ML13141A320

Letter Aging Management Programs Audit Report Regarding the Sequoyah Nuclear Plant, Units 1 and 2

ML13141A320
Person / Time
Site:	Sequoyah
Issue date:	06/13/2013
From:	Plasse R Division of License Renewal
To:	James Shea Tennessee Valley Authority
Yoo, Mark 415-8583
References
TAC MF0481, TAC MF0482
Download: ML13141A320 (96)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 June 13, 2013 Mr. Joe W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority P.O. Box 2000 Soddy-Daisy, TN 37384

SUBJECT:

AGING MANAGEMENT PROGRAMS AUDIT REPORT REGARDING THE SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. MF0481 AND MF0482)

Dear Mr. Shea:

By letter, dated January 7,2013, Tennessee Valley Authority submitted an application for renewal of operating licenses DPR-77 and DPR-79 for the Sequoyah Nuclear Plant, Units 1 and 2. On March 29,2013, the staff of the U.S. Nuclear Regulatory Commission 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 301-415-1427 or bye-mail at Richard.Plasse@nrc.gov.

Sincerely, Richard A. Plasse, Project Manager Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosure:

As stated cc: Listserv

ML13141A320 CE PM: RPS 1:DL =':§P~O~S==:D:=:=L==R::;:::::::S==C==:R=:=: P=:=: S=:=1==:D=:=L==R====r=::::=pN===I==:R=:=::P==S=1==:D=:=L==R===91 E YDiaz-Sanabria RPlasse DATE 5/22/2013 6/212013 6/13/2013 Letter to J. Shea from Richard Plasse dated June 13, 2013

SUBJECT:

AGING MANAGEMENT PROGRAMS AUDIT REPORT REGARDING THE SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 (TAC NOS. MF0481 AND MF0482)

HARDCOPY:

DLRRF E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource beth. mizuno@nrc.gov brian. harris@nrc.gov john. pelchat@nrc.gov gena.woodruff@nrc.gov siva.lingam@nrc.gov wesley.deschaine@nrc.gov galen.smith@nrc.gov scott.shaeffer@nrc.gov jeffrey.hamman@nrc.gov craig.kontz@nrc.gov caudle.julian@nrc.gov joel.rivera-ortiz@nrc.gov steven. vias@nrc.gov

u.s. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket Nos: 50-327, 50-328 License Nos: DPR-77, DPR-79 Licensee: Tennessee Valley Authority Facility: Sequoyah Nuclear Plant, Units 1 and 2 Location: P.O. Box 2000 Soddy-Daisy, TN 37384 Dates: March 18-22, 2013 March 25-29, 2013 Reviewers: R. Plasse, Project Manager, Division of License Renewal (DLR)

M. Yoo, Project Manager, DLR A. Hiser, Senior Technical Advisor, DLR D. Morey, Branch Chief, DLR S. Ghasemian, Branch Chief, DLR B. Pham, Branch Chief, DLR C. Nickell, General Engineer, DLR B. Fu, Mechanical Engineer, DLR R. Kalikian, Materials Engineer, DLR S. Min, Materials Engineer, DLR C. Ng, Mechanical Engineer, DLR O. Vee, Mechanical Engineer, DLR W. Gardner, General Scientist, DLR J .Gavula, Mechanical Engineer, DLR K. Green, Sr. Mechanical Engineer, DLR W. Holston, Sr. Mechanical Engineer, DLR J. Wise, Materials Engineer, DLR A. Erickson, General Engineer, DLR D. Nguyen, Electrical Engineer, DLR A. Sheikh, Sr. Structural Engineer, DLR C. Hunt, Chemical Engineer, DLR A. Obodoako, Materials Engineer, DLR B. Venkataraman, Electrical Engineer, DLR R. Li, Electrical Engineer, DLR Approved By: Bo Pham, Chief Aging Management of Reactor Systems and Guidance Update Branch Division of License Renewal Shahram Ghasemian, Chief Aging Management of Plant Systems Branch Division of License Renewal ENCLOSURE

Michael Marshall, Chief Aging Management of Structures, Electrical, and Systems Branch Division of License Renewal ENCLOSURE

1 Introduction The staff of the U. S. Nuclear Regulatory Commission (NRC or the staff) conducted a 10-day audit at the Sequoyah Nuclear Plant, Units 1 and 2 (Sequoyah), in Soddy-Daisy, Tennessee, from March 18 to March 29, 2013. The purpose of this audit was to examine the aging management programs (AMPs) and related documentation of the Tennessee Valley Authority (TVA or the applicant) to verify the applicant's 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 AMP program elements: 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 staff's review of the Sequoyah license renewal application (LRA) and documented in the staff's 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 applicant's determination should be documented in an auditable form and maintained on site.

During this audit, the staff audited AMP elements one through six 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 applicant's AMPs were claimed to be consistent with the GALL Report and were audited against the related elements of the associated AMP described in the GALL Report, unless otherwise indicated in this audit report. Elements seven through nine ("corrective actions,"

"confirmation process," and "administrative controls") were audited during the scoping and screening methodology audit conducted March 11-15, 2013, and are evaluated separately.

The staff audited all AMPs that the applicant stated were consistent with the GALL Report AMPs.

During this audit, if an applicant took credit for a program in the GALL Report, the staff verified that the plant program contains all the elements of the referenced GALL Report program.

In addition, the staff verified the conditions at the plant were bounded by the conditions for which the GALL Report program was evaluated.

In performing this audit, the staff examined the applicant's LRA, program-bases documents, and related references; interviewed various applicant representatives; and conducted walkdowns of several plant areas. In total, the NRC staff reviewed 43 AMPs and conducted 42 breakout (discussion) sessions with applicant representatives. This report documents the staffs activities during this audit.

