ML12180A023

Aging Management Programs Audit Report Regarding the Callaway Plant Unit 1 License Renewal Application

ML12180A023
Person / Time
Site:	Callaway
Issue date:	08/09/2012
From:	Cuadradodejesus S License Renewal Projects Branch 1
To:	Heflin A Union Electric Co
CuadradoDeJesus S
References
TAC ME7708
Download: ML12180A023 (96)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 9, 2012 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

AGING MANAGEMENT PROGRAMS AUDIT REPORT REGARDING THE CALLAWAY PLANT UNIT 1 LICENSE RENEWAL APPLICATION (TAC NO. ME7708)

Dear Mr. Heflin:

By letter dated December 15, 2011, Union Electric Company d/b/a Ameren Missouri (the applicant) submitted an application for renewal of operating license NPF-30 for the Callaway Plant Unit 1 (Callaway). On May 10, 2012, the staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) completed the on-site audit of aging management programs. The audit report is enclosed.

If you have any questions, please contact me by telephone at 301-415-2946 or bye-mail at Samuel.CuadradoDeJesus@nrc.gov.

Sincerely,

(;'/2:""'1;:;; /

,~"" /<" );pf amuel Cuadrado de Jesus, ~Ct Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

As stated cc w/encl: Listserv

ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket No:

50-483 License No:

NPF-30 Licensee:

Union Electric Company d/b/a Ameren Missouri Facility:

Callaway Plant Unit 1 Location:

Callaway County, Missouri Dates:

April 30, 2012-May 10, 2012 Reviewers:

S. Cuadrado de Jesús, Project Manager, Division of License Renewal (DLR)

B. Harris, Project Manager, DLR R. Auluck, Branch Chief, DLR B. Pham, Branch Chief, DLR M. Marshall, Branch Chief, DLR W. Holston, Mechanical Engineer, DLR J. Klos, Mechanical Engineer, DLR M. Kichline, Mechanical Engineer, DLR J. Wise, Mechanical Engineer, DLR R. Sun, Mechanical Engineer, DLR K. Green, Mechanical Engineer, DLR J. Gavula, Mechanical Engineer, DLR W. Gardner, General Scientist, DLR K. Karwoski, Sr. Advisor Steam Generator Integrity, DE A. Obodoako, Materials Engineer, DE C. Hunt, Chemical Engineer, DE J. Burke, Mechanical Engineer, DE M. Vera, Project Manager, DLR T. Marenchin, Project Manager, DLR C. Ng, Mechanical Engineer, DLR B. Fu, Mechanical Engineer, DLR S. Min, Mechanical Engineer, DLR O. Yee, Mechanical Engineer, DLR C. Sydnor, Mechanical Engineer, DE D. Brittner, Mechanical Engineer, DLR R. Kalikian, Materials Engineer, DLR J. Medoff, Mechanical Engineer, DLR M. Yoo, General Engineer, DLR B. Lehman, Structural Engineer, DLR A. Prinaris, Structural Engineer, DLR A. Sheikh, Structural Engineer, DLR

A. Istar, Structural Engineer, DLR C. Doutt, Sr. Electrical Engineer, DLR D. Nguyen, Electrical Engineer, DLR R. Li, Electrical Engineer, DLR R. Royal, Consultant (Advanced Technologies and Laboratories)

D. Naus, Consultant (Oak Ridge National Lab)

Approved By:

Rajender Auluck, Chief Aging Management of Plant Systems Branch Division of License Renewal Billy Rogers, Chief Aging Management of Reactor Systems and Guidance Update Branch Division of License Renewal Michael Marshall, Chief Aging Management of Structures, Electrical, and Systems Branch Division of License Renewal

Introduction The U.S. Nuclear Regulatory Commission (NRC or the staff) conducted a 10-day audit at the Callaway Plant Unit 1 (Callaway), in Callaway County, MO, from April 30 to May 10, 2012. The purpose of this audit was to examine Union Electric Company d/b/a Ameren Missouri (the applicants) aging management programs (AMPs) and related documentation to verify the applicants claim of consistency with the corresponding AMPs in NUREG-1801, Revision 2, Generic Aging Lessons Learned (GALL) Report, dated December 2010. As described in the GALL Report, the staff based its evaluation of the adequacy of each AMP on its review of the following 10 program elements in each AMP: 1) scope of program; 2) preventive 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 staffs review of the Callaway license renewal application (LRA) and documented in the staffs safety evaluation report (SER).

NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), Revision 2, dated December 2010, provides staff guidance for reviewing an LRA. The SRP-LR allows an applicant to reference in its LRA, the AMPs described in the GALL Report. By referencing the GALL Report AMPs, the applicant concludes that its AMPs correspond to those AMPs 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 applicants determination should be documented in an auditable form and maintained on site.

During this audit, the staff audited AMP elements 1-6, and 10 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and operating experience). These elements of the applicants 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 April 16-19, 2012, 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 applicants LRA, program-bases documents, and related references; interviewed various applicant representatives; and conducted walkdowns of several plant areas. In total, 42 AMPs were reviewed and 45 breakout (discussion) sessions with applicant representatives were conducted. This report documents the staffs activities during this audit.

LRA AMP B2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD Summary of Information in the Application. The LRA states that AMP B2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD, is an existing program that is consistent with the program elements in GALL Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: cracking, leak, flaw, failure, degradation, and weld.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. EDP-ZZ-01003 Inservice Inspection Program Revision 25

2. LO-WTGGGN-2004-001 Change of Inspection Frequency of N-10 Nozzle 07/30/2005

3. CEP-RR-001 American Society of Mechanical Engineers (ASME)

Section XI Repair/Replacement Program 12/09/2010

4. Calculation EF-109 Design Min Wall Calculation Revision 0

5. QCP-ZZ-05000 Liquid Penetration Examination Revision 21

6. QCP-ZZ-05010 Magnetic Particle Examination Revision 15

7. QCP-ZZ-05025 Ultrasonic Examination of Austenitic Pipe Welds Revision 10

8. QCP-ZZ-05026 Ultrasonic Examination of Ferritic Pipe Welds Revision 9

9. QCP-ZZ-05040 Visual Examination to ASME VT-1 Revision 21

10. CAR 201010669 Detail information for CAR 201010669-RCS Leakage CVCS Letdown Orifice 11/12/2010

11. ML0421804040 ISI Summary Report - RFO 10 12/03/1999

12. ML0421804070 ISI Summary Report - RFO 11 02/21/2003

13. ML0421804020 ISI Summary Report - RFO 12 06/11/2004

14. ML071770133 ISI Summary Report - RFO 14 06/18/2007

15. CAR 200809886 CARs and Action INPO Report. Detail information for CAR 200809886 08/03/2011

16. E170.0105 Callaway NPP Third Interval Inservice Inspection Plan Revision 5

17. CAR 199501891 RCS Leak Detected in Line BB-74-BCA-2 10/04/1995

18. CAR 201011236 Localized Pitting on 8 NPS SCH 40 Pipe Revision 0 During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the detection of aging effects and monitoring and trending program elements insufficient information was available to determine if they were consistent with the corresponding program elements in the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The staff reviewed the applicants Inservice Inspection (ISI) Summary Reports dated from 1999 to 2012 and noted that pin hole leaks in the sites essential service water (ESW) system piping have been detected. Pinhole leaks also have been detected in the chemical and volume control system letdown piping. During the onsite audit of the American Society of Mechanical Engineers (ASME)Section XI Inservice Inspection, Subsections IWB, IWC and IWD Program, the staff reviewed documents indicating that, as mitigative measures, the applicant enhanced its water chemistry control and replaced some of the degraded piping with more corrosion-resistant stainless steel piping during the current 10-year ISI interval, which began on December 19, 2004. However, based on recent inspection results, as documented in the ISI Summary Reports during the current 10-year ISI interval, the staff noted that there were more pinhole leaks detected and repaired, and that the degradation had not been alleviated. In addition, during its onsite audit, the staff reviewed documents indicating that there is still an extensive amount of carbon steel piping in the system that is susceptible to similar degradation.

Therefore, the staff lacks sufficient information to conclude that the AMPs detection of aging effects program element will be effective in timely detection of aging effects, and the monitoring and trending program element will be effective in providing timely corrective or mitigative activities to adequately manage the effects of aging so that the intended function(s) will be maintained consistent with the current licensing basis (CLB) during the period of extended operation.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the final safety analysis report (FSAR) supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, and acceptance criteria are consistent with the corresponding program elements in the GALL Report AMP XI.M1. The staff also identified certain aspects of LRA program elements detection of aging effects, and monitoring and trending that will require additional information or evaluation is required before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.2, Water Chemistry Summary of Information in the Application. The LRA states that AMP B2.1.2, Water Chemistry, 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.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using the keywords: chloride, conductivity, dissolved oxygen, sulfate, and fouling.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1.

Callaway Plant Unit 1 License Renewal Application 12/15/2011

2. APA-ZZ-01020 Primary Chemistry Program Revision 021

3. APA-ZZ-01021 Secondary Chemistry Program Revision 030

4. APA-ZZ-01021, Addendum 1 Action Level Limits Part I and Part II Revision 005

5. APA-ZZ-01021, Addendum 2 Non-Routine Sampling Schedule Revision 002

6. APA-ZZ-01021, Addendum 3 Secondary Water Chemistry Strategic Optimization Plan Revision 003

7. CDP-ZZ-0200 Chemistry Schedule and Water Specs Revision 092

8. CDP-ZZ-0200, Appendix A Water Makeup and Storage Tables Revision 011

9. CDP-ZZ-0200, Appendix B Primary Plant System Tables Revision 025

10. CDP-ZZ-0200, Appendix C Secondary Plant System Tables Revision 017

11. CTO-ZZ-01020 Off Normal Primary Chemistry Corrective Action Revision 007

12. CTO-ZZ-01021 Off Normal Secondary Chemistry Corrective Actions Revision 013

13. EDP-BB-01341 Steam Generator Surveillance Revision 006

14. CTP-ZZ-01000 Miscellaneous Sampling Guidelines Revision 007

15. CTP-SJ-01102 Auxiliary Building Sample Station (SJ-143) Operation Revision 037

16. CTP-RM-01205 RM Panel Sampling Revision 023

17. CDP-ZZ-00110 Chemistry Data Trending Program Revision 004 During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M2.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.3, Reactor Head Closure Stud Bolting Program Summary of Information in the Application. The LRA states that AMP B2.1.3, Reactor Head Closure Stud Bolting Program is an existing program that is consistent with the program elements in GALL Report AMP XI.M3, Reactor Head Closure Stud Bolting. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: bolt, bolting, closure stud, stress corrosion cracking (SCC), wear, and cracking.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.3 Reactor Vessel Head Stud Cleaning and Lubrication Revision 2, 10/05/2011

2. ETP-BB-03150 Reactor Vessel Head Stud Cleaning and Lubrication Revision 14

3. ETP-BB-03155 Reactor Vessel Head Stud Installation Revision 15

4. ETB-BB-03156 Reactor Vessel Head Stud Tensioning Revision 19

5. ETP-BB-03165 Reactor Vessel Head Stud Removal Revision 12

6. ETP-BB-03147 Reactor Vessel Head Removal - IPTE Revision 16

7. EDP-ZZ-01003 Inservice Inspection Program Revision 25 Document Title Revision/Date

8. E 170.0105 Callaway NPP Third Interval ISI Program Plan Revision 5 10/14/2011

9. QCP-ZZ-05040 Visual Examination to ASME VT-1 Revision 21

10. QCP-ZZ-05041 Visual Examination to ASME VT-2 Revision 25

11. AUE-UT-98-5 Ultrasonic Examination of Studs/Bolts Greater than Two Inches in Diameter 03/02/07

12. APA-ZZ-00107 Review of Current Industry Operating Experience Revision 19

13. DEI-234 Stuck Stud Evaluation - Callaway Unit 1 Reactor Vessel October 1987

14. DEI-260 Flange Thread Degradation Callaway Unit 1 Reactor Vessel March 1989

15. CAR 199601632 Reactor Head Stud # 18 Stuck in the Reactor Vessel 10/31/1996

16. RFR 17464 Material Equivalency: Use 2 Spacers in RV Bolting 10/31/1996

17. BB-131 Stress Calculation to Justify the #18 Stud being stuck with 2-5/8" less thread engagement than design 10/31/1996

18. APA-ZZ-00662 ASME Section XI Repair/Replacement Program Revision 19

19. CAR 200404261 RV Stud Hole # 20 Had Rolled Lead Thread 05/20/2004 During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the detection of aging effects, and monitoring and trending program elements insufficient information was available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

During the review of the LRA and the audit of the applicants operating experience for the AMP, the staff noted that the Callaway plant had several occasions when reactor pressure vessel (RPV) closure studs were found to be stuck during stud insertion or removal activities. In some cases, the studs had to be either cut or forcibly removed from their RPV flange stud hole locations. In addition, during the audit the staff noted numerous cases in which the RPV lower flange stud holes have either damaged threads, or if the thread regions were repaired the stud holes had fewer threads than were originally designed. Stuck studs or damaged threads were detected during plant refueling or cold shutdown activities and the amount of damaged threads was only determined after the studs were removed from the flange stud hole locations. Therefore, for studs that are stuck in place, the staff is concerned that the examinations performed in accordance with the Reactor Head Closure Stud Bolting Program, may not be capable of detecting wear or damage in the stud holes or quantifying the amount of wear or damage in the stud holes.

In addition, the staff also noted that additional RPV flange stud holes may have damaged threads. Specifically, the staff noted that the RPV flange stud hole location Nos. 2, 4, 5, 7, 9, 14, 18, 20, 25, 39, 53, and 54 have or may have missing or damaged threads. This represents more than 20 percent of the applicants total number of RPV closure stud bolting. Based on the staffs review of the documents associated with the applicants operating experience, the staff was unable to verify whether the entire RPV flange assembly was re-assessed every time a new RPV stud or stud hole issue arose, or whether the evaluation of the entire flange assembly had accounted for the collective impact of both the current issue and the past flange issues that occurred before the new occurrences. Thus, the staff is uncertain how monitoring and trending is accomplished at the site with respect to this AMP.

During the audit of the operating experience program element, as discussed above, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed above related to operating experience.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the LRA program elements scope of program, preventive actions, parameters monitored or inspected, and acceptance criteria are consistent with the corresponding elements of the GALL Report AMP XI.M3. The staff also identified certain aspects of LRA program elements detection of aging effects and monitoring and trending that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information on operating experience is required before a determination can be made about the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.4, Boric Acid Corrosion Summary of Information in the Application. The LRA states that AMP B2.1.4, Boric Acid Corrosion, is an existing program with enhancements 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. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: corrosive, cracking, degradation, rust, boric, and borated.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.4-Rev 3 Callaway Plant Aging Management Program Evaluation Report, Boric Acid Corrosion - B2.1.4 Revision 3

2. EDP-ZZ-01004 Boric Acid Corrosion Control Program Revision 011

3. EDP-ZZ-001131 Engineering System Walkdowns, Appendix K Revision 001

4. MDP-ZZ-LM001 Fluid Management Program Revision 010

5. CQP-ZZ-05048 Boric Acid Walkdown for RCS Pressure Boundary Revision 007

6. ODP-ZZ-00029 RCS Leakage Action Level Guideline Revision 003

7. NET 12-002 Boric Acid Corrosion Control Program (BACCP) Quarterly Report 01/10/2012

8. NET 12-023 Boric Acid Corrosion Control Program (BACCP) Quarterly Report 04/10/2012

9. CAR 200809886 Leak Identified on Line BG-026-BCB-2 09/26/2008 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 verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M10.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Summary of Information in the Application. The LRA states that AMP B2.1.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components, is an existing program that is consistent with the program elements in GALL Report AMP XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components [pressurized water reactors (PWRs) only]. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using the keywords: nozzle, weld, vessel head, crack, cladding, and PWSCC.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.5-Rev 3 Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components (PWRs Only) - B2.1.5 NUREG 1801 Program XI.M11B Revision 3, 04/12/2012

2. Not applicable Callaway Plant License Renewal Management Industry Operating Experience Report for AMP XI.M11, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components (PWR Only) B2.1.5 02/29/2012

3. EDP-ZZ-04070 Management of Engineering Materials Degradation Management Plan Subprograms Activities (including Appendix A, Alloy 600 Management Plan)

Revision 4

4. EDP-ZZ-01003 Inservice Inspection Program Revision 25

5. QCP-ZZ-05048 Boric Acid Walkdown for RCS Pressure Boundary Revision 7

6. QCP-ZZ-05049 RPV Head Bare Metal Examination Revision 3

7. CAR 201005998 What Has Changed To Eliminate the Upper Core Flow Anomaly?

07/19/2010

8. CAR 200403580 Loop C Cold Leg Stainless Steel Safe End-to-Pipe Weld Indications 04/30/2004

9. CAR 200609622 Evaluate Pressurizer Weld Overlay and Pressurizer Heater Inspection OE 07/25/2007

10. CAR 200706976 OE25024 - PT Indications Discovered at CRDM Penetration 68 11/21/2006

11. CAR 200703900 Indication Visually Detected in the Reactor Vessel Lower Head Cladding 04/14/2007

12. CAR 200700110 Primary System Integrity Review Visit RV Lower Head Cleaning 01/5/2007

13. CAR 200711361 Incomplete Evaluation for Chemical Conditions 11/30/2007

14. CALC. No.

BB-183, Rev. 01 Evaluation of Reactor Vessel Cladding Indication Inside Bottom Head During Refueling 13 1/21/2004 Document Title Revision/Date

15. Not applicable Callaway Nuclear Power Plant Third Interval Inservice Inspection Program Plan Appendix D, Third Interval Examination Schedule Revision 4, 10/14/2011

16. WCAP-13778 Analysis of Thermal Effects on Component Fatigue Resulting from the Upper Plenum Anomaly in Westinghouse PWRs November 1993 During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the parameters monitored or inspected program element, insufficient information was available to determine if it was consistent with the corresponding program element of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The parameters monitored or inspected program element of the LRA AMP, as described in the applicants evaluation report, indicates that reactor coolant pressure boundary (RCPB) cracking and leakage are monitored by the applicants ISI program as augmented by ASME Code Cases N-722-1, N-729-1, and N-770-1, subject to the conditions specified in Title 10 of the Code of Federal Regulations (CFR) Part 50.55a, Codes and standards. The GALL Report AMP recommends that RCPB cracking and leakage are monitored by the applicants ISI program in accordance with 10 CFR 50.55a. ASME Code Case N-770-1 specifies visual examination to detect the reactor coolant leakage and boric acid corrosion associated with Class 1 pressure retaining dissimilar metal piping and vessel nozzle welds. During the audit, the staff noted that the applicants procedure for boric acid walkdown and examination scheduled for the third-interval ISI program plan do not clearly indicate the implementation of visual examination specified in ASME Code Case N-770-1.

