic Issue Advisory Committee (NSIAC) for management of primary pressure boundary materials. NEI 03-08 is classified as a NSIAC initiative, which is a formal agreement by 80% vote of Chief Nuclear Officers and is binding for all US nuclear utilities. To implement the NEI 03-08 requirements, the U.S. industry, through the efforts of the EPRI Materials Reliability Program (MRP) and PWR Owners Group, developed and issued MRP-227 and MRP-228 to identify and document the components and subcomponents that require aging management to support continued reliable operation during the period of extended plant operation.

In addition, a secondary purpose of this AMP is to develop and document a PWR reactor internals aging management program (AMP) as outlined in Appendix A of MRP-227 Rev. 0 and as required by Condition Report 322266 (Reference 8.2).

This document, in conjunction with the integrated plant assessment reports, demonstrates that the effects of aging on identified SSCs will be adequately managed so that the intended function(s) will be maintained consistent with the plant-specific current licensing basis for the period of extended operation.

2.0 PROGRAM DESCRIPTION The Reactor Vessel Internal Inspections program is a new plant-specific program that consists of the applicable ten elements as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components (Reference 8.3). These applicable ten elements are KLR-1309A, Rev. 3 Page 5 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS the same as the ten elements included in MRP-227 Appendix A (Reference 8.4) and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal applications for Nuclear Power Plants" (Reference 8.5).

The program manages the aging effects of changes in dimensions due to void swelling: cracking due to stress corrosion cracking (SCC), primary water stress corrosion cracking (PWSCC), irradiation-assisted stress corrosion cracking (IASCC), and fatigue; loss of fracture toughness due to neutron irradiation embrittlement and thermal aging embrittlement; loss of material due to wear; and loss of preload due to stress relaxation.

Loss of material by pitting corrosion and crevice corrosion is controlled by plant chemistry by limiting the oxygen concentration in the coolant system. Additional management of such mechanisms is not required by the reactor internals program.

The Reactor Vessel Internals Inspections program performs one-time, periodic, and conditional examinations using visual, surface, and ultrasonic examination techniques in accordance with the ASME Code,Section XI and EPRI Report 1016596 (MRP-227) and NEI 03-08 (References 8.4, 8.6). The ASME Section Xl Inservice Inspection, Subsections IWB, IWC, and IWD program performs visual examinations of the reactor vessel removable core support structures under Table IWB-2500-1, Examination Category B-N-3. MRP-227 has developed additional inspection requirements for reactor vessel internals that are susceptible to the aging effects managed by the program, including the examination techniques to be used, the examination schedule, the examination acceptance criteria, and the inspection expansion criteria.

The MRP-227 requirements are administered by Dominion using Fleet Reactor Internals Inspection Program Description, ER-AA-RII-10 (Reference 8.10) and Fleet Reactor Internals Inspection Administrative Procedure ER-AA-RII-101 (Reference 8.11). The Reactor Vessel Internals Inspections program is implemented in accordance with the KPS ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program that include the inspection procedures, the acceptance criteria for each examination technique, and the process for evaluating unsatisfactory inspection results. For the ASME Code Section XI inspections, indications and relevant conditions detected during examination will be evaluated in accordance with ASME Section XI, Article IWB-3500. For the additional MRP-227 required inspections, the evaluations will be performed in accordance with the examination acceptance criteria and the expansion criteria provided in MRP-227.

The program inspections will provide support for the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program for managing the reactor vessel internal components *in accordance with NEI 03-08 management of material issues.

Flaw indications detected during the required examinations are dispositioned in accordance with the Corrective Action Program.

KLR-1309A, Rev. 3 Page 6 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS 3.0

SUMMARY

PROGRAM INFORMATION Attachment 1 provides the Kewaunee and Nuclear Business Unit procedures that implement this aging management program.

Attachment 2 provides a listing of the aging management programs that are credited by this program as performing activities required by the program and a listing of the aging management programs that credited this program to perform activities required by that program.

Attachment 3 identifies the materials and aging effects managed by this aging management program.

Attachment 4 identifies the Integrated Plant Assessment Reports that credits this aging management program and identifies the systems or commodities managed by the program.

Attachment 5 is a detailed assessment of the ten program elements at the implementation level.

4.0 EVALUATION OF NUREG-1800 AND MRP-227 PROGRAM ELEMENTS This section provides a summary comparison of the Kewaunee aging management program to the ten program elements described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These applicable ten elements are the same as the ten elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." Age-related degradation in the reactor internals is managed through an integrated program. Specific features of the integrated program are listed in the following ten program elements. The comparison addresses the aging management program expectations for each element and provides a description of station implementation of these expectations.

Page 7 of 62 KLR-1309A, Rev. 33 KLR-1 309A, Rev. Page 7 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS Attachment 5 is a detailed assessment of the program elements at the implementation level. Attachment 5 provides the following information:

Column Content Attribute Indicates the "attribute" or detailed element recommendation Number being addressed. A program element that contains multiple recommendations is divided into more than one attribute.

Attribute Contains the detailed recommendation directly from NUREG-Description 1800 and MRP-227, Appendix A.

Attribute Evaluates the Kewaunee program against the NUREG-1800 and Response MRP-227 recommendations.

Document Provides the procedure(s), preventive maintenance activities, or Number other documents, which implement the program.

Document Indicates if all or only a portion of the document is required to Section implement the program.

Purpose Indicates the specific activities performed by the document, which are required to address the NUREG-1800 and MRP-227 recommendations.

Document Indicates the specific document changes to properly implement Change the program.

Note: Some document changes that clarify or provide additional detail for existing activities have not been identified as a,program enhancement since the change is not required to meet the NUREG-1800 and MRP-227 recommendations.

Follow-Up Indicates the internal tracking number used to track proposed Action Item document changes and other activities (FAI)

CAP/CR Indicates the number of the Corrective Action Program Action Request/Condition Report that will implement the proposed document changes and other activities.

4.1 PROGRAM ELEMENT 1 - SCOPE OF PROGRAM The scope of the Reactor Vessel Internals Inspections program is defined in Sections 5.1 and 5.2 of the ASME Section XI Inservice Inspection, Subsections KLR-1309A, Rev. 3 Page 8 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS IWB, IWC, and IWD program (Reference 8.7). These two sections identify two program enhancements to incorporate applicable industry reactor vessel internals inspection initiatives. The two enhancements state:

"5.1 Enhancement 1: Aging Management of Reactor Vessel Internals The ASME Section XI Inservice Inspection Subsections IWB, IWC and IWD program will be enhanced to (1) participate in the industry programs for investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval to augment the current inspections.

5.2 Enhancement 2: Aging Management of Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel The ASME Section XI Inservice Inspection Subsections IWB, IWC and IWD program will be enhanced to include identification of the limiting susceptible cast austenitic stainless steel reactor vessel internals components from the standpoint of thermal aging susceptibility, neutron fluence, and cracking. For each identified component, a plan will be developed, which accomplishes aging management through either a supplemental examination or a component-specific evaluation. The plan will be submitted for NRC review and approval not less than 24 months before entering the period of extended operation."

The scope of the ASME Section XI ISI - Reactor Vessel Internals Inspections program is to implement the inspections required by the two above program enhancements.

The reactor vessel internals included in the scope of the program consist of two basic assemblies, the upper internals assembly that is removed during each refueling operation to obtain access to the reactor core, and the lower internals assembly that can be removed, if desired, following a complete core off-load.

Reactor Vessel Internals Inspections program implements the NEI 03-08 (Reference 8.6) "Mandatory" requirement to use MRP-227 and MRP-228 to develop and implement a program for reactor vessel internals no later than- three years after the initial industry issuance of MRP-227, which was issued in December 2008.

The reactor vessel internals components included in the program are based on EPRI Report 1016596 (MRP-227) and Westinghouse letter LTR-ARIDA-08-63 Rev. 3, (References 8.4, 8.8).

The scope of the program does not include consumable items, such as fuel assemblies, reactivity control assemblies, and nuclear instrumentation, because these components are not typically within the scope of the components that are KLR-1309A, Rev. 3 Page 9 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS required to be subject to an aging management review, as defined by the criteria set in 10 CFR 54.21(a)(1).