2 LRA AMP B.1.1, Aboveground Metallic Tanks Summary of Information in the Application. The LRA states that AMP B1.1, "Aboveground Metallic Tanks," is a new program 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 documents associated with 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 applicant's 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), fire water storage tank (FWST), and CO 2 central unit tank. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "coating," "damage,"

"degradation," "holiday," "tank," and "wall thick."

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

The applicant provided these documents or the staff identified them in its search of the applicant's operating experience database.

Relevant Documents Reviewed I Document Title Revision I Date

1. SQN-RPT-1 0-LRD03 Aging Management Program Evaluation Report Revision 3 Non-Class 1 Mechanical 2.1,2-17W585-3 Mechanical Drains and Embedded Piping 07/27/1995

[Installation drawing, 7 Day EDG Fuel Oil Storage Tank]

3. 1,2-17W585-1 Mechanical Drains and Embedded Piping 08/29/1995 .

[Installation drawing, 7 Day EDG Fuel Oil Storage Tank]

4. PER 82694 Coating holidays found during inspection of CST 05/16/2005 i B

5. NA Reviewed 14 pictures from internal inspections of 2005 the Condensate Storage Tanks

6. PER 16233 Threaded coupling leak Unit 1 RWST 11/03/2011

7. 1,2-47W309-5 Mechanical Large Reservoirs [RWST] Revision 0

8. 1,2-1919-204 Fire Protection Fire Water Storage Tank Revision 1

9. 110789371 Work Order -Internal Inspection A FWST 07/11/2011

10. 0-PI-FPU-026-801.H Internal Inspection A FWST 09/13/2005

11. 0-PI-FPU-026-802.H Internal Inspection of B FWST 07/26/2011

12. 112536662 Work Order - B FWST Spot Check Heater Metal 08/08/2011 Thickness Measurements

13. 2-41N 363-3 Concrete Pipe Tunnels and Tank Foundations 01/05/1983 Outline 14.1,2-941201-S1 Fire Water Storage Tank Foundation Plan Revision 0 15.10N300-1 Concrete Foundations and Trenches for 03/29/1971 Condensate Storage and Lubricating Oil Tanks 16.1,2-47W491-1 Mechanical Service Air, Water Fire Protection, Revision 2 and Primary Water Makeup

3 During the audit of program elements one through six, the staff confirmed that the "scope of program," "preventive actions," "parameters monitored or inspected," "monitoring and trending,"

and "acceptance criteria" program elements of the LRA AMP will be consistent with the corresponding elements of the GALL Report AMP. For the "detection of aging effects," program element sufficient information was not available to determine if it will be consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to confirm if this program element will be consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing a request for additional information (RAI) for the subject discussed below.

During its walkdown of the RWST, the staff noted that the tank is insulated. The GALL Report AMP recommends that periodic visual examination of the external surfaces of the tank be conducted. It is not clear to the staff if insulation will be removed to perform a visual examination of the external surfaces of the RWST and, if insulation will be removed, how much insulation will be removed, the locations of insulation to be removed, and the frequency of removal such that the external surfaces of the tank can be directly examined.

During the audit the staff noted the following:

The "preventive action" program element of AMP XI,M29 states that, "[s]ealant or caulking may be applied at the external interface between the tank and concrete or earthen foundation to mitigate corrosion of the bottom surface of the tank by minimizing the amount of water and moisture penetrating the interface, which would lead to corrosion of the bottom surface." The Program Description for LRA Section B.1.1 states,

"[i]n accordance with installation and design specifications, the tanks do not employ caulking or sealant at the concrete/tank interface." During the audit, the staff reviewed the construction drawings for the in-scope tanks. The tanks sit on concrete ring foundations, which are either sloped downward toward the exterior of the tank or a fiber cane joint filler or fiber board was installed between the tank and its foundation. The staff noted that these configurations would limit or eliminate water accumulating under the tank bottom.

During the audit of the "operating experience" program element, the staff determined that the operating experience the staff identified in an independent database search is bounded by industry operating experience (i.e., neither the applicant nor the staff identified any previously unknown aging effects). The staff also determined that the operating experience the staff identified in an 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.

In addition, the staff 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 the "scope of program," "preventive actions," "parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" program elements of the LRA AMP will be consistent with the corresponding program elements in GALL Report AMP XI.M29. The staff also identified certain aspects of the "detection of aging effects" program element of the LRA AMP for which additional information or additional evaluation is required before the NRC staff could determine consistency.

4 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.1.2, Bolting Integrity Summary of Information in the Aoolication. The LRA states that AMP B.1.2, "Bolting Integrity,"

is an existing program with enhancements that will be 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.

Audit Activities. During its audit, the NRC staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "bolt," "corrosive,"

"cracking," "degradation," "rust," "stress corrosion cracking," 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 the NRC staff identified them in its search of the applicant's operating experience database.