During the audit, the staff noted that the applicants operating experience indicates that refueling cavity seal leakage caused a potential to interfere with the visual examinations of dissimilar metal welds on the reactor vessel loop nozzles and bottom-mounted instrument penetrations. The staff needs to clarify what corrective action was taken to prevent the refueling cavity seal leakage, and to correct the conditions (e.g., corrosion product build-up) that would potentially interfere with the visual examination of dissimilar metal welds on the reactor vessel loop nozzles and bottom-mounted instrument penetrations. The applicants implementing procedure for boric acid walkdown for the reactor coolant system does not clearly address how the applicants procedure would resolve the instance when leakage from other locations interferes with the visual examinations of the reactor vessel nozzle welds and other RCPB components specified in ASME Code Cases N-770-1 and N-722-1.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.

During the audit, the staff noted that the applicants operating experience indicates that the reactor coolant system has experienced reactor hot leg temperature fluctuations associated with periodic, opposing step changes in adjacent hot leg temperatures. This phenomenon has been referred to as upper plenum anomaly (UPA), and is apparently caused by a flow switching phenomenon in the reactor vessel upper plenum, as discussed in WCAP-13778, Analysis of Thermal Effects on Component Fatigue Resulting from the Upper Plenum Anomaly in Westinghouse PWRs, dated November 1993. The UPA may increase the local temperatures of the reactor hot leg nozzles above 625 °F (329 °C) due to non-symmetrical flow mixing such that Inspection Item A-1, rather than A-2, of ASME Code Case N-770-1 should be applied to the inspections of the applicants reactor hot leg nozzles. It is not clear to the staff how the applicants program evaluates the potential effect of the UPA on the reactor hot leg nozzle temperatures and determines which inspection item to apply (that is, Inspection Item A-1 or A-2).

LRA Section B2.1.5 also addresses the operating experience regarding the RPV lower head cladding as follows:

An indication was visually detected in the RPV lower head cladding in 2007, during the remote VT-3 examination of the vessel interior. The indication was evaluated and additional volumetric and surface examinations were performed for better characterization. The operating experience also indicates that the indication was determined to be acceptable as is.

During the audit, the staff noted that the applicants RPV bottom head region has at least two indications of cladding degradation [detected in refueling outages (RFOs) 13 and 15, respectively], as also addressed in LRA Section 4.7.3. The staff needs to confirm the total number of RPV cladding degradation indications detected on the applicants reactor vessel. In addition, the staff noted that the LRA does not provide the following information on the cladding and vessel degradation: (1) the root cause analysis and corrective action for the cladding indications, (2) the previous inspection results to identify any change in the size and depth of the cladding indications, and (3) the inspection method and frequency to manage the degradation of the cladding and RPV and the technical basis for the adequacy of the inspection method and frequency.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the LRA program elements scope of program, preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M11B. The staff also identified certain aspects of LRA program element parameters monitored or inspected that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information on operating experience is required before a determination can be made about the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.6, PWR Vessel Internals Summary of Information in the Application. The LRA states that AMP B2.1.6, PWR Vessel Internals, is a new program that is consistent with the program elements in GALL Report AMP XI.M16A, PWR Vessel Internals. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using the keywords: cracking, SCC, loss of preload, and loss of material.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.6 Callaway Plant Program Evaluation Report B2.1.6 Revision 2

2. CW-SCO-BBVI Reactor Vessel & Internals: Callaway System and Structure Scoping Report Revision 1

3. MP 02-1024 Replace Guide Tube Support Pins from the Upper Internals and Replace with a Different Design/Material Pin Revision A

4. RVIAMD E170.0002/R071 Reactor Vessel Internals Aging Management Document Revision 0, December 2011

5. LTR-RIDA-12-59 Callaway Unit 1 - Request for Reactor Vessel Internals Material Certifications 03/13/2012

6. CAR 200904268 MRP-227 Implementation Program for Reactor Internals Inspection Revision 1 During the audit of program elements 1-6, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the scope of program program element, insufficient information was available to determine if it was consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The Callaway reactor vessel internals design does not include thermal shield flexures and includes neutron shield panels instead. However, the LRA states fatigue analyses were performed on reactor vessel internals components, including the thermal shield flexures. It is not clear to the staff if Callaway has thermal shield flexures and whether the neutron shield panels provided the same intended function as the thermal shield flexures.

The scope of program program element of the LRA AMP does not include the upper support ring or skirt. However, the GALL Report AMP recommends that the upper support ring or skirt be in scope as an Existing program component. It is not clear to the staff if there is another component that performed the intended function of the upper support ring or skirt and how that component will be inspected.

The scope of program program element of the LRA AMP includes a list of components classified as Existing program components. The GALL Report AMP recommends that components examined per ASME Code Section XI, Table IWB-2510, B-N-3, be included in the list of Existing program components. It is not clear to the staff which Existing program components are inspected under Examination Category B-N-3 and if the ISI plan for performing VT-3 examinations will achieve coverage for those reactor vessel internals component locations designated as the B-N-3 components.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

There is currently a draft license renewal interim staff guidance (LR-ISG-2011-04), Updated Aging Management Criteria for PWR Reactor Vessel Internal Components. Since the LR-ISG is still in draft form and may change, the applicants program may also change. Future RAIs are possible to account for changes to LR-ISG-2011-04 and the applicants program.

Audit Results. Based on this audit, the staff verified that the LRA program elements preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M16A. The staff also identified certain aspects of LRA program element scope of program that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.7, Flow-Accelerated Corrosion Summary of Information in the Application. The LRA states that AMP B2.1.7, 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. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using the keywords: flow accelerated, erosion, and flow assist.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.7 Callaway Plant Aging Management Program Evaluation Report, Flow-Accelerated Corrosion Revision 4, 11/28/2011

2. EDP-ZZ-01115 Flow-Accelerated Corrosion [FAC] of Piping and Components Predictive Performance Manual Revision 23

3. ME-004 Engineering Design Guide - Material Selection Revision 1, 12/12/2000

4. ME-013 Pipe Wall Thickness Revision 1, 09/17/2007

5. 4501-01 Callaway Nuclear Plant FAC System Susceptibility Evaluation Revision 0 02/08/2008

6. 4501-02 Callaway Nuclear Plant FAC Susceptible Non-Modeled Program Revision 0, 02/13/2008

7. CAR 200102270 Main Feedwater System Component Wall Thinning 04/22/2001

8. CAR 200403322 RF 13 FAC Results in the Main Feedwater System 04/24/2004

9. CAR 200500411 Unexpected Lowering of Flow during Startup 01/22/2005

10. CAR 200811208 TAF03A Inlet Nozzle Thinning 10/28/2008

11. CAR 201004190 Valve Found with Internal Erosion 05/10/2010

12. FMWE v2.0 FAC Manager Web Edition User Guide Revision 0, 06/01/2010

13. NET 11-0104 Flow Accelerated Corrosion Refuel 18 Outage Report 11/21/2011

14. NET 10-0026 Refuel 17 Flow Accelerated Corrosion Report 05/15/ 2010

15. DTI-E-00004 Flow-Accelerated Corrosion Program Desktop Instruction Revision 1, 08/27/2009

16. ULNRC-1591 Callaway Plant Response to I&E Bulletin 87-01, Thinning of Pipe Wall in Nuclear Power Plants 09/10/1987 During the audit of program elements 1-6, the staff verified that the preventive actions, parameters monitored or inspected, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the scope of program, detection of aging effects, and acceptance criteria program elements, insufficient information was available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

LRA Table 3.3.2-10, Auxiliary Systems - Summary of Aging Management Evaluation -

Chemical and Volume Control System, includes an item for carbon steel piping that is being managed for wall thinning by the Flow-Accelerated Corrosion program. However, Appendix A of the System Susceptibility Evaluation for the Flow-Accelerated Corrosion program states that the chemical and volume control system (BG) is excluded from the Flow-Accelerated Corrosion program based on non-susceptible material. It is not clear to the staff whether the LRA is crediting the Flow-Accelerated Corrosion program for managing portions of a system that has been excluded from the Flow-Accelerated Corrosion program in the System Susceptibility Evaluation, or whether the system has susceptible material that was not evaluated in the System Susceptibility Evaluation.

The LRA AMP description states that the program uses baseline and follow-up inspections using ultrasonic, visual, or other approved testing techniques capable of detecting wall thinning. In the detection of aging effects program element, the GALL Report AMP recommends ultrasonic or radiographic testing to detect wall thinning, but does not discuss visual inspections. Since visual inspections were not further described in the Callaway Plant AMP Evaluation Report or in the implementing procedures for this program, it is not clear to the staff whether the applicant uses visual inspections instead of ultrasonic or radiographic testing to detect wall thinning.

The LRA AMP description states that the [Flow-Accelerated Corrosion (FAC)] Manager Web Edition is used to calculate component wear, wear rate, and the next scheduled inspection. In the acceptance criteria program element, the GALL Report AMP states that inspection results are input for a predictive code to calculate the number of operating cycles remaining before the component reaches the minimum allowable wall thickness. Industry guidance, NSAC-202L, states that, to account for wear rate inaccuracies when calculating remaining service life, the minimum safety factor should never be less than 1.1. The Flow-Accelerated Corrosion program implementing procedure, EDP-ZZ-01115, uses a safety factor of 1.1 in calculating an Inspection Index for some situations, but it is not clear to the staff whether a safety factor of 1.1 is used in all situations, and whether any safety factor is used in calculating the next scheduled inspection within FAC Manager Web Edition.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is not bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LR AMP, the staff will consider issuing RAIs for the subjects discussed below.

The Callaway Plant AMP Evaluation Report included a Callaway Action Request (CAR) that cited loss of material due to erosion as an aging effect addressed by this AMP. In addition, CAR 200102270, which was discussed in the above Operating Experience Report, contained a corrective action to prevent recurrence for wall thinning in main feedwater components, stating, expanded the scope of wall thinning inspections to include other potential damage mechanisms (impingement, cavitation, etc.). Further, CAR 201004190 discussed valve with internal erosion and adjacent pipe wall erosion.

It was not clear to the staff whether mechanisms other than FAC were being managed in this program.

CAR 20043322 states that for component AE05-AB590, this calculation decreased the design minimum thickness required by utilizing the measured ultimate tensile strength listed in the Certified Materials Test Report (CMTR). In justifying the use of CMTR data in the calculation of the minimum wall thickness, the applicant provided Engineering Design Guide, ME013, Pipe Wall Thickness, which stated that it is permissible to use CMTR data instead of published allowable stress values. However, the use of CMTR data to decrease the minimum wall thickness is not consistent with the staffs understanding of the ASME Code.

CAR 200500411 described the failure of a flow tube due to FAC that separated from its venturi throat, migrated downstream, and blocked the minimum recirculation flow. The spool piece containing the flow venturi had been inspected in 2004 and was projected to last more than 50 years; however, the configuration of the flow element does not allow it to be inspected from the outside of the pipe using ultrasonic testing methods. While the wall thinning due to FAC is not unique, this circumstance is unique because normal wall thinning inspections cannot be used to monitor ongoing wall thinning of a passive component. Furthermore, the consequence of FAC resulted in macrofouling, and this plant-specific operating experience is not bounded by the industry operating experience for which the GALL Report program was evaluated.

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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing RAIs for the subject discussed below.

The FSAR supplement states that inspections are performed using ultrasonic, visual, or other approved testing techniques capable of detecting wall thinning; however, it is not clear to the staff that visual inspections alone are capable of detecting wall thinning.

This issue can be included with the RAI for the detection of aging effects program element discussed above.

Audit Results. Based on this audit, the staff verified that the LRA program elements preventive actions, parameters monitored or inspected, and monitoring and trending are consistent with the corresponding program elements in GALL Report AMP XI.M17. The staff also identified certain aspects of LRA program elements scope of program, detection of aging effects, and acceptance criteria that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information on operating experience is required before a determination can be made about the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.8, Bolting Integrity Summary of Information in the Application. The LRA states that AMP B2.1.8, Bolting Integrity, is an existing program with enhancements 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. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency, these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted a walkdown of the B Emergency Diesel Generator room. The staff also conducted an independent search of the applicants operating experience database using keywords: bolt, torque, preload, crack, SCC, leak, flange, lubrication, and moly.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.8 Bolting Integrity Revision 3, 04/12/2012

2. APA-ZZ-00500 Corrective Action Program Revision 54

3. APA-ZZ-00400 Procurement of Parts, Supplies, Materials, and Services Revision 37

4. APA-ZZ-00662 ASME Section XI Repair/Replacement Program Revision 20

5. Not applicable Callaway Plant Bolting Manual Revision 8, 03/27/2012

6. E170.0105 Callaway Nuclear Power Plant Third Interval Inservice Inspection Program Plan Revision 5, 10/19/2011

7. EDP-ZZ-01003 Inservice Inspection Program Revision 25

8. EDP-ZZ-01131 Plant Health and Performance Monitoring Program Revision 21

9. EDP-ZZ-01131 Appendix K, Engineering System Walkdowns Revision 1

10. MDP-ZZ-LM001 Fluid Leak Management Program Revision 11

11. MDP-ZZ-LR001 Temporary Repair of Leaks Revision 3

12. CAR 201102260 Determine If Callaway Procedures Fulfill Recommendations of GL 91-17 03/22/2011

13. QCP-ZZ-05018 Ultrasonic Examination of Bolting Revision 6

14. CAR 200703805 Damaged Stuck Studs 04/12/2007

15. CAR 200703822 Damaged Stuck Studs 04/13/2007

16. CAR 200703691 Damaged Stuck Studs 04/11/2007

17. CAR 200906224 Remove Stuck Studs 08/09/2009

18. CAR 200001317 Missing Torque Values in Work Package 06/02/2000

19. CAR 200002198 Missing Torque Values in Work Package 09/10/2000

20. CAR 200403325 Overtorqued Studs 04/24/2004 Document Title Revision/Date

21. CAR 200810176 Wrong Bolt Material 10/07/2008 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 verified that the scope of program, preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the parameters monitored or inspected program element, sufficient information was not available to determine if it was consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

The parameters monitored or inspected program element of the GALL Report AMP states that the program monitors the effects of aging on the intended function of bolting, and that components should be inspected for leakage, loss of material, cracking, and loss of preload. However, between 1985 and 1987, Callaway installed seal cap enclosures on four swing check valves to mitigate gasket leakage from the bolted body-to-bonnet flange joint. The use of seal cap enclosures as mitigation for leakage may prevent the bolting within the enclosure from being managed for loss of preload, cracking, and loss of material aging effects since the enclosure prevents direct inspection of the bolted joint. The known seal cap enclosures have since been removed; however, it is not clear to the staff whether additional seal cap enclosures have been installed or if seal cap enclosures are still used at the site to mitigate leakage.

Furthermore, the staff requested clarification on how the use of seal cap enclosures is controlled such that aging effects can be managed in the period of extended operation.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M18. The staff also identified certain aspects of LRA program element parameters monitored or inspected that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.9, Steam Generators Summary of Information in the Application. The LRA states that AMP B2.1.9, Steam Generators, is an existing program that is consistent with the program elements in GALL Report AMP X1.M19, Steam Generators. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using the keywords: steam generator, tube, leakage, and eddy current.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.9 Steam Generators Revision 5

2. APA-ZZ-00801 Foreign Material Exclusion Revision 031

3. APA-ZZ-01023 Primary-to-Secondary Leakage Program Revision 019

4. EDP-BB-01341 Steam Generator Surveillance Revision 006

5. ETP-BB-01314 Steam Generator Secondary Upper Internals Inspection Revision 004

6. ETP-BB-01315 Secondary Side Inspection Plan and Procedure Revision 008

7. S-1032 Technical Specification [(TS)] for Steam Generator Maintenance Services Revision 12

8. ETP-AE-03000 Upper Bundle Flush and Water (Sludge) Lancing Revision 010

9. ETP-BB-01309 Steam Generator Eddy Current Testing and Analysis Guidelines Revision 022

10. AREVA NP 51-9172264-000 Callaway Unit-1 SG [Steam Generator] Condition Monitoring for Cycles 16, 17, and 18 and Final Operational Assessment for Cycles 19, 20, and 21.

10/18/2010

11. AREVA 51-9034988-000 Callaway EOC [End-of-Cycle] 15 Steam Generator Degradation Assessment 03/20/2007

12. AREVA NP 51-9167781-000 Callaway 1R18 Degradation Assessment October 2011 10/18/2010

13. AREVA 51-9048595-000 Condition Monitoring an Operational Assessment for Callaway (EOC-15) 03/30/2006 During the audit of program elements 1-6, the staff verified that the scope of program program element of the LRA AMP is consistent with the corresponding element of the GALL Report AMP. For the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements, insufficient information was available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP state, in general, that Nuclear Energy Institute (NEI) 97-06, Steam Generator Program Guidelines, and the associated Electric Power Research Institute (EPRI) guidelines will be followed for the steam generator AMP. The GALL Report AMP indicates that the NEI 97-06 program and the associated EPRI guidelines have been effective at ensuring steam generator integrity. It is not clear to the staff that the applicants program is consistent with NEI 97-06 and the associated EPRI guidelines since several apparent discrepancies were identified as discussed below.

NEI 97-06, Steam Generator Program Guidelines, Revision 3, was to be implemented by September 1, 2011. The Technical Specification (TS) for Steam Generator Maintenance Services (S-1032) was used for the RFO 18 steam generator tube inspections (which began after October 15, 2011). This document (S-1032) references NEI 97-06, Revision 2, in Section 4.2.A.4. If NEI 97-06, Revision 2, was used it would not be consistent with the industry program and a deviation should have been processed per NEI 03-08. This information could not be located by the staff.