MRP-227 provides the results of the industry initiative via the Materials Reliability Program (MRP) to develop the inspection and evaluation guidelines for managing the long-term aging of pressurized water reactor (PWR) reactor vessel internals. The report provides a generic list of the reactor vessel internals components for Westinghouse PWRs. Westinghouse letter LTR-ARIDA-08-63 Rev. 3 evaluated the MRP-227 generic list of the reactor vessel internals components for applicability to KPS.

Fleet procedures provide the administrative and technical direction for the Reactor Vessel Internals Inspections program (References 8.9 - 8.11). The reactor vessel internals components, including the cast austenitic stainless steel components, in the scope of the program are identified in Table 2 and Table 4.

MRP-227 has been submitted to the NRC for review. Following NRC review and approval, MRP-227 will be revised to incorporate any necessary changes to the guidelines and reissued as MRP-227-A. The Reactor Vessel Internals Inspections program will be revised, as necessary, to incorporate the final recommendations and requirements as published in MRP-227-A" Dominion will maintain cognizance of industry activities related to PWR internals inspection and aging management and will address/implement industry guidance stemming from those activities, as appropriate under NEI 03-08 practices.

The scope of program will be consistent with the corresponding program elements as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

4.2 PROGRAM ELEMENT 2 - PREVENTIVE ACTIONS The Reactor Vessel Internals Inspections program is a condition monitoring program and does not include any preventive or mitigative actions.

MRP-227 does not specify any preventive actions other than their applicability limitations to base-loaded plants. However, the guidelines in MRP-227 do rely on PWR water chemistry control to manage SCC and reduce the impact of IASCC.

Therefore, an important adjunct to the aging management methodologies described by guidelines in MRP-227 is PWR water chemistry control. The water chemistry program for PWRs relies on monitoring and control of reactor water 1 Any revisions to MRP-227 resulting from the issuance of MRP-227-A will not be incorporated for any inspections that are completed before MRP-227-A is issued.

KLR-1309A, Rev. 3 Page 10 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS chemistry as presented in Chapter XI.M2, "Water Chemistry," of NUREG-1801, Volume 2.

It is noted that KPS Primary Water Chemistry program manages the aging effects of cracking, loss of material, and reduction of heat transfer for nickel alloys, stainless steel and steel components due to stress corrosion cracking (SCC), including primary water stress corrosion cracking (PWSCC), and irradiation-assisted stress corrosion cracking (IASCC) pitting and crevice corrosion, and fouling (Reference 8.12).

The preventive actions will be consistent with the corresponding element as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

4.3 PROGRAM ELEMENT 3 - PARAMETERS MONITORED/INSPECTED The Reactor Vessel Internals Inspections program manages the aging effects of Changes in dimensions due to void swelling: cracking due to stress corrosion cracking (SCC), primary water stress corrosion cracking (PWSCC), irradiation-assisted stress corrosion cracking (IASCC), and fatigue; loss of fracture toughness due to neutron irradiation embrittlement and thermal aging embrittlement; loss of material due to wear; and loss of preload due-to stress relaxation.

The aging effects related to reactor vessel internals components in the program are identified in Table 2 and Table 4.

The parameters monitored/inspected will be consistent with the corresponding element as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

4.4 PROGRAM ELEMENT 4 - DETECTION OF AGING EFFECTS The Reactor Vessel Internals Inspections program performs one-time, periodic, and conditional examinations using visual, surface, and ultrasonic examination techniques in accordance with the ASME Code,Section XI and MRP-227.

The ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program conducts a visual VT-3 examination of the reactor vessel removable core support structures under Table IWB-2500-1, Examination Category B-N-3, once per Inservice Inspection interval (Reference 8.13). The visual VT-3 examination determines the general mechanical and structural condition of the components by inspecting for structural distortion or displacement of parts, KLR-1309A, Rev. 3 Page 11 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS loose/missing, cracked or fractured parts, loose/missing bolting or fasteners, debris, corrosion or erosion, and wear of mating surfaces. The inspections are performed by qualified personnel following procedures consistent with the ASME Code and 10 CFR Part 50, Appendix B.

Additional reactor vessel internals inspection requirements have been promulgated by MRP-227. MRP-227 developed three important precursor elements as a basis for the reactor vessel internals inspection requirements:

screening criteria, categorization of PWR vessel internals, and functionality assessment of components and assemblies of components. The evaluation of the three precursor elements resulted in the assignment of the reactor vessel internals components into four inspection categories:

• Primary - those reactor vessel internals that are highly susceptible to the effects of at least one of the eight aging mechanisms.

0 Expansion - those reactor vessel internals that are highly or moderately susceptible to the effects of at least one of the eight aging mechanisms, but for which functionality assessment has shown a degree of tolerance to those effects.

• Existing Programs - those reactor vessel internals that are susceptible to the effects of at least one of the eight aging mechanisms and for which existing generic and plant-specific aging management programs are capable of managing those effects.

• No Additional Measures - those reactor vessel internals for which the effects of all eight aging mechanisms are below the screening criteria.

MRP-227 provided appropriate recommendations for aging management for each category (Reference 8.17). The categorization and resulting inspection requirements described above do not supersede the ASME Section XI, Inservice Inspection requirements for reactor vessel internals components.

The MRP-227 guidelines were based on a broad set of assumptions about plant operation, which encompass the range of current plant conditions for the U.S.

domestic fleet of PWRs. The functionality analyses and supporting aging management strategies in MRP-231 and MRP-232 provided the basis for the MRP-227 guidelines (References 8.14, 8.15, 8.17). The following table compares KPS to the general assumptions used in the analysis.

Page 12 of 62 Rev. 33 KLR-1309A, Rev. Page 12 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 1 - Comparison to MRP-227 Assumptions MRP Assumption KPS Comparison Assumption Met 30 years of operation with high KPS used new fuel at the Yes leakage core loading patterns peripheral locations during then Fuel Cycles 1 and 2. Once remaining 30 years of burned fuel was used at operation with a low-leakage peripheral locations during fuel management strategy. Fuel Cycles 3 through 15. In Fuel Cycle 16 KPS switched to use of a low leakage core design. KPS continues to use a Low Leakage core design for all subsequent fuel cycles.

Base load operation KPS has implemented Base Yes load operation over the life of the plant.

No design changes affecting Design changes to the KPS Yes Reactor Vessel Internals Reactor Vessel Internals components beyond those components have been limited identified in general industry to Westinghouse replacement guidance or recommended by of split pins, installation of the original vendors flexure less inserts, and replacement of the reactor vessel head.

The Reactor Vessel Internals Inspections program will perform the inspections of the reactor vessel internals in the Primary and Expansion categories consistent with the requirements of MRP-227. The aging management methodologies described in MRP-227 are based on either existing inservice examinations required by the ASME Code,Section XI or on well-documented and well-demonstrated examination methods with which the industry has considerable experience. The Reactor Vessel Internals Inspections program will perform visual examinations, surface examinations, volumetric examinations, and physical measurements. Visual examinations (VT-3) will be used to detect the general degradation conditions. Visual and enhanced visual examinations (VT-1 and EVT-1, respectively) will be conducted to detect discontinuities and imperfections on the surface of components. The surface examinations further characterize discontinuities on the surface of components, and the volumetric inspections KLR-1309A, Rev. 3 Page 13 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS indicate the presence of discontinuities or flaws throughout the volume of material. Some aging effects may involve changes in clearances, settings, and physical displacements that can be monitored by visual means, supplemented by physical measurements.

The specific inspection methodologies and requirements for the NDE examinations of the components in the Primary and Expansion categories will be consistent with the guidance with EPRI Report 1016609 (MRP-228) (Reference 8.16). New procedures will be developed to perform the NDE examinations of the components in the Primary and Expansion categories as identified in Table 2 and Table 4.

The schedule for inspection of the reactor vessel internals components in the Primary and Expansion categories will be consistent with the requirements of MRP-227, as shown in Table 3.