5 Relevant Documents Reviewed I Document Title Revision I Date

1. SQN-RPT-10-LRD03 Aging Management Program Evaluation Revision 3 Report, Non-Class 1 Mechanical

! 2. SQN-RPT-1O-LRD09 Operating Experience Review Results Revision1 Aging Management Program Effectiveness

3. 0-TI-SPT-000-301.0 ASME Section XI Pressure Testing Program Revision 0002, Basis Document 10104/2011

4. MMTP-104 Guidelines and Methodology for Assembling Revision 0005, and Tensioning Threaded Connections 06/18/2012

5. PS 4.M.4.4 ASME Section III and Non-ASME Section III Revision 5 (including AISC, ANSI/ASME B31.1, and ANSI B31.5) Bolting Material 6.PS4.M.1.1 Process Specification for Material Fabrication Revision 25, and Handling Requirements for Austenitic 06/10/2011 Stainless Steel

7. N-PT-7 Liquid Penetrant Examination of Threaded Revision 0013, Fasteners (Studs or Bolts), Two Inches and 07/31/2008 Smaller in Diameter and Other Components as Applicable Using the Fluorescent Water-Washable Method

8. N-VT-4 System Pressure Test Visual Examination Revision 0025, Procedure 03/08/2011

9. N-VT-9 Visual Examination of ASME III Bolts, Studs, Revision 0002, and Nuts 08/26/2008

10. N-UT-67 Generic Procedures for Straight Beam Revision 0004, Ultrasonic Examination of Bolts and Studs 08/11/2008

11. PER 598635 ReviewlEvaluate NRC IN 2012-15 10/9/2012

12. 0-SI-SXP-067 -202A ERCW Traveling Screen Wash Pump A-A Revision 0010, Performance Test 03/12/2012 13.0-SI-SXP-067-201J Essential Raw Cooling Water Pump J-A Revision 0018, Performance Test 07/25/2012

14. 0-SI-SXI-067-300.7 System Leakage Test of the Essential Raw Revision 0002, Cooling Water System Buried Piping 05/22/2012 The staff conducted its audit of LRA program elements one through six 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 confirm if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAI for the subjects discussed below.

• The LRA AMP program description and FSAR supplement state that periodic system walkdowns and inspections of non-ASME Code class bolting occur at least once per

6 refueling cycle. The "detection of aging effects" program element of the GALL Report AMP recommends that these periodic inspections occur for both ASME Code class bolting and non-ASME Code class bolting. It is not clear to the staff that these statements are consistent because the applicant's inspections of all Code class bolting may not be as frequent as once per refueling cycle.

• The LRA contains AMR items for submerged bolting that is managed for loss of material and loss of preload by the Bolting Integrity program. The "detection of aging effects" program element of the GALL Report AMP recommends periodic system walkdowns and inspections to detect leakage that is indicative of age-related degradation of closure bolting. It is not clear to the staff how the applicant will detect leakage from bolted connections that are submerged.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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. As discussed above, the staff was not able to verify that this description is consistent with the description provided in the SRP-LR, and the staff will consider issuing an RAI regarding the periodic walkdowns of ASME Code class bolting.

Audit Results. Based on this 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 program elements in GALL Report AMP XI.M18. The staff also identified certain aspects of the "detection of aging effects" program element of the LRA AMP for which additional information or additional evaluation is required 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, 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 B.1.3, Boric Acid Corrosion Summary of Information in the Application. The LRA states that AMP B.1.3, "Boric Acid Corrosion," is an existing program that is consistent with the program elements in GALL Report AMP XI.M1 0, "Boric Acid Corrosion." To verify this claim of consistency, the staff audited the LRAAMP.

Audit Activities. During its audit, the NRC staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "boric,"

"corrosive," "degradation," "piping," "bolt," and "wastage."

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

The applicant provided these documents or the NRC staff identified them in its search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date i 1. SQN-RPT-1 0-LRD03 Aging Management Program Evaluation Revision 3 Report, Non-Class 1 Mechanical

2. SQN-RPT-10-LRD09 Operating Experience Review Results  :~n 1 Aging Management Program Effectiveness 3.0-TI-DXX-000-097.1 Boric Acid Corrosion Control Program n 0008, 11

4. 0-PI-DXX-000-105 Boric Acid Leak Monitoring Program Revision 0000, 01/23/2009

5. NPG-SPP-09.7 Corrosion Control Program Revision 0002, 04/11/2012 6.NA Boric Acid Corrosion Control Program Health 07/01/2012 Report 12/31/2012

7. PER 153635 Scheduling review group consistently 2008 rescheduling boric acid leak work orders

8. PER 441562 Boric acid program needs better maintenance 10/03/2011 support During the audit of program elements one through six, 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 "scope of the program" program element, the staff also gathered information regarding an issue with environment definitions in the LRA, as discussed in the following.

In the LRA, the applicant defined the environment of "air-indoor" as potentially including borated water leakage. As a result, when reviewing LRA aging management review items exposed to "air-indoor," it was unclear to the staff when borated water leakage could be present and, thus, when loss of material caused by boric acid corrosion was a viable aging effect. During audit discussions, the applicant stated that it included the borated water leakage environment within the general "air-indoor" environment in the LRA because this is consistent with the treatment in EPRI 1010639, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4." The applicant also stated that the use of the Boric Acid Corrosion Program in an aging management review item in the LRA effectively defines the environment as containing borated water leakage. If the Boric Acid Corrosion Program was not used, the applicant did not consider the environment for that item to potentially contain borated water leakage.

To confirm that the applicant's program inspects all components that are potentially exposed to borated water leakage, the staff reviewed procedures 0-TI-DXX-000-097.1, "Boric Acid Corrosion Control Program," 0-PI-DXX-000-1 05, "Boric Acid Leak Monitoring Program," and NPG-SPP-09.7, "Corrosion Control Program." The staff confirmed that the applicant performs walkdowns of all components that contain borated water and visually inspects all adjacent components to ensure that leakage is detected, cleaned, and evaluated in a timely manner, consistent with GALL Report guidance.