The term active degradation is used in EDP-BB-01341, Steam Generator Surveillance (e.g., refer to Sections 4.4.1.4, 4.9.7.c, and 7.1). This term, as originally defined, was misleading and is no longer used in the Pressurized Water Reactor Steam Generator Examination Guidelines, which were issued in 2007. The use of the term active degradation appears to be inconsistent with industry guidelines.

Section 4.1.2.c.3 of EDP-BB-01341, Steam Generator Surveillance, indicates that if implementation of a guideline change cannot be performed within 3 months of the due date then a deviation should be processed. This appears to permit implementing the guideline change 3 months after the due date. It is not clear that this 3-month extension is permitted by the industry guidelines (i.e., if the forwarding letter indicates the guideline change should be implemented by a specific date, it is not clear that a 3-month automatic extension is justified).

Section 4.5.1 of EDP-BB-01341, Steam Generator Surveillance, deals with secondary side inspections; however, Section 4.5.1.a refers to primary side maintenance activities.

This appears to be a typographical error; however, it may result in the procedures being inconsistent with the EPRI guidelines.

Section 4.10.3 of EDP-BB-01341, Steam Generator Surveillance, requires the condition monitoring report to be completed within 30 days following completion of the outage; however, Section 4.9.6.a.1 requires the condition monitoring report to be completed prior to Mode 4 after a steam generator inspection. The EPRI Steam Generator Integrity Assessment Guidelines (Section 1.2.2) requires the condition monitoring assessment to be completed before Mode 4. There appears to be an internal discrepancy on the requirement pertaining to completion of the condition monitoring report that draws into question whether the industry guidelines are being followed.

Section 4.8.5.e of EDP-BB-01341, Steam Generator Surveillance, refers to degradation of interest rather than existing and potential degradation as discussed in the EPRI Steam Generator Integrity Assessment Guidelines (Section 6.2). A definition of degradation of interest could not be located in the procedure to permit confirmation that this procedure is consistent with industry guidelines.

AREVA NP, Inc. Document No. 51-9172264-000, Callaway Unit-1 SG [Steam Generator] Condition Monitoring for Cycles 16, 17, and 18 and Final Operational Assessment for Cycles 19, 20, and 21, does not appear to justify the length of the operating interval for secondary side degradation. Section 10.3 of the EPRI Steam Generator Integrity Assessment Guidelines indicates that the operational assessment shall include a justification for operating the planned interval between secondary side inspections as well as primary side inspections. If a justification to operate for the planned operating interval is not performed for secondary side degradation, it would be inconsistent with industry guidelines.

Section 8.6 of the EPRI Steam Generator Integrity Assessment Guidelines indicates, in part, that (1) failure to meet condition monitoring requirements means that the projections of the previous operational assessment were not conservative and that necessary corrective actions shall be identified, and (2) even if condition monitoring requirements are met, a comparison of condition monitoring results with the projections of the previous operational assessment shall be performed and that this comparison shall be completed prior to issuance of the final operational assessment since adjustment of input parameters may be required.

In AREVA NP, Inc. Document No. 51-9172264-000, Callaway Unit-1 SG [Steam Generator] Condition Monitoring for Cycles 16, 17, and 18 and Final Operational Assessment for Cycles 19, 20, and 21, there is a statement that the latter must be performed, but then the report went on to indicate that the assumptions and uncertainties included in the previous operational assessment are validated since none of the detected indications approach the condition monitoring limit and that additional discussions below provide further details. The staff could not locate these additional discussions. In addition, in reviewing the previous operational assessment, the staff could not locate any specific projections such that a comparison of the as-found and previously projected conditions could be compared. It is not clear that the intent of the EPRI requirement has been met. The staff notes that the operational assessment is supposed to be conservative. As a result, even if the actual detected conditions are near (including slightly below) the projections from the previous operational assessment, this could indicate a potential nonconservative assessment that may lead to issues in the future, if not corrected.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the LRA 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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing RAIs for the subject discussed below.

The FSAR supplement for steam generators (LRA Section A1.9) indicates that the tube structural integrity limits consistent with Regulatory Guide (RG) 1.121, Bases for Plugging Degraded PWR [Pressurized Water Reactor] Steam Generator Tubes, are applied. The structural integrity requirements for steam generator tubes are specified in the plants TSs. Although RG 1.121 provides guidance and a methodology for determining steam generator tube plugging limits, the actual requirements for tube integrity are contained in the plants TSs. It would appear more complete to indicate that structural limits consistent with the steam generator structural integrity performance criteria (specified in the plant technical specifications) are applied.

Audit Results. Based on this audit, the staff verified that the LRA program element scope of program is consistent with the corresponding program element in GALL Report AMP X1.M19.

The staff also identified certain aspects of LRA program elements preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.10, Open-Cycle Cooling Water System Summary of Information in the Application. The LRA states that AMP B2.1.10, Open-Cycle Cooling Water System, is an existing program with an enhancement 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. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes an enhancement necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted partial walkdowns of the ultimate heat sink cooling tower and the essential service water pump house. The staff also conducted an independent search of the applicants operating experience database using keywords: coating, erosion, fouling, microbiological, service water, and through wall.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.10 Callaway Plant Aging Management Program Evaluation Report, Open-Cycle Cooling Water System Revision 3, 04/08/2012

2. ULNRC-2146 Callaway Plant Response to Generic Letter 89-13, Service Water System Problems Affecting Safety Related Equipment 01/29/1990

3. ULNRC-05425 Callaway Plant Cycle 15 Commitment Change Summary Report 07/16/2007

4. EDP-ZZ-01121 Raw Water Systems Predictive Performance Program Revision 14

5. EDP-ZZ-01112 Heat Exchanger Predictive Performance Manual Revision 17

6. ETP-ZZ-03001 GL 89-13 Heat Exchanger Inspection Revision 9

7. APA-ZZ-01025 Raw Water Systems Control Program Revision 0

8. CAR200608086 ESW Pipe Preservation 10/01/2006

9. CAR200700441 New Commitments to GL 89-13 01/17/2007

10. CAR200703627 ISP-SA-2413A/B Procedure Revision in 1993 Causing ESW System Transient 04/10/2007

11. CAR200703680 Flange on EF-007-HB-30" to EFV113 Has Corrosion Damage 04/11/2007

12. CAR200703776 PEF01B Potential Erosion Damage on Pump Discharge 04/12/2007

13. CAR200800415 Service Water System Components with MIC Index Greater Than 50 01/17/2008 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 verified that the scope of program, preventive actions, and monitoring and trending, program elements of the LRA AMP are consistent with the corresponding element of the GALL Report AMP. In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, and acceptance criteria, program elements sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

GALL AMP XI.M20, detection of aging effects, states that inspection methods (e.g., visual or nondestructive examination) are in accordance with the applicants docketed response to Generic Letter (GL) 89-13. Callaway responded to GL 89-13, by letter dated January 29, 1990, and stated that selected sections of ESW piping are inspected each RFO and that each pipe is radiographed to determine any localized pitting. This is followed by ultrasonic testing using accurately placed grid locations to determine the extent of any damage. However, the AMP Evaluation Report and the implementing procedure EDP-ZZ-01121do not describe the use of radiography as part of the program, which appears to be inconsistent with the docketed response to GL 89-13.

GALL AMP XI.M20 program element detection of aging effects, states that when sampling is used in condition monitoring programs, the basis for the inspection population and sample size should be provided. However, information provided during the audit did not include the number or selection criteria for the locations being trended by the program. In addition, procedure EDP-ZZ-01121 included an appendix with Non-Trended Monitored Locations for Raw Water Program, but did not describe the identification criteria and purpose of these non-trended locations.

GALL AMP XI.M20 program element parameters monitored or inspected, discusses inspections of coatings. However, the AMP Evaluation Report states that the amount of coating surface area is relatively small and its aging has not been a concern for ESW system performance, and does not indicate that inspection of coatings are credited as part of this program.

GALL AMP XI.M20, detection of aging effects, states that inspection scope is in accordance with the applicants docketed response to GL 89-13. Callaway modified its commitments to GL 89-13, by letter dated July 7, 2007, stating that for various room coolers, monitoring methods will be fin inspection and cleaning per EDP-ZZ-01112 and that thermography also will be performed on these heat exchangers as a method of predictive performance monitoring. For the containment air coolers, the letter states that the primary monitoring method will be cleaning and inspection of the outer coil fins per EDP-ZZ-01112. However, EDP-ZZ-01112 did not appear to address inspection or cleaning for room cooler or the containment air cooler fins. In addition, aging management review (AMR) items in LRA Tables 3.3.2-19 and 3.3.2-15 cited heat transfer as an intended function for these air heat exchangers, but does not cite reduction of heat transfer as an aging effect requiring management (AERM).

GALL AMP XI.M20, acceptance criteria, states that inspected components should exhibit adequate design margin. During its review of operating experience reports, the staff noted that CAR 200703680 justified the structural integrity of a damaged flange by stating that the standard Class 3 manufacturing tolerance of 12.5 percent provides assurance that the corrosion damage on a 30-inch flange is not a structural or pressure boundary issue. However, the staff notes that the 12.5 percent manufacturing tolerance typically only applies to pipe wall thickness and not to flange thickness.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject discussed below.

Due to the pervasive degradation of the ESW system, it was not clear what enhancements were made to the AMP to address the consequences of past program weaknesses. Since additional leaks continue to be identified, it is unclear what specific corrective actions were taken to prevent recurrence of the identified problems, and whether additional replacement activities will be credited for license renewal.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending are consistent with the corresponding program elements in GALL Report AMP XI.M20. The staff also identified certain aspects of LRA program elements parameters monitored or inspected, detection of aging effects, and acceptance criteria for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff also identified that additional information about operating experience is required before a determination can be made about the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.11, Closed Treated Water Systems Summary of Information in the Application. The LRA states that AMP B2.1.11, Closed Treated Water Systems, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M21A, Closed Treated Water Systems. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: corrosive, cracking, crevice, pitting, rust, fouling, biofoul, microbiological, and wastage.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.11-Rev 2 Callaway Plant Aging Management Program Evaluation Report, Closed Treated Water Systems - B2.21.11 Revision 2

2. CDP-ZZ-00110 Chemistry Data Trending Program Revision 004

3. CDP-ZZ-00200 Chemistry Schedule and Water Specs Revision 092

4. CDP-ZZ-00940 Auxiliary Water Systems Chemistry Optimization Plan Revision 006

5. EDP-ZZ-xxxxx Non-Chemistry Inspection of Closed Treated Water Systems Revision 0

6. ETP-EG-00003 Proto-Power Corporation Procedure: Thermal Performance Test of the A CCW Heat Exchanger Revision 0, 10/08/2008

7. ETP-EG-00004 Proto-Power Corporation Procedure: Thermal Performance Test of the B CCW Heat Exchanger Revision 0, 10/08/2008

8. CAR 200900231 Wall Thinning on EDG Heat Exchangers 01/13/2009

9. CAR 200805013 B Diesel Generate Has Pitting on Jacket Water System 06/10/2008 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 verified that the scope of program program element of the LRA AMP is consistent with the corresponding element of the GALL Report AMP. The staff also verified that the preventive actions program element of the LRA AMP is consistent with the GALL Report AMP, including the use of water chemistry controls, such as the monitoring of bacteria counts and adding biocides as necessary to inhibit microbiologically-influenced corrosion (as stated in procedure CDP-ZZ-00200). In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The enhancement associated with the parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP states that a representative sample of each combination of material and water treatment program will be visually inspected at least every 10 years. The GALL Report AMP recommends that a representative sample of piping and components be selected based on likelihood of corrosion or cracking and inspected at least every 10 years. In its review of the applicants onsite documentation, the staff noted inconsistencies between the LRA enhancement, program basis document, and the implementing procedure regarding the inspection sampling methodology. Because of these inconsistencies, and the fact that inspections may not be focused on locations with the greatest likelihood of corrosion or cracking, it is not clear to the staff whether the inspection sampling methodology is adequate to ensure that degradation can be detected before loss of intended functions.

The program description of the LRA AMP states that the program uses the water treatment of molybdate control with tolyltriazole in the closed treated water systems.

During its review of the applicants onsite documentation, the staff noted that the boron thermal regeneration system (BTRS) chilled water, a closed treated water system, is treated with a nitrite/molybdate chemistry. The staff also noted that the improper identification of the water chemistry of the BTRS chilled water system may lead to inadequate inspection sampling of unique combinations of materials and water treatment programs. Thus, it is not clear to the staff whether the inspection sampling of this system will be adequate to ensure that degradation can be detected before loss of intended functions.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program and preventive actions are consistent with the corresponding program elements in GALL Report AMP XI.M21A. The staff also identified certain aspects of LRA program elements parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.12, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. The LRA states that AMP B2.1.12, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted a walkdown of the crane for the B Emergency Diesel Generator Room. The staff also conducted an independent search of the applicants operating experience database using keywords: crane, hoist, scc, rail, overhead, and wear.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.12 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Revision 2, 10/18/2010

2. APA-ZZ-00365 Callaway Plant Lifting and Rigging Program Revision 21

3. APA-ZZ-00365 Addendum L, Callaway Plant Lifting Operations Revision 9

4. APA-ZZ-00322 Integrated Work Management Process Description Revision 12

5. MPM-KE-QH008 Polar Crane Inspection Revision 29

6. APA-ZZ-00500 Corrective Action Program Revision 54

7. CAR 200908152 Loose Bolts Found on Turbine Crane Safety Bar 09/18/2009 Document Title Revision/Date

8. CAR 200900603 Circ & Service Water Pump House Overhead Crane 01/27/2009 The staff conducted its audit of LRA program elements 1-6, based on the contents of the existing program as modified by the proposed enhancements. During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience the applicant provided and the staff identified in an independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience the applicant provided and the staff identified in an 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 the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M23.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.13, Fire Protection Summary of Information in the Application. The LRA states that AMP B2.1.13, Fire Protection, is an existing program with enhancements 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. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the halon system, fire barrier walls, and fire barrier penetrations for the ESF switchgear room. The staff also conducted an independent search of the applicants operating experience database using the plant designation for the fire protection system, KC, and the keywords corrosive, damage, and fire.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.13 Callaway Plant Aging Management Program Evaluation Report Fire Protection - B2.1.13 Revision 4

2. CAR 200400717 Seismic Gap Isolation Seal Inadequate

3. CAR 200408368 Fire Door DSK15031 Will Not Fully Self Close and Latch

4. CAR 200508469 Degraded Structural Steel Fireproofing in Room 3404

5. CAR 200608108 NRC Inspection Item: Aux Bldg. Fire Door Integrity

6. CAR 200901428 Fire/Radiation Barrier Seal Found Degraded

7. APA-ZZ-00703 Fire Protection Operability Criteria and Surveillance Requirements Revision 20

8. MSM-ZZ-FG002 Fire Damper Inspection and Drop Test Revision 12

9. MSM-KC-FQ001 Function Test - Halon Systems Protecting Safety Related Areas Revision 27

10. MSM-KC-FT001 Halon Fire Protection Cylinder Inspection Revision 27

11. OSP-KC-00015 Fire Door Inspections Revision 13

12. QSP-ZZ-65045 Fire Barrier Seal Visual Inspections Revision 8

13. QSP-ZZ-65046 Fire Barrier Inspection Revision 13 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 verified that the preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the scope of program and detection of aging effects program elements, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The scope of program program element of GALL Report AMP XI.M26 includes aging management of penetration seals, walls, ceilings, floors, doors, and other fire resistance materials with a fire barrier function. The LRA denotes items with an intended function of fire barrier using an FB. However, there are AMR items in the LRA that have an intended function of fire barrier but are not being managed for aging using the Fire Protection program. It is not clear to the staff how these statements are consistent because some components with a fire barrier function are not being managed for aging using the Fire Protection program.

The detection of aging effects program element of GALL Report AMP XI.M26 states that visual inspections of fire barrier penetration seals, walls, ceilings, floors, doors, and other fire barrier materials are performed by fire protection qualified personnel. During the audit, the staff noted that procedures QSP-ZZ-65045, Fire Barrier Seal Visual Inspection, and QSP-ZZ-65046, Fire Barrier Inspection, state that the personnel performing the inspections are Quality Control Inspectors. The staff also noted that procedure OSP-KC-00015, Fire Door Inspections, does not state what qualifications are required for personnel who perform the inspections. It is not clear to the staff whether these statements are consistent because the personnel who perform inspections as part of the Fire Protection program are not fire protection qualified.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M26.