Table 2 provides a breakdown of how each component maps to the four categories: Primary, Expansion, Existing, No Additional Measures. Those reactor vessel internals components included in the Existing Programs or No Additional Measures categories will require no additional measures for future inspections other than the ASME Code inspections per Section Xl, Examination Category B-N-3 for removable internal structures, which were previously discussed.

The CASS items are identified in Table 2 as Expansion, Existing, or No Additional Measures. Per guidance from MRP-227, the CASS item in the Expansion category will be inspected if and when the Primary criteria for the RCCA guide tubes lower flange weld is exceeded. The CASS item in the Existing category will be inspected under the Section XI program on a frequency of approximately once every 10 years. Per MRP-227, the CASS items in the No Additional Measures category do not require scheduled inspections.

For the CASS items in the Expansion, Existing, or No Additional Measures category they will be inspected per the guidance in MRP-227 or evaluated per the following criteria.

For reactor vessel internal CASS components, in the Expansion and Existing category, that meet one of the following criteria: 1) have a neutron fluence of greater than [1017 n/cm 2]2 (E>1 MeV); OR 2) are determined to be susceptible to thermal embrittlement; the Reactor Vessel Internals Inspections program will:

Perform a component-specific evaluation, including a mechanical loading assessment to determine the maximum tensile loading on the component during ASME Code Level A, B, C, and D conditions. If the loading is compressive or low enough (<5 ksi) to preclude fracture, then supplemental inspection of the component is not required.

2 Per MRP-175, Materials Reliability Program: PWR Internals Material Degradation Mechanism Screening and Threshold Values - EPRI Report 1012081, 2005, a threshold value of 102o n/cm2 (E>1 MeV) will be used for screening of neutron fluence for susceptibility to thermal aging embrittlement pending agreement with NRC.

KLR-1309A, Rev. 3 Page 14 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS If the above criterion is not met, a supplemental inspection will be performed for the portions of the susceptible components determined to be limiting from the standpoint of thermal aging susceptibility (i.e., ferrite and molybdenum contents, casting process, and operating temperature),

neutron fluence, and cracking susceptibility (i.e., applied stress, operating temperature, and environmental conditions). The inspection technique will be capable of detecting the critical flaw size with adequate margin. The critical flaw size is determined based on the service loading condition and service-degraded material properties.

For CASS components that meet neither of the two criteria specified above, the existing ASME Section XI inspection requirements are adequate in accordance with NUREG-1801, XI.M13.

Table 2 and Table 4 identify the reactor vessel internals components in the program, the aging effects applicable to each component, the examination techniques used to detect the aging effect(s), and the examination schedule for the Primary and Expansion category components.

The Reactor Vessel Internals Inspections program inspections are performed in accordance with the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program, which includes the procedures for performing the inspections, the acceptance criteria for each examination technique, and the review and disposition of inspection results.

The personnel performing the inspections will be trained in accordance with the guidance in MRP-228.

The detection of aging effects will be consistent with the corresponding element as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

4.5 PROGRAM ELEMENT 5 - MONITORING AND TRENDING The Reactor Vessel Internals Inspections program performs one-time, periodic, and conditional examinations as scheduled and performed in accordance with the ASME Code, Section Xl as well as MRP-227 to provide timely detection of aging effects.

In addition to the MRP-227 Primary components, Expansion components have been defined by MRP-227 should the scope of examination and re-examination need to be expanded beyond the Primary group due to detection of significant aging effects found in Primary components with the same material and potential aging mechanism.

Table 2 and Table 4 identify the reactor vessel internals components in the program, the aging effects applicable to each component, the examination KLR-1309A, Rev. 3 Page 15 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS techniques used to detect the aging effect(s), and the examination schedule for the Primary and Expansion category components.

Those reactor vessel internals components included in the Existing Programs or No Additional Measures categories will be inspected on a schedule consistent with the requirements of the ASME Code for Section Xl, Examination Category B-N-3, for removable internal structures, as outlined in the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program. This schedule is consistent with the recommendations of MRP-227.

The EPRI MRP Reactor Internals Inspection and Evaluation Guidelines Core Group will evaluate the results of the first and subsequent rounds of augmented examinations as documented in Section 7 of MRP-227. This evaluation may result in recommendations for changes in the examination periodicity, which would be evaluated for applicability to KPS (Reference 8.17).

Flaw indications detected during the required examinations are dispositioned in accordance with the Corrective Action Program.

The monitoring and trending will be consistent with the corresponding element as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

4.6 PROGRAM ELEMENT 6- ACCEPTANCE CRITERIA As discussed in Section 4.4, the Reactor Vessel Internals Inspections program is implemented in accordance with the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program that include the inspection procedures, the acceptance criteria for each examination technique, and the process for evaluating unsatisfactory inspection results. For ASME Code Section XI inspections, indications and relevant conditions detected during examination are required to be evaluated in accordance with ASME Section XI, Article IWB-3500.

In addition to the ASME Code Section XI requirements, MRP-227, MRP-228, WCAP-17096, and WCAP-17020-P provide the examination acceptance criteria for the Primary and Expansion components and the expansion criteria for expanding the examinations beyond the Primary components to include the Expansion components (References 8.18, 8.19).

The guidance in MRP-227 contains three types of examination acceptance criteria:

For visual examination (and surface examination as an alternative to visual examination), the examination acceptance criterion is the absence of any of the specific, descriptive relevant conditions; in addition, there are requirements to record and disposition surface breaking indications that detected and sized for length by VT-1/EVT-1 examinations; KLR-1309A, Rev. 3 Page 16 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS

• For volumetric examination, the examination acceptance criterion is the capability for reliable detection of indications in bolting, as demonstrated in the examination Technical Justification; in addition, there are requirements for system-level assessment of bolted or pinned assemblies with unacceptable volumetric (UT) examination indications that exceed specified limits; and

• For physical measurements, the required examination acceptance criterion is related to the hold down spring. At KPS the hold down spring is fabricated from alloy 403SS and therefore does require inspection.

For the examination of the baffle-former bolts and the baffle-former edge bolts, a plant specific evaluation to determine the minimum acceptable bolting pattern in accordance with the NRC reviewed and approved methodology in WCAP-15029-P-A has been completed and is documented in WCAP-15425, (References 8.20, 8.21).

Table 2 and Table 4 identify the specific reactor vessel internals components in the program, the aging effects applicable to each component, the examination techniques used to detect the aging effect(s), and the additional examination acceptance criteria and inspection expansion criteria for the Primary and Expansion category components.

The acceptance criteria will be consistent with the corresponding element as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

4.7 PROGRAM ELEMENT 7 - CORRECTIVE ACTIONS As discussed in Section 4.4, the Reactor Vessel Internals Inspections program is implemented for applicable components in accordance with the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program that include the inspection procedures, the acceptance criteria for each examination technique, and the process for evaluating unsatisfactory inspection results.

For the additional MRP-227-required inspection of the Primary and Expansion category components, MRP-227 provides information on methodology that can be used for the evaluation of detected conditions that exceed the examination acceptance criteria. The flaw evaluation methodology accounts for the accumulated neutron exposure and the resulting loss of fracture toughness due to radiation embrittlement in assessing the suitability of the component for continued service. Justification for flaw evaluation fracture toughness limits is provided in Section 6 of MRP-227.

Any detected conditions that do not satisfy the examination acceptance criteria are required to be dispositioned through the plant corrective action program, which may require repair, replacement, or analytical evaluation for continued KLR-1309A, Rev. 3 Page 17 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS service until the next inspection. The disposition will ensure that design functions of the reactor internals components will continue to be fulfilled for all licensing basis loads and events. Other alternative corrective action bases may be used to disposition relevant conditions if they have been previously approved or endorsed by the NRC. For example, previous NRC-endorsed alternative corrective actions bases include the corrective actions bases for Westinghouse-design RVI components that are defined in Tables 4-1, 4-2, 4-3, 4-4, 4-5, 4-6, 4-7, and 4-8 of Westinghouse Report No. WCAP-14577 Rev 1-A (Reference 8.22).