8 During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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 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 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, 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.1.4, Buried and Underground Piping and Tanks Inspection Surnmary of Information in the Application. The LRA states that AMP B.1.4, "Buried and Underground Piping and Tanks Program," is a new program that will be consistent with the program elements in GALL Report AMP XI.M41, "Buried and Underground Piping and Tanks Program." To verify this claim of consistency, the staff audited documents associated with the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the NRC staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "buried," "coating,"

"damage," degradation," "dug," "excavation," "holiday," "perforation," "through wall,"

"underground," "wall-thick," and "wrap."

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

The applicant provided these documents or they were identified in the staff's search of the applicant's operating experience database.

9 Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD03 Aging Management Program Evaluation Revision 3 Report Non-Class 1 Mechanical 2.7A300 General Notes - Yard Piping 07/19/1978

3. NA Buried Piping Program Report 07/01/2012 thru 12/31/2012

4. 0-TI-DXX-000-9150 Buried and Underground Piping Revision 3 and Components Integrity Program I

• 5. G-9 Earth and Rock Foundations and Fills During Revision 9 Construction, Modification and Maintenance for Nuclear Plants

6. G-55 Technical and Programmatic Requirements Revision 18 for the Protective Coatings Programs for TVA Nuclear Plants

7. NPG-SPP-09.15 Underground Piping and Tanks Integrity Revision 2 Program (UPTI)

8. NA TVA- Sequoyah Nuclear Plant - Buried Piping 02/12/2010 Integrity Program Corrosion Assessment Report

9. NA Underground Piping and Tanks Integrity Revision 2 Program Inspection Plan

10. SIA Project No. jJ:eline Risk Implementation Analysis: Revision 0 0901186.00 uoyah Nuclear Power Plant

11. PER 525994 Inspection Results for Liquid Radwaste 3/23/2012 Discharge Line

12. SIA Report No. GWT/A-Scan Assessment of Various 06/10/2010 1000691.401.R0 Common and Unit 1 Above & Below Ground Piping

13. SIA Report No. GWT/UT Assessment on Radioactive Waste 11/22/2011 1101105.401 Disposal System 77 and Steam generator Blowdown, System 15

14. 1,2-17W585-1 & 3 Mechanical Drains and Embedded Pipe [7 Revision 0 Day EDG FOSTl

15. PER 452647 TBS Discharge Piping Leaking Underground 10/26/2011

[Turbine Building Sump]

16. PER 175149 Fuel Piping Failed PM [Preventive 06/27/2009 Maintenance Task]

17. PER 22693 Holes in Buried Nonsafety-related essential 06/21/2002 raw cooling water (ERCW) Used to Fill Fire Pump Forebay During Flood Event

18. PER 117288 Underground Potable Water Pipe Leak 12/23/2006

19. NA Corrpro TVA - Sequoyah Nuclear Plant 02/12/2010 Buried Piping Integrity Program Corrosion Assessment Report

20. PER 228947 Pipe Coating Damage to Four-Inch Diesel 05/10/2010 Fuel Transfer Line

10 Document Title Revision I Date

21. PER 32256 Contaminated Soil Samples West Side of Unit 04/09/2002 1 RWST

22. PER 63662 Granular Backfill for Fire Protection for Refill 06/21/2004 of Fire Protection Piping Excavation Does Not Meet Specification

23. 09-780676-002 Work Order, SPP-9.15 Buried 05/07/2010 Piping/Component Visual Inspection Form 0-YRD-722 Fuel Oil Dig, Outside DG Building

24. LRA 1,2-47W819-1 Flow Diagram Primary Water Revision 0 During the audit of program elements one through six, the staff verified that the "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements of the AMP will be consistent with the corresponding elements of the GALL Report AMP XLM41. However, the NRC issued LR-ISG-2011-03, "Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program AMP XLM41, 'Buried and Underground Piping and Tanks'," on August 2,2012. Therefore LR-ISG-2011-03, and not GALL Report AMP XLM41, represents the current staff position for age-managing buried and underground piping and tanks. During its audit, the applicant stated that the Buried and Underground Piping and Tanks Program will be consistent with LR-ISG-2011-03. To confirm this, the staff will consider issuing RAI for subjects discussed below.

• The "scope of program," "preventive actions," parameters monitored or inspected,"

"detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements state either that the program element will be consistent with the corresponding program element in NUREG-1801 or NUREG-1801 XLM41. This is consistent with LRA Section 8.1.4, which states that the Buried and Underground Piping and Tanks Program will be consistent with the program described in NUREG-1801, Section XLM41.

However, this is inconsistent with LRA Section 2.1.3, "Interim Staff Guidance Discussion," which states in relation to LR-ISG-2011-03 that, "[t]he revised guidance has been considered in the integrated plant assessment and is reflected in the aging management results presented in Section 3 and the aging management program description presented in Appendix B, Section B.1.4." Since LR-ISG-2011-03 is the currently approved guidance, the applicant's program should be compared to the ISG and not NUREG-1801. It is not clear to the staff that when the new program is developed it will be consistent with LR-/SG-2011-03.

For the "scope of program" and "preventive actions" program elements sufficient information was not available to determine if they will be consistent with the corresponding program elements of LR-ISG-2011-03. To obtain the information necessary to confirm if these program elements will be consistent with the corresponding program elements of LR-ISG-2011-03, the staff will consider issuing RAI for the subjects discussed below.

• The "scope of program" program element states that the scope of the program will be consistent with GALL Report AMP XI.M41. LR-ISG-2011-03 defines "buried" as tanks in direct contact with soil or concrete; however, LRA Table 3.3.2-1, "Fuel Oil System,"

states that steel tanks exposed to concrete have no aging effects requiring management and no recommended AMP. LRA Table 3.3.2-1 cites SRP-LR item 3.3.1-112. SRP-LR

11 Table 3.4-1, item 3.4.1-47 states that steel tanks exposed to concrete or soil should be managed for loss of material by GALL Report AMP XI. M41, "Buried and Underground Piping and Tanks." It is the staffs intent that to be consistent with the LR-ISG-2011-03, tanks buried in concrete are managed by LR-ISG-2011-03 and item 3.4.1-47 be cited instead of 3.3.1-112. The ambiguity between the two items occurred because during the development of GALL Report Revision 2, item 3.3.1-112 was not changed to be consistent with the newly developed AMP XI.M41.