The staff also identified certain aspects of LRA program elements scope of program and detection of aging effects that will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.14, Fire Water System Summary of Information in the Application. The LRA states that AMP B2.1.14, Fire Water System, is an existing program with enhancements and exceptions 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. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the fire water storage tanks, electric and diesel fire water pumps, and jockey pump. The staff also conducted an independent search of the applicants operating experience database using the plant designation for the fire protection system, KC, and the keywords corrosive, damage, and fire.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. APA-ZZ-00703 Fire Protection Operability Criteria and Surveillance Requirements Revision 20

2. CTP-KC-06001 Fire Protection System Chemical Addition Revision 6

3. MPM-KC-FW004 18 Month Fire Hose Station Inspection Outside Areas Revision 9

4. MSM-KC-FW007 Yard Loop Flush Revision 18

5. MSM-KC-FW004 Fire Hose Hydrostatic Testing Revision 19

6. MSM-KC-FW008 Fire Hose Hydrostatic Testing in Potentially Contaminated Areas Revision 11

7. MSM-KC-FW003 Fire Hose Station Inspection Inside RCA Revision 19

8. MSM-KC-FW009 Fire Hose Station Inspection Outside RCA Revision 7

9. OSP-KC-03003 Fire Main Flow Test Revision 5

10. OSP-KC-00008 Sprinkler System Discharge Head Inspection Revision 10

11. APA-ZZ-01025 Raw Water Chemistry Strategic Optimization Plan Revision 7

12. CAR 200408232 Preliminary Test Data Indicates Fire Loop C Factor Lower than Allowed

13. CAR 200502420 During Performance of OSP-KC-00009, 10 Nozzles Failed to Meet Acceptance Criteria

14. CAR 200510105 Jockey Pump Excessive Run Time

15. CAR 200608082 Fire Protection Piping AFI

16. CAR 200711546 Underground Fire Protection Leak Downstream of VKC1052

17. CAR 200801913 Fire Water Leak at Stores 2

18. CAR 200808087 Engineering Fundamentals AFI

19. CAR 200809173 Fire Water MIC Samples High from Stagnant Conditions

20. CAR 200909578 Fire Loop Flow Test Did Not Meet Acceptance Criteria

21. CAR 201102974 Fire Loop Flow Test Did Not Meet Acceptance Criteria

22. CAR 201106793 Fire Protection System Hose Testing Job Delays 08/25/2011

23. CAR 201110777 Fire Hose Leak During Training 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 the detection of aging effects program element of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the program description and detection of aging effects program element, sufficient information was not available to determine if the LRA AMP is consistent with the corresponding GALL Report AMP. To obtain the information necessary to verify if the LRA AMP is consistent with the corresponding GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The program description of GALL Report AMP XI.M27 recommends that sprinklers that have been in place for 50 years be replaced or a representative sample of sprinklers be field service tested at a recognized testing laboratory in accordance with National Fire Protection Association (NFPA) 25, Inspection Testing and Maintenance of Water-Based Fire Protection Systems. The LRA states that sprinklers will be replaced prior to 50 years inservice or a representative sample of sprinklers will be tested, with testing repeated every 10 years. The Fire Water System program does not discuss what type of testing will be performed or that testing will be performed in accordance with NFPA 25. It is unclear to the staff whether these statements are consistent because the LRA does not state that testing will be performed in accordance with NFPA 25.

The program description of GALL Report AMP XI.M27 recommends that sprinklers be tested in accordance with applicable NFPA codes and standards. NFPA 25 states that any sprinklers that show signs of physical damage, corrosion, or loading shall be replaced. In the first operating experience example of the operating experience program element, the LRA states that in 2005, 10 sprinkler heads were found with corrosion or damage. The LRA also states that two sprinkler heads were replaced and the rest were cleaned. Review of CAR 200502420 during the audit identified that there were four sprinklers with damage, three with corrosion, and three with lint, but only two were documented as being replaced. It is unclear to the staff why only two of the sprinklers with identified damage, corrosion, or loading were replaced. This does not appear to be consistent with the guidance in NFPA 25, and therefore does not appear to be consistent with the recommendations in the GALL Report.

The detection of aging effects program element of GALL Report AMP XI.M27 recommends that fire hydrants be flow tested annually in accordance with NFPA 25.

The LRA states an exception to GALL Report AMP XI.M27 to perform fire hydrant flow tests every 3 years. The staff reviewed the results of the last three performances of the fire hydrants flow tests. The staff noted that testing performed in 2011 indicated that approximately 25 percent of the hydrants tested failed to drain in the required timeframe.

The testing performed in 2007 indicated that approximately 20 percent of the hydrants tested failed to drain properly, and testing performed in 2005 indicated that approximately 50 percent of the hydrants tested failed to drain as required. It is not clear to the staff how the existing frequency of 3 years is acceptable to identify degradation before loss of intended function given that the recent performances of the hydrant flush has resulted in 20-50 percent of the hydrants failing.

The detection of aging effects program element of GALL Report AMP XI.M27 recommends that fire hoses be hydrostatically tested annually in accordance with NFPA codes and standards. The LRA states an exception to GALL Report AMP XI.M27 to perform hydrostatic hose testing for hose stations that are more than 5 years old on a 3-year frequency. During the audit, the staff noted that hydrostatic testing has not been performed since 2007. The staff also noted that CAR 201110777 documents failure of a fire hose when it was charged during fire brigade training in 2011. It is not clear to the staff how these statements are consistent because fire hose hydrostatic testing is not being performed in accordance with the frequency outlined in the existing Fire Protection program or the frequency recommended in GALL Report AMP XI.M26.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject discussed below.

GALL Report AMP XI.M27 manages aging for components exposed to fire water to ensure degradation is detected before loss of intended function. GALL Report AMP XI.M27 includes system flow testing and pipe wall thickness evaluations using non-intrusive techniques or visual inspections to manage aging. The LRA states that flow testing is performed every 3 years and pipe wall thickness examinations or internal inspections will be performed prior to the period of extended operation and every 10 years. The LRA includes an operating experience example, which states that there was a leak in the fire water system in 2005 identified by excessive jockey pump run times. CAR 200510105 clarifies that the leak was on buried piping on an isolable branch. The LRA includes another operating experience example, which states that a low cleanliness factor was identified during system flow testing in 2006. Chemical cleaning was performed on the fire water system to improve the cleanliness factor.

However, after chemical cleaning, five leaks developed and were subsequently repaired.

During the audit, the staff noted that microbiologically induced corrosion (MIC) contributed to the low cleanliness factor and leakage. Furthermore, subsequent to the chemical cleaning, additional leaks have occurred. The staff also noted that system flow testing performed in 2011 identified a low cleanliness factor again and compensatory measures were required to maintain system intended function. Given that the fire water system degraded from a clean system in 2006 to a degraded system in 2011, in which compensatory measures were required to maintain system intended function, it is not clear to the staff how aging of the fire water system will be adequately managed during the period of extended operation such that loss of intended function of the fire water piping does not occur.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M27. The staffs evaluation of aspects of the program element associated with exceptions will be addressed in the SER. The staff also identified certain aspects of the program description and LRA program element detection of aging effects that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information about operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.15, Aboveground Metallic Tanks Summary of Information in the Application. The LRA states that AMP B2.1.15, Aboveground Metallic Tanks, is a new program with exception that will be consistent with the program elements in GALL Report AMP XI.M29, Aboveground Metallic Tanks. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the condensate storage tank (CST), refueling water storage tank (RWST), and fire water storage tanks (FWST). The staff also conducted an independent search of the applicants operating experience database using keywords: coating, chloride, corrosive, cracking, damage, degradation, flaw, holiday, indication, inspection, insulation, loss of material, microbiological, pitting, sulfate, and throughwall.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.15 Callaway Plant Aging Management Program Evaluation Report, Aboveground Metallic Tanks - B2.1.15 NUREG-1801 Program XI.M29 Revision 2, 04/11/2012

2. Not applicable Callaway Plant Operating Experience Summary Report XI.M29, Aboveground Metallic Tanks 03/09/2012

3. EDP-ZZ-xxxxx Inspections of Aboveground Metallic Tanks Draft

4. CAR 200000412 Lagging Damage on Top of RWST None Available

5. CAR 201004307 Small Bubbles in Internal Coating of A Diesel Fuel Oil Storage Tank (EDFOST)

None Available

6. WO 06519798 Work Order - FWST Internal Inspection 09/06/2007

7. WO 08501230 Work Order - FWST Internal Inspection 09/01/2009

8. WO 0951003 Work Order - FWST Internal Inspection 06/27/2011

9. MTT-ZZ-I0011 Installation of Insulation Revision 8

10. M-160 Specification for Thermal Insulation for Piping and Equipment Located Inside the Reactor Containment and Outside Containment Requiring ISI Examination for the Standardized Nuclear Unit Power Plant System (SNIPPS)

Revision 19

11. M162 B Specification for Nonmetallic Thermal Insulation for Piping and Equipment Located in the Turbine Building, Auxiliary Boiler Building, and Communications Corridor Building for Union Electric Company Revision 13 Document Title Revision/Date

12. M162 A Specification for Nonmetallic Thermal Insulation for Piping and Equipment Located in the Auxiliary Building, Control Building, Diesel Generator Building, Fuel Building, and Reactor Waste Building for Union Electric Company Revision 16 The staff conducted its audit of LRA program elements 1-6, based on the contents of the new program. Aspects of the detection of aging effects program element of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the scope of program, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the preventive actions and detection of aging effects program elements, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The preventive actions program element of the LRA AMP states that there are no sealants or caulking applied at the external interface between the bottoms of the CST and RWST and their concrete foundations. The GALL Report AMP recommends that sealant or caulking be applied at the external surface of the interface joint to minimize the amount of water penetrating the interface, which could lead to corrosion of the tank bottom. These statements are not consistent, and the applicant did not identify this as an exception or provide a justification for not meeting the recommendation. Given that this preventive measure is not met, it is not clear to the staff why the number of tank bottom volumetric inspections to be conducted (i.e., one within 5 years of the period of extended operation and whenever the tank is drained) is adequate.

The preventive actions program element of the LRA AMP states:

The stainless steel CST does not have a protective coating; the insulation materials have a documented evaluation demonstrating that there are not any harmful substances which could leach onto the tank surface; and the insulation has a protective aluminum jacket with overlapping seams. In contrast to this statement, LRA Table 3.4.2-6, Insulation, plant-specific note 3, in pertinent part, states, [t]he dome of the stainless steel tank is prepped with a low halogen (<200 ppm) primer prior to the application of the foam urethane.

The stainless steel RWST does not have a protective coating and the insulation has a protective aluminum jacket with overlapping seams.

The steel FWSTs have an external coating of Carboline tie coat and polyurethane.

The staff has the following concerns and questions:

The staff lacks sufficient information related to the potential for chemical compounds in the cooling tower water or soil (which could become airborne), if present, to migrate to the tanks external surface and cause cracking, pitting, or crevice corrosion of the stainless steel surface.

The applicant has not provided information related to whether the insulation on the RWST contains harmful substances that could leach onto the tank surface and cause corrosion.

The staff questions if coatings are applied on the entire or portions of the CST and RWST external surfaces. In addition, if the coatings are credited for purposes of license renewal, was holiday testing conducted during initial application of the coating, and will the coatings be inspected during the period of extended operation?

During the staffs walk down of the structure that partially encloses the CST, water stains were observed on the side of the tank where insulation is not installed. It is not clear that insulation jacketing will prevent water intrusion into the tank insulation and then onto the tank surface.

The detection of aging effects program element of the LRA AMP states that visual inspections of the exterior surfaces of the CST and RWST are conducted when the surface is accessible. It also states that for inaccessible exterior tank surfaces, the program will sample wall thickness to ensure that the tank bottom and tank wall sections with insulated outer surfaces are not losing material or cracking. It further states that thickness measurements will be conducted once within 5 years of entering the period of extended operation and whenever the tank is drained, and at least one measurement per square yard of tank surface will be performed. The GALL Report AMP recommends that external surfaces of the tank be inspected on a RFO interval. The staff questions whether obtaining one thickness data point per square yard of tank surface is sufficient to detect pitting, crevice corrosion, and cracking. The staff also questions what percent of opportunistically removed insulation would be deemed sufficient to not conduct the internal volumetric exams.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

Multiple inspections of the internal surfaces of the FWST(s), spanning 2007 through 2011 have revealed blistering and delamination of coatings. Work orders documented that these defects were not all repaired before returning the tanks to service. The work orders document that the acceptance of the as-found defects that were not repaired was based on the fact that internal cathodic protection of the tank would prevent corrosion of exposed metal surfaces. However, neither the LRA AMP nor FSAR supplement state that the cathodic protection system is credited as a preventive measure to account for the plant-specific operating experience. In addition, the staff lacks sufficient information to conclude that the delaminating coatings would not block downstream components either based on current levels of delamination or those that could occur in 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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing an RAI described above associated with the operating experience program element.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, parameters monitored or inspected, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M29.

The staff also identified certain aspects of LRA program elements preventive actions, and detection of aging effects, that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information about operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.16, Fuel Oil Chemistry Summary of Information in the Application. The LRA states that AMP B2.1.16, Fuel Oil Chemistry, is an existing program with enhancements 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. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the emergency fuel oil system storage tanks and the emergency fuel oil system day tanks. The staff also conducted an independent search of the applicants operating experience database using keywords: fuel oil, corrosion, tank, biofoul, MIC, and emergency diesel fuel.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CSP-ZZ-07350 Diesel Fuel Oil Testing Program Revision 023

2. CTP-JE-01230 Diesel Fuel Oil Sampling Revision 043

3. CTP-ZZ-02135 Specific Gravity Determination Revision 014

4. CTP-ZZ-02145 Flash Point Determination Revision 010

5. CTP-ZZ-02233 Biodiesel Determination Revision 000

6. CTP-ZZ-02360 Water and Sediment Determination Revision 008

7. CTP-ZZ-02350 Viscosity Determination Revision 009

8. CTP-JE-01235 Diesel Fuel Oil Skid Sampling and Chemical Addition Revision 005

9. EDP-ZZ-01131 Appendix G System and Component Health Reports Revision 005

10. MSM-KJ-QT001 10 Year Emergency Diesel Generator Fuel Oil Storage Tank Cleaning Revision 011

11. OTS-JE-00002 Filtration of Emergency D/G Fuel Oil Revision 009

12. 201103756 Callaway Action Request 05/05/2011

13. 200000677 Callaway Action Request 03/29/2000

14. 201004307 Callaway Action Request 05/06/2010

15. 200900683 Callaway Action Request 01/28/2009

16. 199901705 Callaway Action Request 08/22/1999 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 verified that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the preventive actions program element sufficient information was not available to determine if it was consistent with the corresponding program element of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

The preventive actions program element of the LRA AMP does not state that the diesel fire pump fuel oil day tank and the security diesel generator fuel oil day tank will be periodically cleaned during the period of extended operation. The GALL Report AMP recommends periodic cleaning of a tank that contains diesel fuel oil to allow the removal of sediments.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

The applicant provided operational experience that observed blisters in the coating of an emergency fuel oil system storage tank. The staff will request that the applicant provide an evaluation estimating the corrosion rate of the fuel oil system storage tank should one of the blisters open up, exposing the fuel oil in the tank to the bare metal material of the tank. Additionally, the staff will request the applicant to provide an evaluation of the adequacy of the 10-year inspection interval based on the evaluation of the corrosion rate of the metal of the tank.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M30. The staff also identified certain aspects of LRA program element preventive actions that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information about operating experience is required before a determination can be made about the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.17, Reactor Vessel Surveillance Summary of Information in the Application. The LRA states that AMP B2.1.17, Reactor Vessel Surveillance, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP X1.M31, Reactor Vessel Surveillance. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this audit report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: reactor vessel, embrittlement, crack, and fluence.

The table below lists the documents that the staff reviewed and found to be relevant to the audit. The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.17 Reactor Vessel Surveillance - B2.1.17, NUREG-1801 Program XI.M31 Revision 3, 6/5/2012

2.

Callaway Plant Operating Experience Summary Report, XI.M31, Reactor Vessel Surveillance 3/9/2012

3.

Callaway Plant License Renewal Aging Management Industry Operating Experience Report for AMP XI.M31, Reactor Vessel Surveillance B2.1.17 3/9/2012

4. WCAP-15400 Analysis of Capsule X from Ameren-UE Callaway Unit 1 Reactor Vessel Radiation Surveillance Program Revision 0, June 2000

5. WCAP-17168-NP Callaway Unit 1 Time-Limited Aging Analysis on Reactor Vessel Integrity Revision 0, September 2010 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 verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the detection of aging effects, program element, sufficient information was not available to determine if it was consistent with the corresponding program element of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.

The detection of aging effects program element of the LRA AMP states that the last-tested surveillance capsule removed from the reactor vessel was exposed to neutron fluence equivalent to about 54 effective full power years (EFPY) at the reactor vessel wall, which exceeds 60-year peak reactor vessel wall neutron fluence. The detection of aging effects program element of GALL Report AMP XI.M31 recommends that a plant-specific reactor vessel surveillance program have at least one capsule with a projected neutron fluence equal to or exceeding the 60-year peak reactor vessel wall neutron fluence before the end of the period of extended operation. To verify that this element of the LRA AMP is consistent with the recommendation in the GALL Report AMP, the staff requires the neutron fluence to which the last-tested surveillance capsule was exposed, which was not provided in the LRA AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M31. The staff also identified certain aspects of LRA program element detection of aging effects that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.18, One-Time Inspection Summary of Information in the Application. The LRA states that AMP B2.1.18, One-Time Inspection, is a new program 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.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using the keywords: loss of material and cracking.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.18 One-Time Inspections Revision 2

2. OTI-TBD One-Time Inspection Program Draft During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). Based on a review of the applicants analysis and the staffs independent review of plant-specific operating experience related to the existing Water Chemistry, Fuel Oil Chemistry, and Lubricating Oil Analysis programs, loss of material, cracking, and reduction of heat transfer are not occurring or are progressing so slowly as to have a negligible effect on the intended function. Therefore, the One-Time Inspection program satisfies the AMP XI.M32 recommendation that it can only be used for structures or components with no known age-related degradation mechanisms.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M32.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, when implemented by the applicant, will be used to confirm the absence of aging effects that will be managed by the program before the period of extended operation. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.19, Selective Leaching Summary of Information in the Application. The LRA states that AMP B2.1.19, Selective Leaching, is a new program, with exceptions, that will be consistent with the program elements in GALL Report AMP XI.M33, Selective Leaching. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using the keywords: cast, leach, and dealloy.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1.

Callaway Plant Unit 1 License Renewal Application 12/2011

2. CW-AMP-B2.1.19 Selective Leaching - Callaway Plant Revision 3

3.

One-Time Inspection for Selective Leaching Draft

4. APA-ZZ-00500 Corrective Action Program

5. APA-ZZ-00703, Fire Protection Operability Criteria and Surveillance Requirements

6. CAR No. 200909091

7. CAR No. 201009835 The staff conducted its audit of LRA program elements 1-6, based on the contents of the new program. Aspects of the parameters monitored or inspected and monitoring and trending program elements of the LRA AMP that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the scope of program, preventive actions, detection of aging effects, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the parameters monitored or inspected, and monitoring and trending program elements not associated with the exception are consistent with the corresponding program elements in the GALL Report AMP. The staffs evaluation of aspects of these program elements associated with the exception will be addressed in the SER. Although associated with the exception to LRA program elements parameters monitored or inspected, and monitoring and trending, the staff will consider issuing RAIs for the subject discussed below.