The Quality Assurance Program and sub-tier procedures fulfill and implement the requirements of Criterion XVI of 10 CFR Part 50, Appendix B. The process includes provisions for timely evaluation of adverse conditions and implementation of corrective actions, including root cause determinations and prevention of recurrence, where appropriate. Provisions are in place for tracking, monitoring, reviewing, and approving corrective actions to ensure effective corrective actions are taken, along with monitoring the process for adverse trends (References 8.23, 8.24).

The corrective actions will be consistent with the corresponding element as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

4.8 PROGRAM ELEMENT 8 - CONFIRMATION PROCESS As discussed in Section 4.4, the Reactor Vessel Internals Inspections program is implemented in accordance with the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD program that include the inspection procedures, the acceptance criteria for each examination technique, and the process for evaluating unsatisfactory inspection results.

The corrective action program, as presented above, includes provisions to ensure that all significant conditions adverse to quality receive a cause determination and that corrective actions are implemented to preclude reoccurrence (References 8.23, 8.24).

The confirmation process will be consistent with the corresponding element as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

4.9 PROGRAM ELEMENT 9 - ADMINISTRATIVE CONTROLS The Quality Assurance Program and sub-tier procedures fulfill and implement the requirements of 10 CFR Part 50, Appendix B. Administrative controls include KLR-1309A, Rev. 3 Page 18 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS management of document issue, revision, review and approval (References 8.23 and 8.25 - 8.28).

The MRP-227 requirements are administered by Dominion using Fleet Reactor Internals Inspection Program Description, ER-AA-RII-10 and Fleet Reactor Internals Inspection Administrative Procedure ER-AA-RII-101.

The administrative controls will be consistent with the corresponding element as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

4.10 PROGRAM ELEMENT 10--OPERATING EXPERIENCE The Reactor Vessel Internals Inspections program is a new program. Therefore, no internal programmatic experience is available. As operating experience is obtained, lessons learned will be used to adjust this program as needed.

Relatively few incidents of PWR vessel internals aging degradation have been reported in operating U.S. commercial PWR plants. However, a considerable amount of PWR vessel internals aging degradation has been observed in European PWRs, with emphasis on cracking of baffle-former bolting. Reactor internals failures (both domestic and international), research data, and vendor evaluations have been considered in the development of MRP-227, which forms the basis for the Reactor Vessel Internals Inspections program.

The PWROG has performed a survey under PA-MSC-0568 to gather reactor internals inspection results to date. Reactor vessel internals inspection results performed under MRP-227 in the future will be reported to the EPRI MRP Issue Program within 120 days following completion'of the inspections. The EPRI MRP program plans to publish future inspection results under MRP-219 (Reference 8.29).

The Operating Experience Program ensures that additional operating experience is factored into the aging management programs to ensure program effectiveness (Reference 8.30).

5.0 PROGRAM ENHANCEMENTS The Reactor Vessel Internals Inspection program is a new plant-specific program that will be consistent with the applicable ten elements as described in Fleet GARD ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components." These program elements are the same as the program elements included in MRP-227 Appendix A and Appendix A of KLR-1309A, Rev. 3 Page 19 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants."

6.0 PROGRAM EXCEPTIONS The Reactor Vessel Internals Inspection program is a new plant-specific aging management program.

7.0 CONCLUSION

The Reactor Vessel Internals Inspections program ensures that the effects of aging associated with the in-scope components will be adequately managed so that there is reasonable assurance that their intended functions will be maintained consistent with the current licensing basis throughout the period of extended operation.

8.0 REFERENCES

8.1 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power Plants," Code of Federal Regulations, U.S. Nuclear Regulatory Commission, Washington, D.C.

8.2 Central Reporting System, Condition Report 322266, "Mandatory and Needed Requirements for Reactor Vessel Internals," February 3, 2009.

8.3 Nuclear Fleet Guidance and Reference Document ER-AA-AMP-1003, "Aging Management Programs for License Renewal Structures, Systems, and Components."

8.4 EPRI Report 1016596, "Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-Rev. 0)," December 2008, Electric Power Research Institute, Palo Alto, California 8.5 NUREG-1800, Revision 1, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," U. S. Nuclear Regulatory Commission, September 2005.

8.6 NEI 03-08, "Guideline for the Management of Materials Issues," April 2007.

8.7 Technical Report KLR-1309, "ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD."

8.8 Memo from Westinghouse Advanced Reactor Internals Design & Analysis to Donna Rogosky, "Summary Report for the Fabrication and Design Information for KPS Reactor Vessel Internals," dated December 5, 2008, [LTR-ARIDA-08-63 Rev. 3].

8.9 Dominion Equipment Reliability (ER) Peer Group Project Charter ER-31, "Fleet Reactor Internals Inspection Program."

KLR-1309A, Rev. 3 Page 20 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS 8.10 Nuclear Fleet Program Description ER-AA-RII-10, "Fleet Reactor Internals Inspection."

8.11 Nuclear Fleet Administrative Procedure ER-AA-RII-101, "Fleet Reactor Internals Inspection Program."

8.12 Technical Report KLR-1310, "Primary Water Chemistry."

8.13 Nuclear Fleet Nondestructive Examination Procedure ER-AA-NDE-VT-608, "VT-3 Visual Examination Procedure for Examination Category B-N-i, Interior of Reactor Vessel."

8.14 EPRI Report 1016592, "Materials Reliability Program: Aging Management Strategies for B&W PWR Internals (MRP-231)," Electric Power Research Institute, Palo Alto, CA.

8.15 EPRI Report 1016593, "Materials Reliability Program: Aging Management Strategies for Westinghouse and Combustion Engineering PWR Internals (MRP-232)," Electric Power Research Institute, Palo Alto, CA.

8.16 EPRI Report 1016609, "Materials Reliability Program: Inspection Standard for PWR Internals (MRP-228)," July 2009, Electric Power Research Institute, Palo Alto, CA.

8.17 Letter from Terry McAlister (EPRI) to Tanya M. Mensah (NRC), "EPRI MRP Responses to: Request for Additional Information Re: Electric Power Research Institute Topical Report 1016596, 'Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (MRP-227-REV.

0)' (TAC NO. ME0680), August 24, 2009," dated February 1, 2010 [MRP 2010-004].

8.18 WCAP-17096, Revision 0, "Reactor Internals Acceptance Criteria Methodology and Data Requirements".

8.19 WCAP-17020-P, Revision 0, "Point Beach Unit 1 Upper Internals Guide Tube -

Guide Card Wear Evaluation".

8.20 WCAP-15029-P-A, "Westinghouse Methodology for Evaluating the Acceptability of Baffle-Former-Barrel Bolting Distributions under Faulted Loaded Conditions".

8.21 WCAP-15425, "Determination of Acceptable Baffle-Barrel-Bolting for Kewaunee and Prairie Island Plants."

8.22 WCAP-14577, Revision 1-A, "License Renewal Evaluation: Aging Management for Reactor Internals."

8.23 Topical Report DOM-QA-1 "Dominion Nuclear Facility Quality Assurance Program Description."

8.24 Nuclear Fleet Administrative Procedure PI-AA-200, "Corrective Action" 8.25 KPS Nuclear Administrative Directive NAD-03.01, "Directive, Implementing Document, and Procedure Control."

8.26 KPS General Nuclear Procedure GNP-03.01.01, "Directive, Implementing Document, and Procedure Administrative Controls."

KLR-1309A, Rev. 3 Page 21 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS 8.27 DNAP-0501, "Dominion Nuclear Procedure Administrative Control Program."

8.28 Nuclear Fleet Program Description AD-AA-10, "Administrative Controls Program."

8.29 MRP-219, "Inspection Data Survey Report."

8.30 Nuclear Fleet Guidance and Reference Document PI-AA-100-1007, "Operating Experience Program."

9.0 ATTACHMENTS Attachment 1 - Implementing Procedures Attachment 2 - Associated Aging Management Programs Attachment 3 - Materials and Aging Effects Managed Attachment 4 - Integrated Plant Assessment Reports / Systems or Commodities Attachment 5 - Detailed NUREG-1800 Program Evaluation Page 22 of 62 KLR-1309A, Rev. 33 KLR-1 309A, Rev. Page 22 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation 2

RVI Component LREffect Aging LR Aging Mechanism Existing Inspections MRP-227 Information CASS Components( )

t Category( 1 Required Iinspections 7 1 Inspection Schedule Procedure Requirements Changes in Baffle Former New void swelling dimensions Assembly procedure 8 Baffle Former " Baseline required to Assembly examination perform the Primary VT-3

• VT-3(e) between 20 and stress corrosion

• Baffle Former 40 EFPY. inspections.