• The "preventive actions" program element states that preventive actions will be consistent with GALL Report AMP XI.M41. LR-ISG-2011-03 recommends that backfill in the vicinity of buried steel pipe meet ASTM D448-08, size 67. In addition, it is recommended that coatings meet the Table 1 of NACE SP0169-2007 or use of other coatings is justified in the LRA. During the audit, the staff noted the following:

o Section 4.7.5 of procedure G9, "Earth and Rock Foundations and Fills During Construction, Modification and Maintenance for Nuclear Plants," in relation to Category I backfill states, "[u]nless otherwise specified by engineering documents, earthfill, fine granular fill, coarse granular fill, and rockfill may be used as Category I fill, and the particular type suited for the conditions shall be specified in engineering documents." Section 3.1.1 of G-9 states that Category I backfill is associated with systems that are designed to remain functional during and following a safe shutdown earthquake. Earthfill is, in part, defined as possibly containing organic material. Rockfill has no size limit except for the longest dimension must be less than three times the thickness. It is not clear that earthfill (due to the potential presence of organic materials) and rockfill (due to its size) are consistent with the backfill recommendations of LR-ISG-2011-03, or if either of these types of backfill was used in the vicinity of inscope components.

o Problem Evaluation Report (PER) 63662 stated that the granular backfill for the refill of a fire protection piping excavation did not meet specifications for the number 16 and 30 sieve requirements. The initiator requested that the engineering organization accept the back fill as-is. It is not clear how the backfill quality compared to that recommended in LR-ISG-2011-03 and if the backfill was subsequently used as backfill in the vicinity of inscope piping.

o PER 525994 stated that coating damage occurred to buried radioactive waste piping because of fretting from a copper grounding wire. This piping is not in scope; however, it is not clear if the procedure controls for backfill in the vicinity of this piping are the same as for those of inscope piping, and if this is the case, if the condition was an isolated event.

o PER 22693 stated that damage occurred to buried nonsafety-related essential raw water cooling piping that is used to fill the safety-related fire pump forebay during a flooding event. During the audit, the applicant stated that this piping is in scope because the pumps are used to fill the steam generators and reactor coolant system during a flood event. The PER further stated that the damage occurred because the piping is not coated. It is not clear how much in-scope buried piping is not coated or how the program, when implemented, will account for noncoated buried piping.

12

• LRA Section B.1.4 states, "If cathodic protection is not provided prior to the period of extended operation, the program will include documented justification that cathodic protection is not warranted." LR-ISG-2011-03 states that the justification for not having cathodic protection must be provided with the LRA. During the audit, the staff reviewed a Corrpro Report titled, "TVA - Sequoyah Nuclear Plant - Buried Piping Integrity Program Corrosion Assessment Report." This report cited several examples demonstrating that the soil at Sequoyah is corrosive and recommended installation of cathodic protection in some locations within-scope piping. The applicant stated a new study was recently completed by a different vendor. The applicant did not make this recently completed study available during the audit; therefore, the staff will issue an RAI regarding the results of this study.

During the audit the staff noted the following:

The program description of LR-ISG-2011-03 states that underground components are contained within a tunnel or vault such that they are in contact with air and are located where access for inspections is restricted. During the audit the staff interviewed the applicant's staff members. The staff confirmed that the pipe tunnels shown on drawing LRA-1,2-47W819-1 in drawing locations B5 and H5 are readily accessible to station personnel.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is sufficient to allow the staff to verify, subject to resolution of the above described RAI, 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 if 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; however, the details related to the additional information required review the FSAR supplement will be included in the above RAI related to cathodic protection.

• LRA Section A.1.4 states, "[c]athodic protection is not installed. If cathodic protection is not provided prior to the period of extended operation, the program will include documented justification that cathodic protection is not warranted." This is not consistent with LR-ISG-2011-03, which states that, "[f]ailure to provide cathodic protection in accordance with Table 2a must be justified in the LRA." Sufficient details to justify not having cathodic protection installed during the period of extended operation were not provided in the LRA or during the audit.

Audit Results. Based on this audit, the staff identified certain aspects of 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 for which additional information or additional evaluation is required before consistency can be determined.

13 Based on this audit, the staff also verified that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the FSAR supplement.

LRA AMP B.1.5, Compressed Air Monitoring Summary of Information in the Application. The LRA states that AMP XI.M24, "Comrpessed Air Monitoring," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M24, "Compressed Air Monitoring." To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "instrumental air," "stress corrosion cracking," and "dew point." In addition, the staff reviewed all issue reports from the past five years associated with the two in-scope compressed air systems, systems 032 and 033.

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD03 Aging Management Evaluation Report Non- Revision 3 Class 1 Mechanical

2. Updated Final Safety Updated Final Safety Analysis Report Amendment 23 Analysis Report

3. ASME OM-SH-1998 PART 17- Performance Testing of Instrument 02/12/1999 Air Systems in Light-Water Reactor Power Plants

4. INPO SOER 88-01 Instrument Air Svstem Failures 06/03/1988

5. ANSIIISA-7.0.01 Quality Standard for Instrument Air 11/12/1996

6. 0-PI-CEM-032-001.0 Turbine Building Control Air Quality Test Revision 0009 I 08/26/2010

7. 0-PI-CEM-032-002.0 Auxiliary Building Control Air Quality Test Revision 0008 08/27/2010

8. Condition Report Summary of Corrective Action 02/25/2012 506039 The staff conducted its audit of LRA program elements one through six 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

14 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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.