The applicant took an exception to GALL Report AMP XI.M33 for buried gray cast iron components, stating that these components do not need to be inspected for selective leaching if the components are within the scope of the fire protection system, have been installed in accordance with NFPA 24, and the activity of the jockey pump is monitored on an interval not to exceed 1 month. The applicant stated that the exception is consistent with the fire protection aging management requirements of GALL Report AMP XI.M41, Buried and Underground Piping and Tanks. However, GALL Report AMP XI.M41 states that the program does not address selective leaching, and that GALL Report AMP XI.M33 is applied in addition to this (AMP XI.M41) program.

During the audit of the operating experience program element, the staff noted that in the LRA, the applicant stated that the Callaway Corrective Action Program was reviewed to determine if selective leaching has been identified for components with the applicable material and environment combinations, and that the review identified no occurrences of selective leaching at Callaway. However, in the AMP basis document, the applicant did identify two Callaway Action Requests (CARs) in which selective leaching was identified. The staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, detection of aging effects, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M33. The staff also verified that for the parameters monitored or inspected, and monitoring and trending, program elements, the aspects of the LRA AMP program elements not associated with the exceptions are consistent with the corresponding program elements in GALL Report AMP XI.M33. The staffs evaluation of aspects of the program elements associated with exceptions will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.20, One-Time Inspection of ASME Code Class 1 Small-Bore Piping Summary of Information in the Application. The LRA states that AMP B2.1.20, One-Time Inspection of ASME Code Class 1 Small-Bore Piping, 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. To verify this claim of consistency, the staff audited the LRA AMP.

Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff conducted an independent database search of the applicants operating experience database using the keywords: cracking, corrosion, cyclic, degradation, damage, socket, fatigue, rupture, thermal, through-wall, weld, and leak.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AP-B2.1.20 One-Time Inspection of ASME Code Class 1 Small-Bore Piping B2.1.20 Revision 2, 10/06/2011

2. E170.0105 Callaway NPP Third Interval Inservice Inspection Plan Revision 5

3. CAR 199501891 RCS Leak Detected in Line BB-74-BCA-2 10/04/1995

4. RDD985554201000 Babcock & Wilcox Research & Development Division Examination of Failed Cross Over Drain Line from Callaway Unit 1 04/1997

5.

Callaway Plant License Renewal Component List Class 1 Small-Bore Piping During the audit of program elements 1-6, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the scope of program program element, insufficient information was available to determine if it was consistent with the corresponding program element of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

LRA Section B2.1.20 states that the applicants unit has 19 Class 1 small-bore socket welds in the population of ASME Code Class 1 piping less than nominal pipe size (NPS) 4 and greater than or equal to NPS 1. During the audit, the applicant stated that a recent recount by the applicant, subsequent to the submission of the LRA, had indicated that there are in fact 23 Class 1 small-bore socket welds. Therefore, the applicant will need to amend LRA Sections A1.20 and B2.1.20 to reflect the correct number of in-scope socket welds for the applicants AMP. The staff further noted that its recent reviews of other similar PWR facilities have shown the number of reported in-scope socket welds to be roughly twice the number counted by the applicant, suggesting the need for a possible verification.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

However, as noted above, the FSAR supplement will need to be amended to reflect the correct population of in-scope socket welds.

Audit Results. Based on this audit, the staff verified that LRA program elements preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M35. The staff also identified certain aspects of LRA program element scope of program that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.21, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The LRA states that AMP B2.1.21, External Surfaces Monitoring of Mechanical Components, is a new program that is consistent with the program elements in GALL Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using the keywords: loss of material, cracking, and hardening and loss of strength.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.21 External Surfaces Monitoring of Mechanical Components Document Title Revision 2

2. EDP-ZZ-xxxxx External Surfaces Monitoring of Mechanical Components Program Document Title Revision 000

3. EDP-ZZ-01131 Plant Health and Performance Monitoring Program Revision 021

4. EDP-ZZ-01131 Plant Health and Performance Monitoring Program, Appendix K, Engineering System Walkdowns Revision 001 During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M36.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.2.1.22, Flux Thimble Tube Inspection Summary of Information in the Application. The LRA states that AMP B2.1.22, Flux Thimble Tube Inspection, is an existing program that is consistent with the program elements in GALL Report AMP XI.M37, Flux Thimble Tube Inspection. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: thimble tube, thimble tube wear, wear rate, and capped tube.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. EDP-ZZ-01003 Inservice Inspection Program Revision 25

2. NRC Bulletin No.

88-09 Thimble Tube Thinning in Westinghouse Reactors 09/30/1988

3. ULNRC-2049 Report on the Results of Incore Thimble Tube Testing 07/28/1989

4. ETP-BB-01200 Incore Flux Thimble Tube Inspection Program Revision 0

5. CW-CL-XI-M37 Flux Thimble Tube Inspection Revision 0 During the audit of program elements 1-6, the staff found that program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, 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., the applicant or the staff did not identify any previously unknown aging effects). The staff also found that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is adequate to detect and manage the effects of aging during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M37.

Based on this audit the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR LRA AMP B2.1.23, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The LRA states that AMP B2.1.23, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is a new program with an exception that is consistent with the program elements in GALL Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: loss of material and cracking.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.23 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Revision 2

2. EDP-ZZ-01131 Plant Health and Performance Monitoring Program Revision 021

3. APA-ZZ-00500 Corrective Action Program Revision 054

4. EDP-ZZ-01128 Maintenance Rule Program Revision 018

5. EDP-ZZ-xxxxx Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Revision 000 The staff conducted its audit of LRA program elements 1-6, based on the contents of the new program. Aspects of the scope of program, parameters monitored or inspected, detection of aging effects, and monitoring and trending, program elements of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of these program elements that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the preventive actions and acceptance criteria program elements of the LRA AMP are consistent with the corresponding element of the GALL Report AMP. The staff also verified that aspects of the parameters monitored or inspected, detection of aging effects, and monitoring and trending, program elements not associated with the exception are consistent with the corresponding program elements in the GALL Report AMP. The staffs evaluation of aspects of these program elements associated with the exception will be addressed in the SER. In addition, the staff found that for the scope of program program element, sufficient information was not available to determine if it was consistent with the corresponding program element of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.

The scope of program program element of the LRA AMP does not state a summary description of the components included in the program. The GALL Report AMP recommends that the program include internal surfaces of metallic piping, piping components, ducting, polymeric, and other components. It is not clear to the staff that these statements are consistent because the LRA AMP does not define the components that will be age managed within the program.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing RAIs for the subject discussed below.

The FSAR supplement does not include key elements of the recommended program description in SRP-LR Table 3.0-1, and omits that for inaccessible components a plant-specific program will be applied. The FSAR supplement also states that the program will use a representative sample as part of the program but does not describe the sample size, the percentage or number of components involved in the sample, nor the method by which components would be selected for the sample.

Audit Results. Based on this audit, the staff verified that LRA program elements preventive actions and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M38. The staff also verified that for the parameters monitored or inspected, detection of aging effects, and monitoring and trending, program elements, the aspects of the LRA AMP program elements not associated with the exception are consistent with the corresponding program elements in GALL Report AMP XI.M38. The staffs evaluation of aspects of the program elements associated with exceptions will be addressed in the SER.

The staff also identified certain aspects of LRA program element scope of program that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.24, Lubricating Oil Analysis Summary of Information in the Application. The LRA states that AMP B2.1.24, Lubricating Oil Analysis, is an existing program with enhancements 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. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: contamination, lube oil, and particulate.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. APA-ZZ-00107 Review of Current Industry Operating Experience Revision 15

2. APA-ZZ-00330 Preventive Maintenance Program Revision 36

3. APA-ZZ-00500 Corrective Action Program Revision 53

4. EDP-ZZ-01110 Predictive Maintenance Program Revision 22

5. EDP-ZZ-01126 Appendix 1 Lubrication Oil Sample Components List Revision 3

6. EDP-ZZ-01126 Lubrication Predictive Maintenance Program Revision 11

7. MDP-ZZ-L0001 Lubrication Program Revision 17

8. OQAM Operating Quality Assurance Manual Revision 28B

9. APA-ZZ-00549 Equipment Reliability Improvement Program Revision 11

10. EDP-ZZ-01131 Plant Health and Performance Monitoring Program Revision 21 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 verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M39.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, will be sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.25, Buried and Underground Piping and Tanks Summary of Information in the Application. The LRA states that AMP B2.1.25, Buried and Underground Piping and Tanks, is a new program with exceptions that will be consistent with the program elements in GALL Report AMP XI.M41, Buried and Underground Piping and Tanks. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: buried, coating, cast, chloride, corrosive, dug, excavation, cracking, damage, degradation, flaw, holiday, indication, inspection, loss of material, microbiological, pitting, sulfate, and throughwall.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. NA Callaway Plant License Renewal Aging Management CAR Operating Experience Report for AMP XI.M41, Buried and Underground Piping and Tanks B2.1.25 03/09/2012

2. NA Callaway Plant License Renewal Component List for AMP XI.M41, Buried and Underground Piping and Tanks B2.1.25 03/09/2012

3. CW-AMP-B2.1.25 Callaway Plant Aging Management Program Evaluation Report Buried and Underground Piping and Tanks B2.1.25 NUREG-1801 Program XI.M41 Revision 3, 05/10/2012

4. EDP-ZZ-01011 Buried and Underground Piping and Tanks Inspection Program Revision 0

5. APA-ZZ-00703 Fire Protection Operability Criteria and Surveillance Results Revision 20

6.

Cathodic Protection Monitoring Draft

7. 83470351 CC Technologies Final Report - Indirect Inspections ESW Supply, Return, Discharge, and Strainer Backwash Pipelines 05/02/2007

8. 83475171 Close-Interval Survey (CIS) and Direct Current Voltage Gradient (DCVG) Survey Buried Fire Water Protection Piping 05/07/2008

9. 10513410-500 Annual Cathodic Protection System Survey 08/29/2011

10. 410049 2005 Cathodic Protection Survey and Assessment Report 05/05/2006

11. S-1080 Technical Specification for the Installation of Replacement ASME Section III Buried Essential Service Water System Piping Revision 1, 10/02/2008

12. E-1026-00012 Cathodic Protection Design Report - Harco Revision 0, 08/21/1992

13. MTT-ZZ-10011 Installation of Insulation Revision 5, 05/09/2002

14. CAR 200607749 External Coating Damage Fire Water System - VKC1027D Unavailable Document Title Revision/Date

15. CAR 200605969 External Corrosion Leak Fire Water System - Near Training Center Unavailable

16. CAR 200606030 External Corrosion Leak Fire Water System - VKC1087 Unavailable

17. CAR 200703899 Internal MIC Initiated Leak on An Essential Service Water (ESW) Train Unavailable

18. CAR 200711546 Leak in Fire Water System Downstream of VKC1052 Unavailable

19. CAR 20080871 External Leak on An ESW Train Unavailable

20. CAR 200207386 Rebar Found in Backfill in Vicinity of Buried Pipe Unavailable

21. CAR 200702384 Internal MIC Initiated Leak on B ESW Train Unavailable

22. CAR 200702484 External Corrosion Leak on B ESW Train Unavailable

23. CAR 200704465 MIC Initiated Leak Corrosion on ESW Trains in Numerous Locations Unavailable

24. CAR 200808781 Internal MIC Initiated Leak on An ESW Train Unavailable

25. CAR 200608647 Portions of Cathodic Protection System Not Meeting Acceptance Criteria for the Service Water, Fire Protection, and ESW Systems Unavailable

26. CAR 200707760 Rectifier Outputs for the EFOST, CST, and FWST are Maxed Out While Not Providing Adequate Protection Unavailable

27. CAR 200803345 Deepwell Anode DAWQH1007 Is Not Functional Unavailable

28. CAR 201010950 Several Cathodic Protection Components Are in Need of Repair Unavailable

29. CAR 201006741 Exterior Cathodic Protection for FWST A is Performing Below Standard Unavailable The staff conducted its audit of LRA program elements 1-6, based on the contents of the new program. Aspects of the preventive actions and detection of aging effects program elements 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 verified that the parameters monitored or inspected and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the scope of program, preventive actions detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The scope of program program element of the LRA AMP states that the emergency diesel engine fuel oil storage and transfer system consists of buried piping and tanks with a safety-related function and also contains hazardous materials. Based on a review of drawing LR-CW-JE-M-22-JE01, the emergency diesel engine fuel oil storage and transfer system also appears to include underground in-scope piping. However, LRA Table 3.3.2-4, Auxiliary Systems - Summary of Aging Management Evaluation -

Essential Service Water System, does not include any AMR items associated with underground piping.

The preventive actions program element of the LRA AMP states that coatings for buried stainless steel piping are only required to protect from a chloride environment to prevent SCC. In addition, it states that the design temperature of the ultimate heat system is 95 °F and the maximum temperature of the RWST is 120 °F, and that this is below the threshold temperature for SCC as stated in GALL Report Section IX.D. The staff recognizes that GALL Report Section IX.D establishes a 140 °F threshold for SCC in stainless steel components; however, it also states, [w]ith a harsh enough environment (i.e., significant contamination), SCC can occur in austenitic stainless steel at ambient temperature. However, these conditions are considered event-driven, resulting from a breakdown of chemistry controls. In contrast to the treated water environments, the soil environment is not controlled to preclude the potential for significant levels of contaminants. Given that contaminants can accumulate in the soil due to normal environmental interactions, the 140°F threshold may not apply to buried piping. In addition, the GALL Report, item AP-137 recommends that stainless steel components exposed to soil are susceptible to loss of material due to pitting and crevice corrosion. GALL Report AMP XI.M41, Table 2a, Preventive Actions for Buried Piping and Tanks, footnote 3 states, [c]oatings are provided based on environmental conditions (e.g., stainless steel in chloride containing environments). If coatings are not provided, a justification is provided in the LRA. During the AMP audit, the applicant did not provide any documentation demonstrating that the soil in the vicinity of the buried stainless steel piping had sufficiently low levels of chlorides and therefore the justification provided by the applicant is insufficient.

The preventive actions program element of the LRA AMP states that the preventive actions of the program will be consistent with the GALL Report; however, during its audit the staff identified five CARs spanning 2006 through 2010 citing gaps in cathodic protection system performance. In addition, a Close-Interval Survey (CIS) and Direct Current Voltage Gradient (DCVG) Survey - Buried Fire Water Protection Piping, dated May 2008, stated that 23 percent of the fire protection system, representing 2,658 feet of piping, was inadequately protected. GALL Report AMP XI.M41, Buried and Underground Piping and Tanks, recommends that a cathodic protection be installed, monitored, annually tested, and potential differences and current measurements be trended to identify changes in the effectiveness of the system. Given that plant-specific operating experience demonstrates a long period of degraded performance of the cathodic protection system, further details on cathodic protection system availability and effectiveness should be included in the FSAR supplement summary description.

The detection of aging effects program element of the LRA AMP states that the fire water jockey pump performance will be monitored in lieu of conducting excavated direct visual examinations of in-scope buried fire water system piping. The GALL Report AMP recommends a similar provision. However, given the numerous leaks in the fire water system piping, it is not clear to the staff that there is adequate sensitivity for monitoring buried fire water piping with the fire water jockey pump.

In relation to the acceptance criteria program element, the CIS and DCVG Survey -

Buried Fire Water Protection Piping, dated May 7, 2008, recommends that for locations not meeting -850 mV criteria, the station should determine whether the alternative 100 mV potential shift criteria would demonstrate acceptable cathodic protection. In addition, it recommended that locations more negative than -1200 mV be addressed to ensure that coating disbondment is not occurring. When dissimilar metals are present in the environment (e.g., steel in relation to the copper grounding grid), the 100mV criterion is only acceptable if it can be demonstrated that the most noble metal will be adequately protected. If the applicant will use the 100 mV criterion on in-scope components during the period of extended operation, it must provide the basis for protecting the most noble metal. In addition, to verify consistency with GALL Report AMP XI.M41, the staff must understand the applicants approach to locations more negative than -1200 mV.

Although not associated with an AMP program element, the staff discussed the following with the applicant during the audit. The LRA cites SRP-LR items 3.3.1-112 and 3.3.1-120 for steel and stainless steel piping, piping components, and other component types embedded in concrete. SRP-LR item 3.3.1-112 addresses steel piping, piping components, and piping elements exposed to concrete for which there is no recommended AERM or AMP, provided 1) attributes of the concrete are consistent with

[American Concrete Institute] (ACI) 318 or ACI 349 (low water-to-cement ratio, low permeability, and adequate air entrainment) as cited in NUREG-1557, and 2) plant operating experience indicates no degradation of the concrete. SRP-LR item 3.3.1-120 addresses stainless steel piping, piping components, and piping elements exposed to concrete as well as other environments (e.g., air-indoor, uncontrolled, gas, dry air) for which there is no recommended AERM or AMP. The program description of GALL Report AMP XI.M41 states, [t]he terms buried and underground are fully defined in Chapter IX of the GALL Report. Briefly, buried piping and tanks are in direct contact with soil or concrete (e.g., a wall penetration). The scope of program program element of AMP XI.M41 states, [t]his program is used to manage the effects of aging for buried and underground piping and tanks constructed of any material including metallic, polymeric, cementitious, and concrete materials. There is an internal misalignment in the GALL Report in that the definition of buried piping and scope of AMP XI.M41 conflicts with items 3.3.1-112 and 3.3.1-120, which state that there is no AERM or recommended AMP for the concrete environment. Regardless of the misalignment, the staff lacks sufficient information to conclude that the in-scope steel and stainless steel piping and piping components embedded in concrete do not need to be age managed by AMP XI.M41.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject discussed below.

The operating experience program element of the LRA AMP states that from 2008 to 2009, portions of the ESW system were replaced with high-density polyethylene (HDPE) piping due to material conditions of the system, including pinhole leaks, pitting, and other localized degradation of the pressure boundary. LRA Table 3.3.2-4 states that there are steel piping, strainer, and valve components in the ESW system exposed to raw water (internal) and a buried environment that have not been replaced. The staff noted that the Buried and Underground Piping and Tanks Inspection Program, Appendix A,, states that four inspections will be performed on steel ESW piping in each 10-year period starting 10 years before the period of extended operation. Given that these steel components are in the same environment as the replaced piping, it is possible that the degradation of the steel piping will occur at the same rate (on a unit length basis) as experienced by the entire system before replacement. Also, given inconsistent site-wide performance of the cathodic protection system, the staff lacks sufficient information to determine that four inspections each 10-year period will provide reasonable assurance that the CLB function(s) of the portions of the ESW that have not been replaced with HDPE piping will be met.