Cracking cracking, irradiation- Assembly

• Core side assisted stress surface as

• Subsequent corrosion cracking indicated examinations on a ten-year interval.

Baffle Former Assembly Loss of neutron irradiation Baffle-edge bolts Baffle-edge bolts fracture embrittlement, void and locking devices and locking devices Including :

toughness swelling

" Baffle Assembly Primary

• VT-3"6 '

• Baseline baffle/former Bolts and locking examination Baffle-edge plates ER-AA-NDE- devices on high between 20 and bolts and VT-608 fluence seams. 40 EFPY.

" Baffle-edge Loss of pitting and crevice locking bolts including devices 100% of e Subsequent material corrosion components examinations on bolting lock bars accessible from a ten-year

" Baffle-former core side. interval.

bolts including bolting lock bars 3 Baffle-former bolts New NAM1 1 Baffle-former bolts 8

• Baseline procedure

• Baffle bolting - UT required to examination lock bars 0 100% of between 25 and perform the Primary accessible bolts 35 EFPY. UT Loss of or as supported inspections.

preload stress relaxation

• Baffle-former

• Subsequent bolts by plant specific examination after justification.

Expansion 10 to 15 Heads additional EFPY

• Baffle-former accessible from bolts. the core side. Re-examination for high leakage core Page 23 of 62 KLR-1 309A, Rev.

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LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation LR Aging LR Aging Existing MRP-227 Information CASS RVI Component Effect Mechanism Inspections Components(2 )

Category(I) Required Procedure Inspections(71 Inspection Schedule Requirements designs requires continuing examinations on a ten-year interval.

Page 24 of 62 Rev. 3 KLR-1309A, Rev. 3 Page 24 of 62

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Ctgr()

1

) Inspections Required Inspection Schedule Requirements Rqurmet category~

Bottom-Mounted Changes in void swelling Instrumentation dimensions columns NAM Including: stress corrosion Except as listed

" BMI column Cracking cracking, irradiation- below.

bMolun Cassisted stress bodies corrosion cracking

• BMI column bolts Loss of thermal aging and

• BMI column fracture neutron irradiation collars toughness embrittlement

" BMI column Loss of pitting and crevice cruciforms material corrosion

" BMI column ER-AA-NDE- BMI column bodies BMI column bodies CASS - BMI extension bars

- VT-3 16 1 As indicated by column

• BMI column VT-608 100% of BMI difficulty of New cruciforms extension tubes bodies insertion/withdra procedure8 Expansion tubes

" BMI column lock Expansion column bodies wal of flux required to caps

• BMI column for which thimbles. Flux perform the

" BMI column bodies difficulty is thimble insertion/ VT-3 detected during withdrawal to be inspections.

flux thimble nuts monitored at insertion/ each inspection withdrawal. interval.

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LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

Catgor~i Inspections(7Rqie SReq

)

npcinShdl Schedule Inspection [Procedure Requirements NAM Changes in void swelling Except as listed dimensions below.

Core barrel flange New Core barrel flange weld procedure 8 weld Initial required to

- EVT-1 examination and perform the Expansion-

• 100% of one side reexamination EVT-1 Core barrel of the accessible frequency inspections.

Core Barrel flange weld surfaces of the dependent on the selected weld examination Including:

and adjacent results for upper

" Core Barrel stress corrosion base metal, core barrel flange cracking, irradiation- flange.

Cracking

• Core Barrel assisted stress outlet nozzles corrosion cracking ER-AA-NDE- Core Barrel outlet New Core Barrel outlet VT-608 nozzles procedure8

• Lower Core nozzles Barrel

• Initial required to

• EVT-1 perform the Expansion- examination and

" Upper Core

• 100% of one side reexamination EVT-1 Barrel

• Core barrel of the accessible frequency inspections.

• Ring Sector outlet nozzles surfaces of the dependent on the selected weld examination and adjacent results for upper base metal. core barrel flange i

Lower core barrel Lower core barrel New 8 Expansion- flange weld flange weld procedure Loss of neutron irradiation Initial required to fracture embrittlement, void

• Lower core

• EVT-1 perform the barrel flange examination and toughness swelling

• 100% of one side reexamination EVT-1 weld of the accessible inspections.

frequency surfaces of the dependent on the a _______________ L____________________ .1.______________ L _________________ L ____________________ +/- L _______________ .1. _________________

Page 26 of 62 KLR-1 KLR-1309A, Rev. 3 309A, Rev. 3 Page 26 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

Category I nsRectired~ Inspection Schedule Required (Procedure Requirements Inspections Rqurmet selected weld examination and adjacent results for upper base metal, core barrel Upper core barrel New Upper core barrel flange weld procedure 8 flange weld ° No later than 2 required to Primary

• EVT-1 refueling outages perform the Upper core

• 100% of one side from the of the beginning EVT-1 inspections.

barrel flange of the accessible weld surfaces of the license renewal selected weld period.

and adjacent Subsequent

• base metal. examination on a ten-year interval.

Page 27 of 62 KLR-1 KLR-1309A, Rev. 3 309A, Rev. 3 Page 27 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

RequiredProcedure Ctgr() Inspections 7 npRequiredn( ) Inspection Schedule Requirements Rqurmet Interfacing NAM Components Changes in dimensions void swelling

• Except as Including: noted below.

" Clevis inserts stress corrosion Existing(4)

Clevis o insert cracking, irradiation-bolts Cracking assisted stress

• Clevis insert

• Clevis insert corrosion cracking bolts lock keys

" Head and Loss of neutron irradiation ER-AA-NDE-VT-608 vessel fracture embrittlement, void toughness swelling alignment pins

" Head and vessel Primary alignment pin NA - KPS does not Hold-down have hold-bolts

• spring (304SS dw 304SS pig(5).

" Head and vessel Loss of only) down springs .

alignment pin preload stress relaxation lock cups

• Hold-down spring Page 28 of 62 KLR-1 309A, Rev.

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LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS Table'2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

Category Required (7) IProcedure Inspections Schedule Requirements Irradiation specimen guide Including:

Irradiation specimen guide ER-AA-NDE-bolts VT-608 NAM Irradiation specimen lock caps Irradiation specimen plugs Changes in dimensions void swelling dimensions Lower core plate Including: stress corrosion

" Fuel alignment cracking, primary pins water stress Fuel alignment Cracking corrosion cracking, ER-AA-NDE- NAM p bol irradiation-assisted VT-608 Existing pin bolts stress corrosion

• Fuel alignment cracking pin lock caps, Loss of neutron irradiation fracture embrittlement, void toughness swelling Page 29 of 62 KLR-1309A, Rev. Rev. 33 Page 29 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing CASS 1 21 Effect Mechanism Inspections MRP-227 Information Components Category Required (7) IProcedure Inspections Schedule Requirements NAM NAM Changes in dimensions void swelling Except as noted below.

Column bodies New

• Initial procedure 8 Lower core plate Column bodies examination and required to support columns stress corrosion Expansion

• EVT-1 reexamination perform the clumn bodies Crackin cracking, irradiation- frequency EVT-1 assisted stress

• Column

• 100% of dependent on the inspections

" Column bodies corrosion cracking bodies accessible examination

• Column bolts" surfaces. results for upper

" Lug core barrel flange weld.

" Nuts (Bearing Nut) Loss of neutron irradiation Column bolts Column bolts New

• Sleeves fracture embrittlement, void a Initial and prcedure8 toughness swelling subsequent required to Expansion a 100% of examinations perform the Column bolts accessible bolts dependent on UT inspections Loss of stress relaxation or as supported results of baffle-preload by plant-specific former bolt justification. examinations.