In addition, the staff 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 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 program elemen~s in GALL Report AMP XI.M24.

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 B.1.6, Containment Inservice Inspection -IWE Summary of Information in the Application. The LRA states that AMP B.1.6, "Containment Inservice Inspection - IWE," is an existing program that is consistent with the program elements in GALL Report AMP XI.S1, "ASME Section XI, Subsection IWE." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified, but not resolved, in this report will be addressed in the SER.

Audit Activities. During its audit, the NRC staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff reviewed photographs of the Sequoyah Nuclear Power Plant (SON), Units 1 and 2. steel containments since both units of the plant were in operation and a walkdown to observe the condition of the steel containments was not possible. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "containment," "IWE," and "liner plate corrosion."

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

The applicant provided these documents or the staff identified them in its search of the applicant's operating experience database.

15 Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-1 0-LRD05 SQN Licensee Renewal Project, Aging Revision 1 Management Program Evaluation Report Civil/Structural (Basis Document)

2. SQN-RPT-1 0-LRD09 Sequoyah License Renewal Project, Operating Revision 1 Experience Review Results - Aging Management Program Effectiveness

3. N-VT-15 Visual Examination of Class MC and Metallic Revision 10 Liners of Class CC Components of Light water

4. N-VT-16 General Visual Examination, Containment I Revision 4 Vessel Integrity

5. 0-PI-DXI-000-116-2 ASME Section XI IWEIIWL Containment Revision 004 Inservice Inspection (CISI) Program

6. DCN 23160 Modification to Unit 2 Steel Containment Vessel Rev. A (SCV) Pressure Test Tubing

7. Notification of Indication Form for Unit IIWE 06/17/2009 Program. Unit 1 Containment Vessel inspection During the audit of program elements one through six, 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 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 confirm if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAI for the subject discussed below.

• The "scope of program," element of the GALL Report AMP recommends the examination of steel containment (Class MC) pressure-retaining components and their integral attachments, metallic shell; steel penetration liners for concrete containments (Class CC) and their integral attachments; containment hatches and airlocks; containment moisture barriers, containment pressure-retaining bolting, and metal containment surface areas, including welds and base metal, per 10 CFR 50.55a imposed inservice inspection (lSI) requirements of the ASME Code,Section XI, Subsection IWE. During steam generator replacements (SGR) for SQN Units 1 and 2 in 2004 and 2012 respectively, the steel containment domes were cut and full penetration welds were added. The LRA section B.1.6, "Containment Inservice Inspection - IWE,"

states that in 2011, the program was revised to change the scope of examinations performed on the containment vessel dome cut welds, based on operating experience.

However, it is not clear that the change in the "scope of program," program element is consistent with the requirements of IWE-2412 for welds added during an inspection interval. Therefore, the staff may issue an RAI requesting the applicant to provide details of the change in-scope of examinations performed on the containment vessel dome cut welds and describe how it meets the requirements of IWE-2412.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (Le., no previously unknown

16 aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subject discussed below.

• During the audit the staff reviewed the applicant's operating experience database and noted a design change notice (DCN) that permanently sealed the pressure test piping with a steel plate after removing a portion of the corroded piping. The carbon steel pressure test piping was designed to facilitate testing the base slab full penetration liner welds through an embedded leak chase channel system. It is not clear how this change will prevent further corrosion of the pressure test piping, containment liner plate, including the full penetration welds in the base slab, and associated embedded leak chase channels. Therefore, the staff may issue an RAI requesting the applicant to describe the details what steps it has taken and will continue to do so to prevent further deterioration of the pipe and leak chase channel assembly.

• During the audit, the staff also reviewed photographs that show evidence of corrosion in the steel containment shell at the moisture barrier due to water leakage. The moisture barrier had been found to be degraded in certain areas. The water may have also leaked beyond the degraded moisture barrier into the inaccessible area of steel containment that is embedded in the concrete resulting in corrosion of the steel plate.

This situation has also been observed at other nuclear power plants. Therefore, the staff may issue an RAI requesting the applicant to describe plans for examination of the steel containment below the moisture barrier from the annulus area and exposure of a portion of the embedded liner plate and rebars in concrete to determine the presence and extent of corrosion.

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 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 program elements in GALL Report AMP XI.S1. The staff also identified certain aspects of the "scope of program," program element of the LRA AMP 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 regarding 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 8.1.7, Containment Leak Rate Summary of Information in the Application. The LRA states that AMP B.1.7, "Containment Leak Rate Program," 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

17 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 applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "LLRT," "ILRT," and "containment leakage."

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title i Revision I Date

1. SON-RPT-10-LRD05 SON Licensee Renewal Project, Aging Revision 1 Management Program Evaluation Report Civil/Structural (Basis Document)

2. 1-SI-SLT-088-156.0 Containment Integrated Leak Rate Test Revision 5

3. SON-RPT-10-LRD09 Operating Experience Review Report - Aging Revision 1 Management Program Effectiveness

4. DCN 23160 Modification to Unit 2 Steel Containment Rev. A Vessel (SCV) Pressure Test Tubing During the audit of program elements one through six, the staff verified that the "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 "scope of program," 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 confirm if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAI for the subjects discussed below.