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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing the RAI described above associated with the second preventive actions program element potential RAI.

Audit Results. Based on this audit, the staff verified that LRA program elements parameters monitored or inspected and monitoring and trending are consistent with the corresponding program elements in GALL Report AMP XI.M41. The staff also identified certain aspects of LRA program elements scope of program, preventive actions detection of aging effects, and acceptance criteria that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information about operating experience is required before a determination can be made about the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.26, ASME Section XI, Subsection IWE Summary of Information in the Application. The LRA states that AMP B2.1.26, ASME Section XI, Subsection IWE, is an existing program with enhancements 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. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the auxiliary building, tendon gallery, turbine building, and the exterior of the containment structure.

The staff also conducted an independent search of the applicants operating experience database using keywords: IWE, containment, liner, corrosion, rust, and coating.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1.

License Renewal Application - Callaway Plant Unit 1 December 15, 2011

2. CW-AMP-B2.1.26 ASME Section XI, Subsection IWE Revision 3

3. ESP-ZZ-01016 ASME Section XI IWE Containment Pressure Boundary Inspection Revision 6

4. APA-ZZ-00500 Corrective Action Program Revision 53

5. APA-ZZ-00662 ASME Section XI Repair/Replacement Program Revision 20

6. QCP-ZZ-05040 Visual Examination to ASME VT-1 Revision 22

7. QCP-ZZ-05-42 Visual Examination to ASME VT-3 Revision 19

8. OQAM Operating Quality Assurance Program Revision 28A

9. Inspection File:

Z170.0001 ASME Section XI IWE Containment Pressure Boundary Inspection October 1999 Refuel 10

10. Inspection File:

Z170.0001 ASME Section XI IWE Containment Pressure Boundary Inspection October 1999 Refuel 10, Revision 1

11. Inspection File:

Z170.0001 ASME Section XI IWE Containment Pressure Boundary Inspection 10/2002 Refuel 12

12. File E190.0101 Callaway NP Containment Pressure Boundary ISI ASME Section XI, Subsection IWE Revision 3

13. CAR 19992304 Indication Found during IWE VT-3 Exam Exceed Acceptance Criteria 10/05/1999

14. CAR 201108817 During QCs Performance of ASME Section XI, IWE Containment Pressure Boundary Inspection on JOB 08512602/500 Containment Zones 9, 14, 17, 18, 19, 21 As Identified on C-2L2959 and C-2L2960 Did Not Meet the General Visual Inspection Criteria of Procedure ESP-ZZ-01016 10/24/2011

15. CAR 200507146 Pitting on I-Beam from.005 to.025 on Spots on Line Wall 09/21/2005

16. CAR 200811011

17. CAR 200811479 B Normal Sumps Has Leak in Lower Back Right Corner At The Weld Area 11/03/2008

18. CAR 201104417 Containment Coatings Were Found in a Degraded Condition at the Seal Table (RBB06) During a Containment Inspection 05/26/2011

19.

NCR GL 91017

20.

NRC IN 2004-09

21.

NRC IN 2010-12

22.

NRC IN 1997-10

23.

NRC Regulatory Issue Summary (RIS) 2011-05

24. APA-ZZ-00107 Review of Current Industry Operation Experience Revision 15

25. C-2L2908 Callaway Plant - Reactor Building Liner Plate Floor and Wall Details Revision 0

26. C-2L2956 Callaway Plant - Pressure Boundary Drawings, Reactor Building Floor Plan, El. 1998'-6

Revision 1 Document Title Revision/Date

27. C-2L2957 Callaway Plant - Pressure Boundary Drawing, Reactor Building Dome Plan Revision 0

28. C-2L2958 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Floor Details Revision 0

29. C-2L2959 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Developed Elevations Revision 1

30. C-2L2960 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Developed Elevations Revision 0

31. C-2L2961 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Personnel Access Hatch Revision 0

32. C-2L2962 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Equipment Hatch Revision 0

33. C-2L2963 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Encapsulated Containment, Recirc. Sump Piping Plan % Typical Penetration Details Revision 0 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 verified that the scope of program, preventive actions, and detection of aging effects, program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the parameters monitored or inspected, monitoring and trending and acceptance criteria program elements, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The parameters monitored or inspected program element of the LRA AMP does not consider the moisture barriers as part of the IWE program. The GALL Report AMP recommends the examination of the moisture barriers for wear, damage, erosion, tear, surface cracks, or other defects that permit intrusion of moisture in the inaccessible areas of the pressure retaining surfaces of the metal containment shell or liner. It is not clear to the staff that these statements are consistent because the moisture barriers are not considered within the IWE program, and no examinations of them were identified in the surveillance reports.

The monitoring and trending and acceptance criteria program elements of the LRA AMP state that the site procedure, ESP-ZZ-01016, Revision 06, establishes the IWE ISI program for the containment metallic liner, penetrations of Class CC pressure-retaining components, their integral attachments and Class MC pressure rating components per the ASME Code, Section IWE, 2001 edition through the 2003 addenda. The procedure further states that to detect evidence of degradation, the applicable examination methods are general visual and detailed visual. The GALL Report AMP recommends the 2004 edition as approved in 10 CFR Part 50.55a of ASME Code,Section XI, Subsection IWE, and to detect evidence of degradation, the applicable examination methods are general visual, VT-3 visual, and VT-1 visual. It is not clear to the staff that these statements are consistent because the applicable visual examination methods in the GALL recommended Code Edition may not be appropriately addressed in the site procedure, ESP-ZZ -01016, Revision 06.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, and detection of aging effects are consistent with the corresponding program elements in GALL Report AMP XI.S1. The staffs evaluation of aspects of the program elements associated with enhancements that are not necessary for consistency will be addressed in the SER. The staff also identified certain aspects of LRA program elements parameters monitored or inspected, monitoring and trending, and acceptance criteria that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.27, ASME Section XI, Subsection IWL Summary of Information in the Application. The LRA states that AMP B2.1.27, ASME Section XI, Subsection IWL, is an existing program that is consistent with the program elements in GALL Report AMP XI.S2, ASME Section XI, Subsection IWL. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the auxiliary building, tendon gallery, turbine building, and the exterior of the containment structure.

The staff also conducted an independent search of the applicants operating experience database using the keywords: IWL, containment, concrete, tendon, sheath, and leak.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1.

License Renewal Application - Callaway Plant Unit 1 December 15, 2011

2. CW-AMP-B2.1.27 ASME Section XI, Subsection IWL Revision 1

3. ESP-ZZ-01012 Containment Post-Tensioning System Inspection Revision 7

4. C-1003 Specification for ISI of the Containment Building Post-Tensioning System and Exterior Concrete Shell Revision 12

5. APA-ZZ-00662 ASME Section XI Repair/Replacement Program Revision 19

6. APA-ZZ-00500 Corrective Action Program Revision 52

7. CECTIP Callaway NP Containment Exterior Concrete and Tendon Inspection Program Revision 3

8. CA-N1042-500 Precision Surveillance Corporation (PSC) Report Engineering File No 261 Twentieth Year Surveillance of the Post-Tensioning System at the Callaway NP Revision 0

9. CA-N1042-500 Final Report for the 25th Year Containment IWL Inspection 2010

10. FSAR-SP Section 16.6.1.2.1 Revision OL-18

11. Inspection E170.0105 Callaway NP Containment Exterior Concrete and Tendon Inspection Program Revision 2

12. Inspection E190.0100 Callaway NP Containment Exterior Concrete and Tendon Inspection Program Revision 3

13. APA-ZZ-00107 Review of Current Industry Operating Experience.

Revision 15

14. CAR 201004223 Containment Post-Tensioning System Tendon 33CB Wire Did Not Meet the Elongation Acceptance Criteria during the Lab Testing of the Removed Tendon Wire 05/04/2010

15. OQAM Operating Quality Assurance Manual Revision 28A

16. CAR 200407394 20th Year Tendon Surveillance Concrete Inspection Report 09/23/2004

17. CAR 201009755 Evaluate NRC IN 1999-10, Rev. 1, Degradation of Prestressing Tendon Systems 10/12/2010

18. CAR 201009713 No Documentation Could Be Found Indicating Callaway Evaluated NRC IN 99-10 10/11/2010

19. Generic Safety Issue 118 Tendon Anchor Head Failure - NRC IN 85-10 Revision 1

20. CAR 200902154 ASME Sec XI Subsection IWL Requirements Were Not Fully Met for 20th Year Tendon Surveillance. See X.S1, LRA Sec B3.3 03/16/2009

21. CAR 201009644 See X.S1, LRA Sec B3.3 - The Tendon Force Data Collected for Year 3 is Missing and Not Used in the Regression Analysis in the Final Report for the 20th Year Containment IWL Inspection 10/07/2010

22. CAR 201104410 Tendon Grease Can Leaking in Tendon Gallery 05/26/2011

23. CAR 200609470 Ground-Water Leakage AB 1974 11/15/2006

24. CAR 201004223 Refuel 17: IWL L2.20 Tendon Wire Elongation Requirements Were Not Met during Test. See Sept. 9, 2010 Owners Activity Reports (OAR-1) for Refuel 17 05/04/2010 Document Title Revision/Date

25. SA10-ES-S02 Simple Self-Assessment Report - CAR 201000189 Containment Post Tensioning System Objectives:

(1) To determine any improvement opportunities in surveillance process or in overall program (2) The best practices that could be used 12/08/2010

26. C-0101(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Typical Details Revision 06

27. C-0102(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Wall Details Revision 02

28. C-0103(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Equipment Hatch Details Revision 02

29. C-0104(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Personnel Hatch Details Revision 06

30. C-0105(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Developed Tendon Layout Revision 02

31. C-01-301 Inland Ryerson - Bechtel SNUPPS, Vertical Sheathing and Trumplate Location 90 to 270 Revision J

32. C-01-302 Inland Ryerson - Bechtel SNUPPS, Vertical Sheathing and Trumplate Location 270 to 90 Revision J

33. C-01-305 Inland Ryerson - Bechtel SNUPPS, Wall Tendon Development Elevation Revision S

34. C-01-309 Inland Ryerson - Bechtel SNUPPS, Section Details of Equipment Hatch Thickened Wall at 128 Revision J

35. C-01-314 Inland Ryerson - Bechtel SNUPPS, Dome Tendon Development Revision L

36. C-01-318 Inland Ryerson - Bechtel SNUPPS, Developed Dome Tendon Plan (Partial)

Revision N

37. C-01-320 Inland Ryerson - Bechtel SNUPPS, Dome Buttress Sections Revision C

38. C-01-321 Inland Ryerson - Bechtel SNUPPS, Post-Tensioning Sequence Revision H

39. C-01-303 Inland Ryerson - Bechtel SNUPPS, Base Slab Gallery and Drain Details Revision J

40. C-01-304 Inland Ryerson - Bechtel SNUPPS, Key Plan, Buttress and Tendon Details Revision D During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the acceptance criteria program element insufficient information was available to determine if it was consistent with the corresponding program element of the GALL Report AMP. To obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

The acceptance criteria program element of the LRA AMP states that Callaway acceptance criteria for concrete degradation are in accordance with IWL-2510, and are consistent with ACI 201.1R and ACI 349.3R. The GALL Report AMP recommends the acceptance criteria provided in IWL-2510, which references ACI 201.1R and ACI 349.3R for identification of concrete degradation. It is not clear to the staff that these statements are consistent because ACI 349.3R was not referenced in any of the plant procedures, and it appears that ACI 349.3R Chapter 5, Evaluation Criteria, was not used during examinations of the concrete containment building.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.

During the walkdown on May 2, 2012, the staff identified cracks mapped around the vertical tendon casing concrete in the tendon gallery. The staff could not determine if they are passive cracks, as defined in ACI 349.3R, and was not able to conclude whether the Evaluation Criteria of ACI349.3R was used.

During the walkdown on May 2, 2012, the staff observed that portions of the containment exterior surface were obstructed by the containment vent duct. It was not clear how the containment concrete surface obstructed by the containment vent duct could be visually inspected during the scheduled IWL examinations.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending are consistent with the corresponding program elements in GALL Report AMP XI.S2. The staff also identified certain aspects of LRA program element acceptance criteria that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information about operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.28, ASME Section XI, Subsection IWF Summary of Information in the Application. The LRA states that AMP B2.1.28, ASME Section XI, Subsection IWF, is an existing program with enhancements 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. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the ultimate heat sink cooling tower and the retention pond. The staff also conducted an independent search of the applicants operating experience database using keywords: loss of material, torque, and support.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.28 Callaway Plant Aging Management Program Evaluation Report: ASME Section XI, Subsection IWF - B2.1.28 Revision 2, 11/11/2011

2. APA-ZZ-00662 ASME Section XI Repair/Replacement Program Revision 20

3. EDP-ZZ-01003 Inservice Inspection Program Revision 24

4. QCP-ZZ-05042 Visual Examination to ASME VT-3 Revision 19

5. CARS #:

200507407 Weld between Stanchion and Embed Plate Too Corroded To Inspect Discovery Date 09/26/2005

6. Detail Information for CARS #:

200507407 Cars and Action Full Detail: Detail Information for CAR:

200507407 Close Date 05/23/2006

7. CARS #:

200704856 ESW Strainer Bases Are Cracked Discovery Date 05/04/2007

8.

Callaway Plant Unit 1 Union Electric Co. Owners Activity Report (Form OAR-1) for Refuel 15 08/08/2007

9.

Callaway Plant Unit 1 Union Electric Co. Owners Activity Report (Form OAR-1) for Refuel 16 02/05/2009

10. N-586-1 ASME Code Case N-586-1 05/04/2004

11. N-652-1 ASME Code Case N-652-1 02/20/2004 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 verified that the scope of program, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the preventive actions, and detection of aging effects program elements, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The preventive action program element of the LRA AMP does not discuss the use of molybdenum disulfide lubricants and does not clearly state that they have not been used in the past. The GALL Report AMP recommends refraining from using molybdenum disulfide and other lubricants containing sulfur for high-strength bolting applications. It is not clear to the staff that these statements are consistent because the applicant has no programmatic guidance in place to prohibit the use of molybdenum disulfide lubricants.

The detection of aging effects program element of the LRA AMP states that volumetric examinations will be conducted on high-strength bolting; however, no discussion is provided on the number of high-strength bolts within the scope of the program or how the bolts will be selected for inspection. The GALL Report AMP recommends volumetric examination for high-strength structural bolting (actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa) in sizes greater than 1-inch nominal diameter. It is not clear to the staff that these statements are consistent because the applicant does not explain how many bolts will be inspected, or how the bolts will be selected for inspection.

The preventive action program element of the LRA AMP includes an enhancement to specify that bolting material, installation torque or tension, and use of lubricants are in accordance with the applicable EPRI guidelines, American Society of Testing and Materials (ASTM) standards, American Institute of Steel Construction (AISC) specifications, and NUREG recommendations to prevent degradation due to SCC. The GALL Report recommends that if bolting consists of ASTM A325, F1852, or A490 bolts, the preventive actions for storage, lubricants, and SCC potential discussed in Section 2 of the Research Council for Structural Connections (RCSC) publication, Specification for Structural Joints Using ASTM A325 or A490 Bolts, be used. Although the applicant plans to enhance its program, it is not clear to the staff that the enhancement will adequately capture the recommended guidance in the RCSC document.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject discussed below.

ASME Section XI, Subsection IWF states, that to the extent practical, the same supports selected for examination during the first inspection interval shall be examined during each successive inspection interval. Recent industry operating experience has revealed situations in which supports within the IWF sample were degraded, but did not meet the IWF threshold for repair. The supports were reworked to as-new condition and remained in the IWF sample. The staffs concern with respect to aging management is that if ASME Code,Section XI, Subsection IWF supports that are part of the inspection sample are reworked to as-new condition, they are no longer typical of the other supports in the population. Subsequent ASME Code,Section XI, Subsection IWF inspections of the same sample would not represent the age-related degradation of the rest of the population. The LRA and the associated basis documents provided no discussion of how this issue would be addressed.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, parameters monitored or inspected, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.S3.

The staff also identified certain aspects of LRA program elements preventive actions, and detection of aging effects that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information on operating experience is required before a determination can be made about the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.29, 10 CFR Part 50, Appendix J Summary of Information in the Application. The LRA states that AMP B2.1.29, 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. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the auxiliary building, tendon gallery, turbine building, and the exterior of the containment structure.