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LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

RequiredProcedure Ctgr() Inspections 7 npRequiredo() Inspection Schedule Requirements Rqurmet Lower Internals void swelling Including: Changes in stress corrosion

" Diffuser plate dimensions cracking, irradiation-assisted stress

• Flux thimble corrosion cracking tubes

• Flux thimble tube plugs stress corrosion

• Head cooling cracking, irradiation-spray nozzles Cracking assisted stress ER-AA-NDE- NAM

• Lower support corrosion cracking VT-608 Existing forging (13 inch tk. plate)

• Radial support keys Loss of neutron irradiation

• Radial support fracture embrittlement, void key bolts toughness swelling

" Radial support key lock keys Page 31 of 62 KLR-1 KLR-1309A, Rev. 3 309A, Rev. 3 Page 31 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

Required (Procedure 7

Inspections(

R Inspection Schedule Requirements NAM RCCA guide Changes in void swelling

• Except as tubes dimensions Includes: noted below.

• Anti-rotation Flanges-lower New studs and nuts *Blswelds Flanges-lower welds wed.roeue procedure8 SBolts we No later than 2 required to

" C tubes

• EVT-1 refueling outages perform the Primary

• 100% of outer from the EVT-1

• Enclosure pins Flanges-lower (accessible) beginning of the inspections

• Upper guide welds CRGT lower license renewal tube flange weld period.

enclosures Flags surfaces adjacent and base ° Subsequent anges- mentba examination on a intermediate mten-year interval.

" Flanges-lower stress corrosion Guide plates/cards New

" Guide Cracking cracking, irradiation- 8uide 8

paGuide assisted stress

• No later than 2 Procedure8 plates/cards corrosion cracking Guide plates/cards refueling outages required to

" Housing plates

• VT-3(6) from the perform the

• 20% examination beginning of the VT-3

" Inserts license renewal inspections of the number of

• Lock bars Primary CRGT period, and no

" Sheaths

• Guide assemblies, with earlier than two

" Support pins plates/cards all guide cards refueling outages S within each prior to the start Support pin selected CRGT of the license cover plate assembly renewal period.

• Support pin examined. Subsequent cover plate exams on a ten-locking caps year basis.

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LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

RequiredProcedure d

Category(p) Requir e Inspections Inspection Schedule Requirements Rqurmet and tie straps

" Support pin nuts

" Water flow slot ligaments

" Flexures NA Loss of thermal aging and Primary KPS does not have

• Flexureless fracture neutron irradiation P ria KPS de thae Inserts toughness embrittlement

• Flexures RCCA guide tubes flexures(5 ).

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LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

RequiredProcedure Ctgr() Inspections nspRequired Inspection Schedule Requirements Rqurmet Secondary Core Changes in void swelling Support (SCS) dimensions Assembly Including: stress corrosion

" SCS base plate Cracking cracking, irradiation-assisted stress "SCS bolts corrosion cracking ER-AA-NDE- NAM

" SCS energy VT-608 absorber

" SCS guide post Loss of neutron irradiation

• SCS housing fracture embrittlement, void

" Tie Plate toughness swelling

" SCS lock keys Page 34 of 62 KLR-1 309A, Rev.

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LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

Required Inspection Schedule Procedure Category( 1 ) inspections 7 Requirements Thermal shield Changes in void swelling Including: dimensions NAM

" Thermal shield stress corrosion

• Except as bolts cracking, irradiation- noted below.

. Thermal shield Cracking assisted stress flexures corrosion cracking

" Thermal shield dowels Cracking fatigue Thermal shield New ER-AA-NDE- flexures procedure

" Thermal shield Loss of neutron irradiation VT-608

• No later than 2 required to bumper bar fracture embrittlement, void Thermal shield refueling outages perform the

• Locking Bar toughness swelling Primary flexures from the VT-3 SAdjustment Plug Thed VT-3 6 beginning of the inspections justrontPnlug Thermal shield Vlicense renewal

" Neutron panel flexures

• 100% of thermal period.

Neutron panel

" bolts Loss of material wear shield flexures.

• Subsequent examinations on

" Neutron panel a ten-year lock caps interval.

Page 35 of 62 KLR-1 309A, Rev.

KLR-1309A, Rev. 33 Page 35 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

RequiredProcedure Required( Inspection Schedule redure Category()

Inspections 7 Requirements Upper core plate Changes in void swelling Including dimensions

" Upper core stress corrosion plate alignment cracking, irradiation- CASS keyways and Cracking assisted stress EEMe pins corrosion cracking ER-AA-NDE- NAM Upper core

" Upper core VT-608 Existing plate mixing plate fuel guide devices pins Loss of neutron irradiation

" Upper core fracture embrittlement, void plate mixing toughness swelling devices Page 36 of 62 KLR-1 KLR-1309A, Rev. 33 309A, Rev. Page 36 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

RequiredProcedure Required( Inspection Schedule redure Category()

Inspections Requirements Upper core plate Changes in void swelling instrumentation dimensions columns Including: stress corrosion cracking, irradiation-

• Bolting Cracking assisted stress

" Brackets, corrosion cracking clamps, terminal blocks, and CASS conduit straps ER-AA-NDE-

• conduit

" Conduit seal VT-608 NAM support assembly-body, tubesheets

• clamp Loss of neutron irradiation

" Conduit seal fracture embrittlement, void assembly-tubes toughness swelling

" Conduits

" Flange base

" Locking caps

" Support tubes Page 37 of 62 KLR-1 KLR-1309A, Rev. 3 309A, Rev. 3 Page 37 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

RequiredProcedure Ctgr() Inspections 7 nsRequiredo( ) Inspection Schedule Requirements Rqurmet Category~

Upper core plate Changes in void swelling support columns dimensions Including stress corrosion

" Adapters cracking, irradiation-

• Bolts Cracking assisted stress

" Column bases corrosion cracking

" Column bodies; Loss of neutron irradiation CASS Upper Support fracture embrittlement, void ER-AA-NDE-

• support Column - Type II toughness swelling VT-608 NAM column bases

• Extension tubes

• thermocouple

" Flanges stop

" Lock keys

" Thermocouple Loss of stop - located at preload stress relaxation flow mixing device

" Nuts Page 38 of 62 KLR-1 309A, Rev. 33 309A, Rev. Page 38 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 2 - Reactor Vessel Internals Evaluation RVI Component LR Aging LR Aging Existing MRP-227 Information CASS Effect Mechanism Inspections Components(2 )

Category (1) Required Inspections(

R 7(Procedure Inspection Schedule Requirements Upper core NAM support plate Changes in assemblyt assembly dmensin void swelling Except as dimensions

• ntdblwbelow.

noted Including

" Bolts stress corrosion

• Deep beam ribs Cracking cracking, irradiation-assisted stress

• Deep beam corrosion cracking stiffeners ER-AA-NDE-

• Upper core VT-608 Existing support plate -

• Upper support welded to deep beam assy. Loss of neutron irradiation ring or skirt beamkassy fracture embrittlement, void

• Lock keys toughness swelling

" Upper core support ring or skirt Table Notes:

1. MRP-227 inspection categories are discussed in Section 4.4.

2. The CASS (Cast Austenitic Stainless Steel) components identified in Reference 8.8 for evaluation in accordance with KLR-1 309, Section 5.2. A component specific evaluation must be performed determine the susceptibility of each CASS component to thermal embrittlement or an inspection is required to detect cracking as discussed in Section 4.4.

3. NAM is the MRP-227 No Additional Measures category.

4. Existing is the MRP-227 Existing Programs category.

5. Reference 8.8, Table 3: Kewaunee Components.

KLR-1309A, Rev. 3 Page 39 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS

6. The MRP-227 inspection recommendations for VT-3 to monitor for the effects of cracking are appropriate because they are limited to cases where the intent of the examination is to monitor the general condition of the component. The VT-3 examination is specified where the objective of the examination is detection of broken or missing bolt locking devices and welds; protruding bolts; or broken or missing pieces (e.g., supports, spider arms, dowels). VT-3 is not specified where the examination objective the detection of the onset of cracking with accompanying tight crack opening displacements (CODs). VT-3 as currently defined in Section XI of the ASME Code is capable of this level of detection. The MRP-227 recommendations are consistent with the approach used in the ASME Section XI examinations, which require VT-3 inspections for accessible core support structures (Reference 8.17).