The LRA AMP Containment Leak Rate Program in its "scope of program," program element recommends the inclusion of all pressure boundary retaining components. The AMP consists of tests performed in accordance with the regulations and guidance provided in 10 CFR Part 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," Option B. The LRA also states that Sequoyah Nuclear Plant (SON) through the Containment Leak Rate Program detects degradation of the containment shell and liner and components that may compromise the containment pressure boundary. However, SON Units 1 and 2 FSAR and Supplement 1 of the original SER, indicate that a number of penetrations and valves are excluded from local leak rate tests (LLRTs). It is not clear how the applicant will manage the aging effects for components that are not included in "its scope of program," program element. Therefore, the staff plans to issue an RAI requesting the applicant to clarify for those components (valves, penetrations, and other components) that have been excluded from the Containment Leak Rate program, how aging effects will be managed during the period of extended operation and indicate which AMPs and/or AMR line items will be used to manage these aging effects for each of the exempted/excluded

18 components, or justify why an AMP and/or AMR line item will not be necessary for the period of extended operation.

The LRA AMP Containment Leak Rate in its "parameters monitored or inspected," program element states that parameters to be monitored include leakage rates through the containment shell, liner, and associated welds. The AMP also states that the applicant has implemented Option B for the 10 CFR Part 50 Appendix J for leak rate testing (LRTs) and detects degradation of the containment shell, liner, and components that may compromise the containment pressure boundary. However, during the audit the staff noted that the applicant has issued a design change notice (DCN) 23160 that allows permanent sealing of the pressure test piping that is connected to leak chase channels embedded in the concrete base slab.

These leak chase channels were originally provided to test the leak tightness of the containment base slab liner plate full penetration welds. It is not clear how the applicant plans to monitor leakage rate through containment base slab liner plate and associated welds during the future ILRTs as recommended in GALL Report AMP, "10 CFR 50, Appendix J," with the pressure test piping, that is connected to the leak chase channels embedded in the concrete base slab, permanently sealed. Therefore, the staff plans to issue an RAI requesting the applicant to describe how the GALL Report AMP, "10 CFR 50, Appendix J" recommendations will be met or to justify alternatives to the leak rate tests to assure the integrity of containment base slab liner plate welds is maintained during the period of extended operation.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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 the "preventive actions," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S4.

The staff also identified certain aspects of the "scope of program," and "parameters monitored or inspected," program elements of the LRA AMP for which additional information or additional 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, 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 8.1.8, Diesel Fuel Monitoring Summary of Information in the Application. The LRA states that AMP B.1.8, "Diesel Fuel Monitoring," 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. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL

19 Report AMP; however, it does not consider the sufficiency of enhancements that are not necessary for consistency, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the diesel fuel oil storage tanks in-scope of the program. The staff also conducted an independent search of the applicant's operating experience database using keywords: "tank," "pitting," and "fuel oiL" The table below lists the documents the staff reviewed and found to be relevant to the audit.

The applicant provided these documents or they were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I I Date

1. SQN-RPT-10-LRD03 Diesel Fuel Monitoring Revision 3 2.0-SI-CEM-018-116.0 Periodic Chemistry Requirements For High 10/25/2012 Pressure Fire Protection Diesel Pump Fuel Oil Storage Tank 3.0-SI-CEM-018-116.1 Monthly Chemistry Requirements For Diesel Revision 0004 Generator 7-Day Fuel Oil Tanks and Fuel Oil 12/16/2010 Storage Tanks

4. 0-SI-CEM-018-294.0 Detection and Removal of Accumulated Revision 0007 Water in Diesel Engine Fuel Tanks 01/28/2011

5. 0-SI-CEM-018-295.0 Qualification of Diesel Fuel Revision 0015 06/11/2011 6.0-SI-MIN-018-102.0 Cleaning of the 7-Day Diesel Fuel Oil Revision 0002 Storage Tanks 05/10/2012

7. NPG-SPP-03.1 Corrective Action Program Revision 0005 10/17/2012

8. WO# 01-00892-000 Corrosion Pitting found in Both the 2A-A and 2B-B Diesel Generator 7 Day Tanks The staff conducted its audit of LRA program elements one through six 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 that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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.

20 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 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 program elements in GALL Report AMP XI.M30. The staff's evaluation of aspects of the program elements associated with enhancements that 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, 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.1.9, Environmental Qualification (EQ) of Electric Components Summary of Information in the Application. The LRA states that AMP B.1.19, "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 applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "EQ cable calculation," "EQ cable," and "EQ 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 staff's search of the applicant's operating experience database.

21 Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD04 B.1.9 Environmental Qualification (EQ) of Revision 1 Electric Components program

.2. EQ Health Reports 01/1/2009 12/31/2012 I 3. PER 234041 Equipment Qualification (EQ) Procedure 08/10/2010 Violation i 4. PER 293937 Engineering received 17 out of 21 EQIRs past 02/02/2011 i its due date

5. SQN-RPT-10-AME01 Aging Management Review Electrical Systems Revision 0, 05/15/2012

6. SQN-DC-V-21.0 Environmental Design Revision 22

7. SQN-SQS2-0205 Evaluation of the Effect on Equipment Qualified Revision 0, Life Due to Environmental Temperatures in 01/08/1999 Excess of their Maximum Normal Limits

8. DCN 20638A Provide the Required Analysis, Evaluation, 01123/2001 Testing, and FSARITS Change Package Necessary to Utilize the LEFM Check System in Achieving a 1.3% Power U~-Rate.

During the audit of program elements one through six, 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (I.e., no previously unknown aging effects were identi'fied by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subject discussed below.