The staff also conducted an independent database search of the applicants operating experience database using the keywords: Appendix J, leak rate testing, ILRT, and LLRT.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.29-3 10 CFR Part 50, Appendix J Revision 3, 12/14/2011

2. CW-OE-CAR-200405610 Containment Hatch Barrel LRT (ISP-SM-LL0L3) Failure (R570993B)

Revision 1, 12/06/2010

3. CW-OE-NRC IN 85-08 Industry Experience on Certain Materials Used in Safety-Related Equipment - As reviewed and evaluated by CW Revision 2, 07/22/2011

4. CW-OE-NRC IN 92-20 UOTE 92-095 Inadequate LLRT-As reviewed and evaluated by CW Revision 0, 12/06/2010

5. CW-OE-NRC IN 97-10 Liner Corrosion in Concrete Containments - As reviewed and evaluated by CW Revision 1, 09/15/2011

6. CW-OE-NRC IN 2004-09 Corrosion of Steel Containment and Containment Liner - As reviewed and evaluated by CW Revision 1, 09/15/2011 Document Title Revision/Date

7. CW-OE-NRC IN 2010-12 CAR201006117 Containment Liner Corrosion - As reviewed and evaluated by CW Revision 1, 09/15/2011

8. CW-OE-NRC IN 85-08 Industry Experience on Certain Materials Used in Safety-Related Equipment - As reviewed and evaluated by CW Revision 2, 07/22/2011

9. CW-AMP-CMPLIST CW License Renewal Component List (CMPLIST) 03/21/2012

10. ESP-SM-01001 Containment LRT Program Revision 23

11. ESP-GP-01007 Reactor Building ILRT Revision 12

12. APA-ZZ-00500 Corrective Action Program

13. ESP-ZZ-01016 ASME Section XI IWE Containment Pressure Boundary Inspection Revision 6

14. ESP-ZZ-01011 Containment Structural Integrity Inspection Revision 6

15. OSP-GP-LL036 Containment Isolation Flange Leak Rate Test Revision 5

16. OSP-GP-LL050 Containment Isolation Flange Leak Rate Test Revision 5

17. OSP-GP-LL068 Containment Isolation Flange Leak Rate Test Revision 5

18. APA-ZZ-00101 Processing Procedures, Manuals, and Desktop Instructions Revision 61

19. C-2L2956 Callaway Plant - Pressure Boundary Drawings, Reactor Building Floor Plan, El. 1998'-6

Revision 1, 09/28/2005

20. C-2L2957 Callaway Plant - Pressure Boundary Drawing, Reactor Building Dome Plan Revision 0, 09/02/1999

21. C-2L2958 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Floor Details Revision 0, 09/02/1999

22. C-2L2959 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Developed Elevations Revision 1, 09/02/1999

23. C-2L2960 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Developed Elevations Revision 0, 09/02/1999

24. C-2L2961 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Personnel Access Hatch Revision 0, 09/02/1999

25. C-2L2962 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Equipment Hatch Revision 0, 09/02/1999

26. C-2L2963 Callaway Plant - Pressure Boundary Drawing, Reactor Building, Encapsulated Containment, Recirc. Sump Piping Plan - Typical Penetration Details Revision 0 09/02/1999 During the audit of program elements 1-6 the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the scope of program program element, insufficient information was available to determine if it was consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

The scope of program program element includes all of the pressure retaining components of the containment structure. However, the plants FSAR-SP and leak rate test (LRT) procedure, state that certain Type B and/or C components are excluded from local leak rate tests (LLRT). In addition, for certain penetrations the plant has substituted LLRTs in place of VT-2 Inspections. It is not clear how the applicant will manage the aging effects for the components excluded from 10CFR Part 50, Appendix J testing or inspections during the period of extended operation.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.S4. The staff also identified certain aspects of LRA program element scope of program that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.30, Masonry Wall Summary of Information in the Application. The LRA states that AMP B2.1.30, Masonry Wall, is an existing program that is consistent with the program elements in GALL Report AMP XI.S5, Masonry Wall, and is integrated and implemented as part of the Structures Monitoring Program (B2.1.31). To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the auxiliary building and the turbine building lube oil storage tank room. The staff also conducted an independent search of the applicants operating experience database using the keywords:

degradation, cracking, masonry, and concrete.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.30 Callaway Plant Aging Management Program Evaluation Report: Masonry Walls - B2.1.30 Revision 1, 07/18/2011

2. ESP-ZZ-01013 Maintenance Rule Structures Inspection Revision 6

3. EDP-ZZ-01128 Maintenance Rule Program Revision 18

4.

Maintenance Rule Walkdown Report - Turbine Building 08/31/2005

5.

Maintenance Rule Walkdown Report - Turbine Building 04/16/2009 During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the acceptance criteria program element insufficient information was available to determine if it was consistent with the corresponding program element of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.

The acceptance criteria program element of the LRA AMP basis document provides proposed quantitative acceptance criteria for masonry walls as an enhancement to the program. However, no basis is provided for the proposed acceptance criteria. The GALL Report AMP recommends further evaluation if the extent of cracking and loss of material identified is sufficient to affect the intended function of the wall or invalidate its evaluation basis. It is not clear to the staff that these statements are consistent because the applicant did not provide a basis for the acceptance criteria, nor did it compare the acceptance criteria in the basis documents to the recommended guidance in the GALL Report.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing RAIs for the subject discussed below.

The GALL Report AMP XI.S5, Masonry Walls, recommends structures within scope of the program be inspected on a frequency not to exceed 5 years. The detection of aging effects program element in the LRA basis document states that inspections are performed at intervals no more than 5 years; however, no discussion of inspection interval is provided in the LRA or the FSAR supplement program description. This level of detail needs to be captured in the FSAR supplement to provide the staff assurance that the programs will be properly implemented during the period of extended operation.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending are consistent with the corresponding program elements in GALL Report AMP XI.S5. The staff also identified certain aspects of LRA program element acceptance criteria that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.31, Structures Monitoring Summary of Information in the Application. The LRA states that AMP B2.1.31, Structures Monitoring, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.S6, Structures Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of different in-scope structures, including the auxiliary, fuel, turbine and reactor buildings. The staff also conducted an independent search of the applicants operating experience database using keywords: concrete, corrosion, damage, degradation, erosion, excavation, leaching, loss of material, rust, spalling, and underground.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.31 Callaway Plant Aging Management Program Evaluation Report, Structures Monitoring - B2.1.31 Revision 3, 03/05/2012

2. ESP-ZZ-01013 Maintenance Rule Structures Inspection, Including Appendices A through D Revision 6

3. CAR No.

200609470 Groundwater in-leakage AB 1974

4. Doc No. 91017 Generic Safety Issue 29, Bolting Degradation or Failure in Nuclear Power Plants 07/19/2011

5. CAR No.

200200434 Leaking Roof/Equipment Stores 1 Office Area 08/26/2010 Document Title Revision/Date

6. CAR No.

200200983 Degradation of Isolation Joint Seals 08/26/2010

7. CAR No.

200900096 Support Beams Under Intake Strainers Corroded 09/10/2010

8. CAR No.

200803956 Slow Leak Through Concrete Wall Near PDA2101A, CIRC Water Pump A 08/26/2010

9. CAR No.

200801207 Concrete Wall Degradation in the D UHS Cooling Tower Fan Room 11/15/2010

10. CAR No.

200703872 Several Small Roof Leaks above the Spent Fuel Pool 08/30/2010 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 verified that the preventive actions program element of the LRA AMP is consistent with the corresponding element of the GALL Report AMP. In addition, the staff found that for the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

Element 1, scope of program, of the Structures Monitoring program basis document as well as the implementing procedure, ESP-ZZ-01013 of the Structures Monitoring program, has excluded penetrations, pipe and raceway supports, cable trays, anchor bolts, transmission towers, electrical conduits, and ultimate heat sink retention pond from the scope of existing AMP before the period of extended operation. The GALL Report AMP recommends that the scope of the program include all structures, structural components, component supports, and structural commodities in the scope of license renewal, including structures, structural components, and commodities not covered by other structural AMPs. Examples of structures, structural components, and commodities in the scope of license renewal are concrete and steel structures, structural bolting, anchor bolts and embedments, component support members, pipe whip restraints and jet impingement shields, transmission towers, panels and other enclosures, racks, sliding surfaces, sump and pool liners, electrical cable trays and conduits, trash racks associated with water control structures, electrical duct banks, manholes, doors, penetration seals, and tube tracks. It is not clear to the staff how structures currently excluded from the existing implementing procedure of the ESP-ZZ-01013 will be inspected and degradations trended prior to the period of extended operation.

Element 3 parameters monitored or inspected, of the LRA Structures Monitoring program basis document states that the inspection methods, inspection frequency, and inspector qualifications at Callaway are consistent with the guidance provided in ACI 349.3R-96. However, a review of the Callaway implementing procedure ESP-ZZ-01013, Maintenance Rule Structures Inspection, indicates that the inspection methods, including walkdown examination guidance and qualification requirements for inspectors are not consistent with ACI 349.3R. The GALL Report AMP recommends that parameters monitored or inspected are to be commensurate with industry codes, standards, and guidelines and also consider industry and plant-specific operating experience. ACI 349.3R and ANSI/ASCE 11 provide an acceptable basis for selection of parameters to be monitored or inspected for concrete and steel structural elements and for steel liners, joints, coatings, and waterproofing membranes. It is not clear to the staff how the implementing procedure ESP-ZZ-01013 is consistent with the GALL Report AMP.

Element 4, detection of aging effects, of the LRA Structures Monitoring program basis document states that inspections are performed at intervals of not more than 5 years.

Although this is stated in the basis documents, no discussion of inspection interval is provided in the LRA or the FSAR supplement program summary. Therefore, the staff will request the applicant to revise the FSAR supplement to incorporate the 5-year inspection interval to provide the staff assurance that the program will be properly implemented during the period of extended operation.

The LRA and the program basis document states that groundwater is monitored for pH, chlorides, and sulfates every 5 years, and the results are evaluated by engineering to assess the impact, if any, on below-grade structures. With the exception of two monitoring wells, pH, chlorides, and sulfates concentrations have been within the prescribed limits for non-aggressive groundwater/soil. The two wells have shown seasonal increases in chloride levels of up to 680 mg/L (ppm) while the pH and sulfate concentrations have remained non-aggressive. The GALL Report, program element 4, detection of aging effects, recommends that for plants with chlorides greater than 500 ppm in the groundwater/soil, a plant-specific AMP accounting for the extent of the degradation experienced should be implemented to manage the concrete aging during the period of extended operation. It is not clear to the staff how the aging of the inaccessible concrete elements will be managed during the period of extended operation due to the presence of high chloride concentrations.

Element 6, acceptance criteria, of the LRA Structures Monitoring program basis document states that the Callaway Structures Monitoring program provides guidance for the determination of the performance criteria for SSCs included within the scope of the Maintenance Rule (

Reference:

ESP-ZZ-01013, Appendix B). These guidelines were used to establish the inspection attributes for SSCs. The Callaway Structures Monitoring program uses Acceptable, Acceptable with Deficiencies, and Unacceptable, to classify levels of aging effects for each inspection attribute. Element 6 of the program also states that the Structures Monitoring program will be enhanced to quantify acceptance criteria and critical parameters for monitoring degradation, and procedures will also be enhanced to incorporate applicable industry codes, standards, and guidelines for acceptance criteria. During the audit, the staff reviewed the proposed enhancement described in Appendix D of the procedure ESP-ZZ-01013, and could not find the basis or reference to any industry standard for some of the acceptance criteria.

In addition, it is not clear to the staff how the acceptance criteria described in Section 7.5 and Appendix D of the procedure ESP-ZZ-01013 are consistent.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.

Appendix C of the implementing procedure ESP-ZZ-01013 for the Structures Monitoring program states that gaps filled with an elastomeric are deemed to have degraded when they no longer perform their intended function. Functionality is compromised if the elastomer is cracked, torn, brittle, not bonded to adjoining media, or shows signs of in-leakage. Furthermore, an elastomer filled gap is deemed to have degraded if the gap is occupied by a foreign material and is considered to have failed if the as-found gap dimension is less than that prescribed by design. However, during the audit, the staff reviewed corrective action reports and during walkdowns observed that elastomers in the seismic gaps of the containment, turbine, and auxiliary buildings have been degraded and are not functional. In addition, in one area in the auxiliary building the elastomer has been replaced with a foreign material. This condition has caused in-leakage of ground and rain water into the buildings. It is not clear to the staff how the aging of the non-functional elastomeric gaps will be managed and trended during the period of extended operation.

During the audit, the staff performed a walkdown of the reactor building tendon gallery and observed leaching of concrete. The staff also reviewed CAR No. 200806266 that documented the presence of leaching of tendon gallery concrete. The applicant performed chemical analysis of the white substance removed from the leached area and determined that leaching is due to groundwater leakage, and this does not affect the structural integrity of the tendon gallery. There is no discussion about prevention of groundwater leakage and effect of leaching on concrete and rebar. It is not clear to the staff how the applicant plans to monitor and manage aging of the concrete in the tendon gallery affected by leaching.

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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing an RAI for the subject discussed below.

The FSAR supplement does not describe the inspection frequency for the structures, systems, and components included in the scope of the Structures Monitoring program.

This level of detail needs to be captured in the FSAR supplement to provide the staff assurance that the programs will be properly implemented during the period of extended operation.

Audit Results. Based on this audit, the staff verified that the LRA program element preventive actions is consistent with the corresponding program element in GALL Report AMP XI.S6. The staff also identified certain aspects of LRA program elements scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information about operating experience is required before a determination can be made regarding the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.32, RG 1.127 Inspection of Water-Control Structures Associated with Nuclear Power Plants Summary of Information in the Application. The LRA states that AMP B2.1.32, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, is an existing program 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. This program is implemented as part of the Structures Monitoring Program (SMP). To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted a walkdown of the ultimate heat sink retention pond. The staff also conducted an independent search of the applicants operating experience database using the keywords: retention pond, ESW pump house, and discharge structure.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.32 Callaway Aging Management Program Evaluation Report, RG 1.127, Inspection of Water-Controlled Structures Associated with Nuclear Power Plants - B2.1.32 Revision 2, 03/23/2012

2. ESP-ZZ-01013 Maintenance Rule Structures Inspection Revision 6

3. ESP-EF-03002 Ultimate Heat Sink Retention Pond Inservice Inspection Revision 6

4. ESP-ZZ-03907 Settlement Monitoring Program Revision 5

5. FSAR SA Table 2.5-55 Estimated, Measured, and Allowable Settlements Rev. OL-13 05/03

6. CAR 200609956 Concrete Wall Degradation in the D UHS Cooling Tower Fan Room

7. CAR 200801207 Concrete Wall Degradation in the D UHS Cooling Tower Fan Room

8. CAR 200502084 Concrete Wall Degradation in the A UHS Cooling Tower Fan Room During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing an RAI for the subject discussed below.

The FSAR supplement does not describe the inspection frequency for the SSCs included in the scope of the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP. This level of detail needs to be captured in the FSAR supplement to provide the staff assurance that the programs will be properly implemented during the period of extended operation.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.S7.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.33, Protective Coating Monitoring and Maintenance Program Summary of Information in the Application. The LRA states that AMP B2.1.33, Protective Coating Monitoring and Maintenance Program, is an existing program with enhancements and an exception that is consistent with the program elements in GALL Report AMPXI.S8, Protective Coating Monitoring and Maintenance Program. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: coating, Service Level 1 coating, and paint.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.33.

Protective Coating Monitoring and Maintenance Revision 1, 11/23/2011

2. CAR No.

200810440 XI.S8 Protective Coating Monitoring and Maintenance

3. CAR No.

201003484 XI.S8 Protective Coating Monitoring and Maintenance

4. CAR No.

201108490 XI.S8 Protective Coating Monitoring and Maintenance

5. CAR No.

201108490 XI.S8 Protective Coating Monitoring and Maintenance 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 the scope of program, program element of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the scope of program program element not associated with the exception are consistent with the corresponding program element in the GALL Report AMP. The staffs evaluation of aspects of this program element associated with the exception will be addressed in the SER.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.S8. The staff also verified that for the scope of program program element, the aspects of the LRA AMP program element not associated with the exception are consistent with the corresponding program elements in GALL Report AMP XI.S8. The staffs evaluation of aspects of the program element associated with the exception will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.34, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA states that AMP B2.1.34, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.E1, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the switchyard. The staff also conducted an independent search of the applicants operating experience database using keywords: cable, corrosion, and cracking.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.34 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 4, 04/27/2012

2. 200701308 Callaway Action Request System - NRC Generic Letter 2007-01 Responses 02/12/2007

3. 200704419 Callaway Action Request System - 5KV cable has split insulation to motor DPAD01A 04/24/2007 The staff conducted its audit of LRA program elements 1-7, based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, acceptance criteria, and monitoring and trending are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, acceptance criteria, and monitoring and trending are consistent with the corresponding program elements in GALL Report AMP XI.E1. The staffs evaluation of aspects of the program elements associated with enhancements which are not necessary for consistency will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.35, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Summary of Information in the Application. The LRA states that AMP B2.1.35, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.E2, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: cable, corrosion, connections, splices, brittle, crack, and degraded.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.35 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Revision 4, 04/27/2012

2. 200404746 Callaway Action Request System - Signal Noise on N61 Gamma-Metrics Signal Cables B 06/04/2004 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 verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that the LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.E2. The staffs evaluation of aspects of the program elements associated with enhancements which are not necessary for consistency will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.36, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA states that AMP B2.1.36, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the LRA AMP.

Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of in-scope manholes MH59-31, MH59-01A, MH59-01B, MH59-12, MH59-20, and MH59-19; and switchyard control house cable pit 2, confirming locations, labeling, cover integrity, and susceptibility to surface water runoff. Manhole MH59-12 was opened for inspection. The staff also conducted an independent search of the applicants operating experience database using keywords: manhole, duct, water, cable, underground, and vault.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.36 Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements - B2.1.36 NUREG 1801 Program XI.E3 Revision 4, 04/13/2012

2. CARS 201101616 Manhole MH01 South (B Train) Contained Approx. 24 Inches of Water 02/28/2011

3. CARS 201008001 Lack of Medium Voltage Cable Strategy 08/21/2010

4. CARS 200905490 Manhole MH01 South (B Train) Contained Approximately 3' 7" of Water 07/10/2009

5. CARS 201104447 Develop Modification Package To Prevent Cable Submergence in Manholes 05/27/2011

6. Job #11004839 Install Sump Pump and Level Indication in MH59-19 02/28/2012

7. Job #11004841 Install Sump Pump and Level Indication in MH59-20 04/02/2012

8. Job #11004842 Install Sump Pump and Level Indication in MH59-12 01/18/2012

9. Job #11004843 Install Sump Pump and Level Indication in MH59-01A 04/13/2012

10. Job # 11004844 Install Sump Pump and Level Indication in MH59-01B 12/22/2011

11. GL 2007-01 Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients 02/07/2007

12. ULNRC-05415 90 Day Response to NRC Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients 05/07/2007

13.

05000483/2010005 Callaway Plant - NRC Integrated Inspection Report 01/26/2011

14.

05000483/2011003 Callaway Plant - NRC Integrated Inspection Report 07/18/2011

15.