7. The coverage requirements for the required inspections based on MRP-227 are adequate to ensure timely detection of aging effects in the reactor vessel components. Coverage for a visual examination of a single component is defined as the percentage of the target surface area observed in the examination. Consideration of accessibility in terms of target surface is included in the coverage requirements for a number of the components. Additionally, accessibility was a factor in determining coverage for inspection of a variety of bolts, locking devices and lock welds. In these cases, coverage referred to the fraction of components inspected rather than the coverage associated with any particular examination (Reference 8.17).

8. Additional NDE procedures (either fleet, plant-specific, or vendor) will be needed to implement the revised ISI Plan for Reactor Vessel Internals Inspections.

Page 40 of 62 Rev. 3 KLR-1309A, Rev. 3 Page 40 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 3 - Aging Management Program Enhancement and Inspection Implementation Schedule 1 Refueling Target Estimated AMP - Scope Inspection MethodComment Outage Month/Year EFPY Criteria KR-31 Spring 2011 30.16 Not Applicable Not Applicable MRP-227 inspections in These items are planned for KR-KR-32 Spring 2012 31.15 RCCA guide tubes Guide Plate/Cards accordance with MRP- 32. If not performed in KR-32 228 specifications and they will be inspected in KR-33.

ASME Section XI MRP-227 inspections in Original license expires KR-33 Fall 2013 32.64 Baffle Former Bolts accordance with MRP- December 21, 2013. Expansion 228 specifications and scope will be implemented on an ASME Section XI as needed basis.

Baffle Former Assembly, Baffle-edge bolts and locking MRP-227 inspections in Core barrel removed this outage.

KR-34 Spring 2015 34.03 devices, Baffle-former bolts, Upper core barrel flange weld, accordance with MRP- Expansion scope will be RCCA guide tubes flanges lower welds, RCCA guide tubes 228 specifications and implemented on an as needed guide plates/ cards, Thermal shield flexures, CASS items ASME Section XI basis.

KR-35 Fall 2016 35.52 Not Applicable Not Applicable KR-36 Spring 2018 36.91 Not Applicable Not Applicable KR-37 Fall 2019 38.40 Not Applicable Not Applicable KR-38 Spring 2021 39.79 Not Applicable Not Applicable KR-39 Fall 2022 41.28 Not Applicable Not Applicable Baffle Former Assembly, Baffle-edge bolts and locking MRP-227 inspections in Core barrel may be removed this KR-40 Spring 2024 42.67 devices, Baffle-former bolts, Upper core barrel flange weld, accordance with MRP- outage. Expansion scope will be RCCA guide tubes flanges lower welds, RCCA guide tubes 228 specifications and implemented on an as needed guide plates/ cards, Thermal shield flexures, CASS items ASME Section XI basis.

KR-41 Fall 2025 44.16 Not Applicable Not Applicable KR-42 Spring 2027 45.55 Not Applicable Not Applicable KR-43 Fall 2028 47.04 Not Applicable Not Applicable KR-44 Spring 2030 48.43 Not Applicable Not Applicable KR-45 Fall 2031 49.92 Not Applicable Not Applicable KR-46 Spring 2033 51.31 Not Applicable Not Applicable Footnote 1 - Table 3 is for illustration, refer to the KPS ISI Program and IDDEAL for the implementation inspection schedule.

KLR-1309A, Rev. 3 Page 41 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 4 - Detailed MRP-227 Reactor Vessel Internals - Component Inspection Requirements 1 RVI LR Effect LR Aging Examination MRP-227 Information Component Mechanism Coverage Categqory Required Inspection Schedule Re-inspection Expansion Inspections Schedule Control Rod Loss of material Wear 20% Primary VT No later than 2 RFO Subsequent exams None Guide Tube examination of measurements from beginning of required on a ten Assembly the number of license renewal period, year interval per Guide plates CRGT and no earlier than two MRP-227 Rev. 0 (cards) assemblies, refueling outages prior with all guide to the start of the license cards within renewal period.

each selected Subsequent CRGT examinations are assembly required on a ten-year examined, interval.

Control Rod Cracking Stress corrosion 100% of outer Primary EVT-1 No later than 2 refueling Subsequent exams Bottom-Guide Tube cracking, Fatigue (accessible) outages from the required on a ten mounted Assembly CRGT lower beginning of the license year interval per instrumentation Lower flange flange weld renewal period and MRP-227 Rev. 0 (BMI) column welds surfaces and subsequent examination bodies, Lower adjacent base on a ten-year interval, support column metal. bodies (cast)

Core Barrel Cracking Stress corrosion 100% of one Primary EVT-1 No later than 2 refueling Subsequent Remaining core Assembly cracking side of the outages from the examinations on a barrel welds, Upper core accessible beginning of the license ten-year interval Lower support barrelflange surfaces of the renewal period and column bodies weld selected weld subsequent examination (non cast) and adjacent on a ten-year interval.

base metal.

Page 42 of 62 KLR-1309A, Rev.Rev. 33 Page 42 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS Table 4 - Detailed MRP-227 Reactor Vessel Internals - Component Inspection Requirements' RVI LR Effect LRA qing Examination MRP-227 Information Component Mechanism Coverage Catecqory Required Inspection Schedule Re-inspection Expansion Inspections Schedule Baffle-Former Cracking that results Irradiation-assisted Bolts and Primary VT-3 Baseline examination Subsequent exams None Assembly in stress corrosion locking devices between 20 and 40 required on a ten Baffle-edge cracking, Fatigue on high fluence EFPY'and subsequent year interval per bolts -Lost or broken seams. 100% examinations on a ten- MRP-227 Rev. 0 locking devices of components year interval.

accessible from

-Failed or missing core side.

bolts

-Protrusion of bolt heads)

Baffle-Former Cracking Irradiation-assisted 100% of Primary UT Baseline volumetric (UT) Subsequent exams Lower support Assembly stress corrosion accessible bolts examination between 25 required after 10 to column bolts, Baffle-former cracking, Fatigue or as supported and 35 EFPY, with 15 additional EFPY Barrel-former bolts by plant specific subsequent examination bolts justification after 10 to 15 additional EFPY to confirm stability Heads of bolting pattern. Re-accessible from examination for high the core side. leakage core designs UT accessibility requires continuing may be affected examinations on a ten-by complexity of year interval.

head and locking device designs.

Page 43 of 62 KLR-1 KLR-1309A, Rev. 33 309A, Rev. Page 43 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS 1

Table 4 - Detailed MRP-227 Reactor Vessel Internals - Component Inspection Requirements RVI LR Effect LR Aging Examination MRP-227 Information Component Mechanism Coverage Category Required Inspection Schedule Re-inspection Expansion Inspections Schedule Baffle-Former Changes in Void swelling or Core side Primary VT-3 Baseline examination Subsequent exams None Assembly dimensions and Irradiation-assisted surface as between 20 and 40 required on a ten Assembly cracking that results stress corrosion indicated. EFPY and subsequent year interval per in cracking examinations on a ten- MRP - 227 Rev. 0 year interval.

- Abnormal interaction with fuel assemblies

- Gaps along high fluence baffle joint

- Vertical displacement of baffle plates near high fluence joint

- Broken or damaged edge bolt locking systems along high fluence baffle joint Thermal Shield Cracking or loss of Fatigue or wear 100% of thermal Primary VT-3 No later than 2 refueling Subsequent exams None Assembly material that results shield flexures outages from the required on a ten Thermal shield in thermal shield beginning of the license year interval per flexures flexures excessive renewal period. MRP - 227 Rev. 0 wear, fracture, or Subsequent complete separation examinations on a ten-year interval.