05000483/2011002 Callaway Plant - NRC Integrated Inspection Report 05/04/2011

16. EDP-ZZ-07001 Cable Management Program Revision 000ac

17. MP 11-0011 Change Package - Post Change Test Plan Not applicable

18. CAR 201107826 MH01 South B Train Contained Approx. 2 Inches Water 10/11/2011

19. CAR 200701308 NRC Generic Letter 2007-01 Responses 02/12/2007 Document Title Revision/Date

20. 11004845 Install Sump Pump and Level Indication in MH59-04 09/02/2011

21. 11004847 Install Sump Pump and Level Indication in MH59-05 09/02/2011

22. 12001060 Install Sump Pump and Level Indication in MH59-10 02/21/2012 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 verified that the preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the scope of program, and detection of aging effects, program elements, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The scope of program program element of Basis Document CW-AMP-B2.1.36, Inaccessible Power Cable Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, does not indicate voltage level of in-scope inaccessible power cable (e.g., greater than or equal to 400 volts). Additionally, FSAR supplement A1.36 does not specify voltage level. The GALL Report AMP recommends the AMP apply to all inaccessible or underground power (greater than or equal to 400 volts) cables within the scope of license renewal that are exposed to adverse environments. It is not clear to the staff that these statements are consistent because it cannot be determined that the applicants program includes 400 volt inaccessible power cables.

The detection of aging effects program element of Basis Document CW-AMP-B2.1.36, Procedure EDP-ZZ-07001, and FSAR supplement A1.36 do not state that test frequencies are adjusted based on test results as well as operating experience. The GALL Report AMP recommends that for power cables exposed to significant moisture test frequencies be adjusted based on test results (includes trending of degradation where applicable) and operating experience. It is not clear to the staff that these statements are consistent because the applicants documents do not include revising test frequencies based on either test results or operating experience.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing RAIs for the subject(s) discussed below.

FSAR supplement A1.36 does not specify voltage level and does not state that test frequencies are adjusted based on test results as well as operating experience. It is not clear to the staff that these statements are consistent with GALL Report AMP XI.E3.

Audit Results. Based on this audit, the staff verified that LRA program elements preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.E3.

The staff also identified certain aspects of LRA program elements scope of program, and detection of aging effects that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B2.1.37, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA states that AMP B2.1.37, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that is consistent with the program elements in GALL Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent database search of the applicants operating experience database using the keywords: cable connections, loosening, and corrosion.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.37 Callaway Plant Aging Management Program Evaluation Report

- Electrical Cable Connection Not Subject to 10 CFR 50.49 Environmental Qualification Requirements - B2.1.37 Revision 3

2. CAR 200000569 Callaway Plant License Renewal Aging Management CAR Operating Experience Report for AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 01/14/2010

3. CAR 200102076 Callaway Plant License Renewal Aging Management CAR Operating Experience Report for AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 01/14/2010 Document Title Revision/Date

4. EDP-ZZ-07001 Cable Management Program Revision 000b During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the acceptance criteria program element insufficient information was available to determine if it was consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The acceptance criteria program element of the Callaway Plant AMP Evaluation Report for Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP states that the acceptance criteria for thermography testing will be based on the temperature rise above the reference temperature. The reference temperature will be ambient temperature or the baseline temperature data from the same type of connections being tested. The applicant referenced Procedure EDP-ZZ-07001 Section 4.3.13. Section 4.3.13 of this procedure states that the acceptance criteria for the review of thermography results for the one-time inspection of cable connections will based on the temperature rise above a reference temperature.

The reference temperature will be ambient temperature or the baseline temperature data from the connections being tested. The procedure does not specify what the acceptance criteria for thermography inspections are. Non-compliance with acceptance criteria is used to perform an evaluation when the test acceptance criteria are not met.

The evaluation may include changes to the one-time inspection, increased inspection frequency, and replacement or repair of the affected connections. The GALL Report AMP recommends that cable connections should not indicate abnormal temperature for the application when thermography is used. It is not clear to the staff that these statements are consistent because Procedure EDP-ZZ-07001 Section 4.3.13 does not specify acceptance criterion for thermography inspections.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects and monitoring and trending are consistent with the corresponding program elements in GALL Report AMP XI.E6. The staff also identified certain aspects of LRA program element acceptance criteria that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.38, Monitoring of Neutron-Absorbing Materials other than Boraflex Summary of Information in the Application. The LRA states that AMP B2.1.38, Monitoring of Neutron-Absorbing Materials other than Boraflex, is a new program that is consistent with the program elements in GALL Report AMP XI.M40, Monitoring of Neutron-Absorbing Materials other than Boraflex. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the spent fuel pool building. The staff also conducted an independent search of the applicants operating experience database using the keywords: neutron absorber, Boral, and boron.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.38 Monitoring of Neutron-Absorbing Materials other than Boraflex Revision 1

2. CAR No.

200909146 XI.M40 Monitoring of Neutron-Absorbing Materials other than Boraflex During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). Although the applicant did not provide plant-specific operating experience for staff review, it provided documentation demonstrating that industry operating experience is evaluated and incorporated into this program element.

The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.M40.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B2.1.39, Metal Enclosed Bus Summary of Information in the Application. The LRA states that AMP B2.1.39, Metal Enclosed Bus, is a new program that is consistent with the program elements in GALL Report AMP XI.E4, Metal Enclosed Bus. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of metal enclosed bus providing power to the service water pumps. The staff also conducted an independent search of the applicants operating experience database using the keywords: bus insulation, loose connection, corrosion, and cracking.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B2.1.39 Metal Enclosed Bus Revision 3

2. EDP-xx-nnnnn Metal Enclosed Bus Clean and Inspect Revision 0b

3. CARS 200909297 Operating Experience Report for AMP B2.1.39 04/29/2012

4. CARS 200508906 Operating Experience Report for AMP B2.1.39 05/11/2010

5. CARS 201203319 Bird Nest Identified in S/U Transformer Overhead Cable Tray 05/01/2012 During the audit of program elements 1-6, the staff found that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding element(s) of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP XI.E4.

Based on this audit the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B3.1, Fatigue Monitoring Summary of Information in the Application. The LRA states that AMP B3.1, Fatigue Monitoring, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP X.M1, Fatigue Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using keywords: cycle, fatigue, and cyclic.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B3.1 Fatigue Monitoring Revision 3, 11/28/2011

2. EDP-ZZ-01123 FatiguePro Cycle/Transient Monitoring Revision 2

3. ETP-ZZ-01002 Tracking Transients and Usage Factors Revision 6

4. APA-ZZ-00600 Design Change Control Revision 42

5. ZZ-006 Engineering Changes Revision 30, 06/24/2011

6.

Operating Experience Summary Report - Fatigue Monitoring (Industry and CAR)

7. CAR No.

200602827 Feedwater Isolation Valve Rupture Discs Leaking

8. CAR No.

200810394 Surge Line Delta T Exceeded 80 °F

9. CAR No.

200909691 Operational Enhancement: Switch to Alternate Charging in Cycle 18 Document Title Revision/Date

10. CAR No.

201103192 Evaluate 120 gpm Letdown Flow on Charging Lines Fatigue Design

11. CAR No.

201102233 Normal 120 gpm CVCS Letdown Flow outside CVCS Fatigue Design Basis

12. FP-CALL-304 Baseline Analysis of Callaway Plant Cycles and Fatigue Usage - Startup through 1/31/2011 Revision 1, 10/13/2011

13. CAR No.

201102470 Indeterminate Document Requirements for Shared Components - for shared Non-ASME and ASME Section III Components and Parts

14. Specification No.

S-1068 (Q)

Technical Specification for Pressurizer Safety Valve and RHR Pump Suction Relief Valve Testing and Refurbishment Revision 4, 03/09/2009

15. CN-SEE-III-11-30 Callaway CVCS Heat Exchangers Revised Transients:

Fatigue, Flow Velocity, and Pressure Drop Evaluations Revision 1, 11/23/2011

16. FP-CALL-307 Environmentally Assisted Fatigue Screening Revision 2, 04/30/2012

17. FP-CALL-310 Benchmarking of Charging Nozzle Stress-Based Fatigue Revision 0, 06/22/2011

18. CAR No.

201106192 Excess Letdown Heat Exchanger Fatigue Design Basis Transient Issue

19. CAR No.

200703155 Pressurizer Cooldown Limit Exceeded When Taking the Pressurizer Solid

20. FP-CALL-402 System Review and Recommendations for a Fatigue Management Program at Callaway Plant Unit 1 Revision 2, 11/23/2010

21. FP-CALL-405 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for Callaway Plant Revision 0, 04/29/2011

22. Job 08501202-330 Certificate of Conformance of Work Performed for Wolf Creek and Callaway - Purchase Order #745261 01/16/2010 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 verified that the scope of program, detection of aging effects, monitoring and trending, acceptance criteria and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the preventive actions and parameters monitored or inspected program elements, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.

The preventive actions program element of the LRA AMP provides an enhancement, which states that [p]rocedures will be enhanced to require the review of the temperature and pressure transient data from the operator logs and plant instrumentation to ensure actual transient severity is bounded by the design and to include environmental effects where applicable. The GALL Report AMP recommends ensuring that the actual transient severity does not exceed the bounds of the design transient definitions. The staff noted that ensuring that the design severity of a transient is not exceeded during plant operation is an essential part of a Fatigue Monitoring Program; therefore, considering this enhancement to the applicants existing program, it is not clear to the staff how the applicant ensured that the accumulated transients from initial plant startup until the procedures are enhanced will be bound by the design transients.

The parameters monitored or inspected program element of the LRA AMP provides an enhancement, which states that [p]rocedures will be enhanced to include additional transients that contribute significantly to fatigue usage identified by evaluation of ASME Section III fatigue and fatigue crack growth analyses. The GALL Report AMP recommends the program monitor all plant design transients that cause cyclic strains, which are significant contributors to the fatigue usage factor. It is not clear to the staff that these statements are consistent, because in contrast, LRA Section 4.3.1 states that this review of the design and licensing analyses has already been performed.

Therefore, it is not clear to the staff what will be enhanced in the procedures.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is not bounded by industry operating experience. The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

Regulatory Issue Summary (RIS) 2011-14, Metal Fatigue Analysis Performed by Computer Software, was issued on December 29, 2011. The staff noted that documentation of how the applicant addressed the recently issued RIS was not available to the staff during its audit; therefore, it is not clear if and how the applicant will address the issues discussed in RIS 2011-14.

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. To obtain the information necessary to verify the sufficiency of the FSAR supplement program description, the staff will consider issuing an RAI for the subject discussed below.

The applicants FSAR supplement in LRA Section A2.1 does not include a general description, or discuss how the monitoring methods will manage cumulative fatigue damage during the period of extended operation.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions are consistent with the corresponding program elements in GALL Report AMP X.M1. The staffs evaluation of aspects of the program elements associated with enhancements that are not necessary for consistency will be addressed in the SER. The staff also identified certain aspects of LRA program elements preventive actions and parameters monitored or inspected that will require additional information or evaluation before consistency can be determined.

Based on this audit, the staff also identified that additional information about operating experience is required before a determination can be made about the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B3.2, Environmental Qualification (EQ) of Electric Components Summary of Information in the Application. The LRA states that AMP B3.2, Environmental Qualification (EQ) of Electric Components, is an existing program that is consistent with the program elements in GALL Report AMP X.E1, Environmental Qualification (EQ) of Electric Components. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicants operating experience database using the keywords: cable and corrosion.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B3.2 Environmental Qualification (EQ) of Electric Components Program Revision 2, 10/04/2011

2. 201104724 Callaway Action Request System - Action Request 06/08/2011

3. 200904936 Callaway Action Request System - Area 5 Steam Tunnel Enclosure Temperature is High 06/21/2009

4. 200407904 Callaway Action Request System - Evaluate Bringing EQ Program to EPEG 05-04 Standards 10/15/2004

5. EQCN #91-02 Equipment Environmental Qualification Evaluation Check Sheet - Pressure Transmitters (Inside Containment)

Revision 2, 06/03/1991

6. 200906638 Callaway Action Request System - RIS 2005-20 First Available Opportunity Documentation - Job W238147 08/25/2009

7. EQ CN #91-02 Equipment Qualification Change Notice 05/23/1991

8. CA1339 Licensing Impact Review - Modification Package 00-1013, RSG Component Revision A, 02/21/2006

9. MP 08-0035 / 000.1 Install Additional Emergency Lights for Post Fire Safe Shutdown 10/06/2009 During the audit of program elements 1-6, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. To obtain the information necessary to determine if the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject discussed below.

Identify schedules or frequencies for publishing health reports, self-assessments, or benchmark report evaluations of the EQ program and to provide additional operating experience that demonstrates the effectiveness of the EQ program.

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP X.E1.

Based on this audit, the staff also identified that additional information about operating experience is required before a determination can be made about the sufficiency of the LRA AMP to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B3.3, Concrete Containment Tendon Prestress Summary of Information in the Application. The LRA states that AMP B3.3, Concrete Containment Tendon Prestress, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP X.S1, Concrete Containment Tendon Prestress. To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP. However, it does not consider the sufficiency of enhancements that are not necessary for consistency; these will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the auxiliary building, tendon gallery, turbine building, and the exterior of the containment structure.

The staff also conducted an independent search of the applicants operating experience database using keywords: concrete, tendon, and prestress.

The table below lists the documents that the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. CW-AMP-B3.3 Concrete Containment Tendon Prestress Revision 2, 02/15/2011

2. ESP-ZZ-01012 Containment Post Tensioning System Inspection Revision 8

3. C-1003(Q)

Specification for Inservice Inspection of the Containment Building Post-Tensioning System and Exterior Concrete Shell Revision 12

4. APA-ZZ-00500 Corrective Action Program Revision 53

5. C-01-114-F Bechtel TR Minimum Tendon Lift-Off Forces for Inservice Surveillance Revision 0, 01/11/1984

6. FSAR - CW SP 16.6.1.2.1 Containment Vessel Structural Integrity LCO Surveillance Requirements Revision OL-17, April 2009

7. CAR 200902154 ASME Section XI Subsection IWL Requirements Were Not Fully Met for the 20th Year Tendon Surveillance Revision 0, 11/18/2010

8. CAR 201009713 No Documentation Could Be Found indicating Callaway Evaluated NRC IN 99-10 Revision 0, 03/10/2011

9. CAR 200806266 Chemical Seeping from CTMT Wall inside Tendon Access Gallery 07/02/2008

10. CAR 200806266 Action 1 Document Results of Sample by Outside Lab 07/31/2008

11. CAR 200806266 Action 2 Evaluate Structural Integrity of Tendon Room Wall due to Leak 07/31/2008

12. CA-N1042-500 Callaway 25th Year Tendon Surveillance Final Report for the 25th Year Tendon Surveillance Revision 0, 09/16/2010

13. CAR 201009644 Year 3 Tendon Data Missing Revision 0, 10/07/2010

14. Unknown 25th Year Regression Analysis with 3rd Year results Included

15. CAR 201000189 Action 7 Simple Self-Assessment Report SA10-ES-S02:

Containment Post Tensioning System (APA-ZZ-01400 Appendix A)

Revision 9

16. CAR 201009755 Eval NRC IN 1999-10 Revision 1-Degradation of Prestressing Tendon Systems Revision 0, 10/12/2010

17. C-0101(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Typical Details Revision 6, 07/10/1981

18. C-0102(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Wall Details Revision 2, 12/31/1975

19. C-0103(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Equipment Hatch Details Revision 2, 12/31/1975

20. C-0104(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Personnel Hatch Details Revision 6, 07/10/1981

21. C-0105(Q)

Bechtel SNUPPS, Reactor Building, Prestressing Requirements, Developed Tendon Layout Revision 2, 03/22/1974

22. C-01-301 Inland Ryerson - Bechtel SNUPPS, Vertical Sheathing and Trumplate Location 90 to 270 Revision J, 08/23/1977

23. C-01-302 Inland Ryerson - Bechtel SNUPPS, Vertical Sheathing and Trumplate Location 270 to 90 Revision J, 08/23/1977

24. C-01-305 Inland Ryerson - Bechtel SNUPPS, Wall Tendon Development Elevation Revision S, 03/26/1979

25. C-01-309 Inland Ryerson - Bechtel SNUPPS, Section Details of Equipment Hatch Thickened Wall at 128 Revision J, 10/10/1977 Document Title Revision/Date

26. C-01-314 Inland Ryerson - Bechtel SNUPPS, Dome Tendon Development Revision L, 08/30/1978

27. C-01-318 Inland Ryerson - Bechtel SNUPPS, Developed Dome Tendon Plan (Partial)

Revision N, 01/23/1980

28. C-01-320 Inland Ryerson - Bechtel SNUPPS, Dome Buttress Sections Revision C, 08/23/1977

29. C-01-321 Inland Ryerson - Bechtel SNUPPS, Post Tensioning Sequence Revision H, 01/05/1981

30. C-01-303 Inland Ryerson - Bechtel SNUPPS, Base Slab Gallery and Drain Details Revision J, 11/03/1977

31. C-01-304 Inland Ryerson - Bechtel SNUPPS, Key Plan, Buttress and Tendon Details Revision D, 08/23/1977

32. CW Portal 50212 Pictures 1-35 Walkdown - Containment Structure 05/02/2012 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 verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (i.e., the applicant or the staff did not identify any previously unknown aging effects). The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this audit, the staff verified that LRA program elements scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria are consistent with the corresponding program elements in GALL Report AMP X.S1.

Based on this audit, the staff also verified that the operating experience is sufficient to indicate that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In addition, the staff verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

ML12180A023 OFFICE PM:RPB1:DLR LA:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME SCuadrado YEdmonds (ltr. only) DMorey SCuadrado DATE 07/31/2012 07/03/2012 08/07/2012 08/09/2012

Letter to Adam C. Heflin from Samuel Cuadrado de Jesús dated August 9, 2012.

SUBJECT:

AGING MANAGEMENT PROGRAMS AUDIT REPORT REGARDING THE CALLAWAY PLANT UNIT 1 LICENSE RENEWAL APPLICATION (TAC NO. ME7708)

DISTRIBUTION:

E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRsrg Resource RidsOgcMailCenter Resource SCuadrado DMorey CFells FLyon MSpencer (OGC)

GPick, RIV NOKeefe, RIV THartman, RIV