Page 44 of 62 KLR-1 KLR-1309A, Rev. 3 309A, Rev. 3 Page 44 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 4 - Detailed MRP-227 Reactor Vessel Internals - Component Inspection Requirements 1 RVI LR Effect LR Aging Examination MRP-227 Information Component Mechanism Coverage Category Required Inspection Schedule Re-inspection Expansion Inspections Schedule Core Barrel Cracking Irradiation-assisted 100% of Expansion UT Initial and subsequent Subsequent None Assembly stress corrosion accessible examinations dependent examinations Barrel-former cracking, Fatigue bolts. on results of baffle- dependent on bolts Accessibility former bolt examinations. results of baffle-may be limited former bolt by presence of examinations.

thermal shields or neutron pads.

Lower Support Cracking Irradiation-assisted 100% of Expansion UT Initial and subsequent Subsequent None Assembly stress corrosion accessible bolts examinations dependent examinations Lower support cracking, Fatigue or as supported on results of baffle- dependent on column bolts by plant-specific former bolt examinations. results of baffle-justification. former bolt examinations.

Core Barrel Cracking Stress corrosion 100% of one Expansion EVT-1 Initial examination and Reexamination None Assembly cracking, fatigue side of the reexamination frequency frequency accessible dependent on the dependent on the Core barrel surfaces of the examination results for examination results flange, Core selected weld upper core barrel flange. for upper core barreloutlet and adjacent barrel flange.

nozzles, Lower base metal.

core barrel flange weld Lower Support Cracking Irradiation-assisted 100% of Expansion EVT-1 Initial examination and Reexamination None Assembly stress corrosion accessible reexamination frequency frequency Lower support cracking surfaces. dependent on the dependent on the column bodies examination results for examination results (non cast) upper core barrel flange for upper core weld. barrel flange weld.

Page 45 of 62 KLR-1309A, Rev. 33 KLR-1309A, Rev. Page 45 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS Table 4 - Detailed MRP-227 Reactor Vessel Internals - Component Inspection Requirements' RVI LR Effect LR Aging Examination MRP-227 Information Component Mechanism Coverage Category Required Inspection Schedule Re-inspection Expansion Inspections Schedule Lower Support Cracking including Irradiation-assisted 100% of Expansion EVT-1 Initial examination and Reexamination None Assembly the detection of -stress corrosion accessible reexamination frequency frequency Lower support fractured support cracking support dependent on the dependent on the column bodies columns columns. examination results for examination results (cast) control rod guide tube for control rod (CRGT) lower flanges. guide tube (CRGT) lower flanges.

Bottom Cracking including Fatigue 100% of BMI Expansion VT-3 Examination of BMI Flux thimble None Mounted the detection of column bodies column bodies as insertion/withdrawa Instrumentation completely fractured for which indicated by difficulty of I to be monitored at System column bodies difficulty is insertion/withdrawal of each inspection Bottom- detected during flux thimbles. Flux interval.

mounted flux thimble thimble instrumentation insertion/ insertion/withdrawal to be (BMI) column withdrawal. monitored at each bodies inspection interval.

Core Barrel Loss of material Wear All accessible Existing VT-3 Each 10 Year Interval Per Section XI None Assembly Core surfaces at Programs Per Section XI Category Barrel Flange specified B-N-3.

frequency.

Upper Internals Cracking SCC, Fatigue All accessible Existing VT-3 Each 10 Year Interval Per Section XI None Assembly surfaces at Programs Per Section XI Category Upper support specified B-N-3.

ring frequency.

Lower core Loss of material Wear All accessible Existing VT-3 Each 10 Year Interval Per Section XI None plate surfaces at Programs Per Section XI Category specified B-N-3.

frequency.

Page 46 of 62 KLR-1309A, Rev. 33 KLR-1 309A, Rev. Page 46 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS Table 4 - Detailed MRP-227 Reactor Vessel Internals - Component Inspection Requirements 1 RVI LR Effect LR Aging Examination MRP-227 Information Component Mechanism Covera-ge Category Required Inspection Schedule Re-inspection Expansion Inspections Schedule Clevis insert Loss of material and Wear and stress All accessible Existing VT-3 Each 10 Year Interval Per Section XI None bolts cracking relaxation surfaces at Programs Per Section XI Category specified B-N-3.

frequency.

Upper core Loss of material Wear Eddy current Existing VT-3 Each 10 Year Interval Per Section Xl None plate alignment surface Programs Per Section XI Category pins examination as B-N-3.

defined in plant response to IEB 88-09.

Flux thimble Loss of material Wear All accessible Existing Eddy Current ER-AA-NDE-ET-501 Every five years None tubes surfaces at Programs (ET) WDI-ISI-088 specified frequency.

Footnotes:

This table is based on the guidelines of MRP-227 for Westinghouse-designed plants. The following are not listed in this table:

"No Additional Measures" components from MRP-227 for Westinghouse Plants (no additional aging management is necessary for this group).

A comprehensive list of Section XAB-N-3 components and inspections (see KPS "ASME Section XI Inservice Inspection, Subsection IWB, IWC, IWD" program).

Page 47 of 62 KLR-1309A, Rev. Rev. 3 3 Page 47 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS ATTACHMENT 1 IMPLEMENTING PROCEDURES (1) Nuclear Fleet Nondestructive Examination Procedure ER-AA-NDE-VT-608 1 , "VT-3 Visual Examination Procedure for Examination Category B-N-i, Interior of Reactor Vessel."

(2) Topical Report DOM-QA-1 "Dominion Nuclear Facility Quality Assurance Program Description."

(3) Nuclear Fleet Administrative Procedure PI-AA-200, "Corrective Action."

(4) KPS Nuclear Administrative Directive NAD-03.01, "Directive, Implementing Document, and Procedure Control."

(5) KPS General Nuclear Procedure GNP-03.01.01, "Directive, Implementing Document, and Procedure Administrative Controls."

(6) DNAP-0501, "Dominion Nuclear Procedure Administrative Control Program."

(7) Nuclear Fleet Program Description AD-AA-10, "Administrative Controls Program."

(8) Nuclear Fleet Guidance and Reference Document PI-AA-100-1007, "Operating Experience Program."

(9) Nuclear Fleet Program Description ER-AA-RII-10, "Fleet Reactor Internals Inspection."

(10) Nuclear Fleet Administrative Procedure ER-AA-RII-101, "Fleet Reactor Internals Inspection Program."

1 Additional NDE procedures (either fleet, plant-specific, or vendor) will be needed to implement the revised ISI Plan for Reactor Vessel Internals Inspections.

KLR-1309A, Rev. 3 Page 48 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION XI ISI - RVI INSPECTIONS ATTACHMENT 2 ASSOCIATED AGING MANAGEMENT PROGRAMS Aging Management Programs Supporting KLR-1309A.

KLR-1 310, "Primary Water Chemistry" Aging Management Program Supported by KLR-1309A.

KLR-1309, "ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD" Aging Management Programs Verifying the Effectiveness of KLR-1309A.

None Aging Management Programs - Effectiveness Validated by KLR-1309A.

None Page 49 of 62 KLR-1 KLR-1309A, Rev. 33 309A, Rev. Page 49 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS ATTACHMENT 3 MATERIALS AND AGING EFFECTS MANAGED Materials Aging Effects Nickel Alloys Cracking Nickel Alloys, Stainless Steel, Cracking (SCC, PWSCC, and CASS (PWR Reactor IASCC, Fatigue)

Internals Under MRP-227) Loss of material (Wear)

Loss of Fracture Toughness (Neutron Irradiation or Thermal Aging Embrittlement)

Loss of Preload (Thermal and Irradiation-Enhanced Stress relaxation or Creep)

Dimensional Changes (Void Swelling)

Page 50 of 62 KLR-1309A, Rev. 3 KLR-1 309A, Rev. 3 Page 50 of 62

LICENSE RENEWAL PROJECT KEWAUNEE POWER STATION AGING MANAGEMENT PROGRAM ASME SECTION Xl ISI - RVI INSPECTIONS ATTACHMENT 4 INTEGRATED PLANT ASSESSMENT REPORTS SYSTEMS OR COMMODITIES KLR-1 104, "Reactor Vessel, Internals, and Reactor Coolant System" Section 4.2, "Reactor Vessel" Section 4.3, "Reactor Vessel Internals" Section 4.4, "Steam Generator" Page 51 of 62 KLR-1309A, Rev. 3 KLR-1309A, Rev. 3 Page 51 of 62