The staff is concerned that LRA EQ AMP B.1.9, when implemented by the applicant, may not meet corrective action criteria in the GALL Report with two indicators in the EQ program health report (3 & 6E) designated as yellow for 3 years.

o 3 - Identified that the qualified permanent backup engineer position has been vacant since October 2010.

o 6E - Identified that no permanent maintenance EQ coordinator is available at Sequoyah, which resulted in two instances of site EQ procedure violations.

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.

22 Audit Results. Based on this 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 program elements in GALL Report AMP X.E1.

Based on this audit, the staff also identified that additional information regarding operating experience may be required before a determination can be made regarding the sufficiency of the LRA AMP, when implemented by the applicant, 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.1.1 0, External Surfaces Monitoring Summary of Information in the Application. The LRA states that AMP B.1.1 0, "External Surfaces Monitoring," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M36, "External Surfaces Monitoring of Mechanical Components." 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.

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

23 Relevant Documents Reviewed I Document Title Revision I Date

1. SQN-RPT-10-LRD03 Aging Management Program Evaluation Revision 3 Report Non-Class 1 Mechanical

2. SQN-RPT-10-LRD09 Operating Experience Review Report- Aging Revision 1 Management Program Effectiveness

13. O-PI-DXX-OOO-7S0 Piping Inspection in Tunnels and Infrequency Revision Accessed Areas 0000, 06/14/2010

• 4. PER 25716 External Leakage Inspection inside the 12/03/2003 Letdown HX Room

5. WO 02-013738-000

Subject:

A thru wall leak discovered on the 10/31/2002 RCW seal water line to the vacuum priming pumps. Corrosion of carbon steel pipe in Raw water system. Extensive corrosion damage led to the leak in the piping.

6. WO 03-008128

Subject:

While performing a program 2003 walkdown, white crusty deposits were noted on piping

7. PER 66768

Subject:

General corrosion walkdown of 2004 ERCW pumping station located areas of galvanic corrosion on drain valve, inline valve and chemical injection points

8. PER 207413

Subject:

QA observation of work in the 2009 auxiliary building observed extensive external corrosion on the inlet and discharge side of both 2A and 28 Incore instrument room chiller pump piping The staff conducted its audit o*f LRA program elements one through six 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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.

24 Audit Results. Based on this 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 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, 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 B.1.11, Fatigue Monitoring Summary of Information in the Application. The LRA states that AMP B.1.11, "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, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "cyclic," "cracking," "fatigue,"

and "cycle."

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 staff's search of the applicant's operating experience database.

25 Relevant Documents Reviewed i

Document Title Revision I Date

1. SQN-RPT-10-LRD02 Sequoyah LRP AMP Evaluation Report Revision 3, Class 1 Mechanical pp.35-42

2. SQN-RPT-10-LRD09 Sequoyah LRP OE Review Results - AMP Revision 1, Effectiveness pp.34-37 I 3. 0-SI-NXX-000-009.0 Monitoring Component Cyclic or Transient Revision 21 Limits i 4. 0-SI-SXX-068-127.0 RCS and Pressurizer Temperature and Revision 11 I Pressure Limits 5.0-TI-DXX-000-012.R Pressurizer Lower Head and Surge Line Revision 1 Fatigue Usage

~O.273850 Fatigue Pro Update Scheduling 10/25/2010 Discrepancy & Cals Not Vaulted 0.276091 I Cals not vaulted as QA Records 10/29/2010 0.275297 Data Errors in performance of O-SI-NXX 10/28/2010 000-009.0 R19 (QAAudit SSA1011)

9. PER No. 275302 Data Errors in performance of O-SI-SXX 10/28/2010 068-127.0 (QA Audit SSA1011)

10. CDQOO052920050005 Calculation for Pressurizer Spray Nozzle 03/28/2007 Partial Cycle Counting for Fatigue Usage

11. NPG-SPP-09.3.1 Guidelines for Preparation of Design Revision 2, Inputs and Change Impact Screen I pg. 28

12. 0-SI-NXX-000-009.0 STS Monitoring Component Cyclic or Transient 01/2006 to Limits Surveillance Task Sheets, Unit 2 01/2007

13. SQA0603 Nuclear Assurance - Engineering 12/08/2006 Functional Area Audit - Audit Report No. SQA-0603

14. SSA0807 TVA Nuclear Assurance - Systems 12/11/2008 Engineering Functional Area Audit - SSA 0807 The staff conducted its audit of LRA program elements one through six 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," "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 "scope of program," 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 confirm if this program element is consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAI for the subjects discussed below.

o The "scope of program" program element of GALL Report AMP X.M1, "Fatigue Monitoring," states that the program monitors and tracks the number of critical thermal and pressure transients for the components that have been identified to have a fatigue TLAA. The staff noted that FSAR Table 5.2.1-1 includes 18,300 cycles of "Loading and unloading power changes per unit at 5% per minute" and 2000 cycles of "Step load

26 increase and decrease of 10% per unit." LRA Section 4.3.1.6 includes 15 cycles of design tensioning cycle limit for RCP hydraulic studs/nuts. LRA Section 4.3.2.3 identifies five additional transients for the fatigue calculations for CVCS Regenerative Heat Exchangers. These transients were not included in LRA Tables 4.3-1 and 4.3-2 and it is not clear to the staff if these transients are monitored by the Fatigue Monitoring program.

o The applicant enhanced the "scope of program" program element of the LRA AMP and the enhancement states that U[f]atigue usage factors for the RCS limiting components will be determined to address the Cold Overpressure Mitigation System (COMS) event (Le., low temperature overpressurization event) and the effects of the structural weld overlays." From the program-bases documents, it is not clear to the staff what the effects of the structural weld overlays for those fatigue usage factors are and how the Fatigue Monitoring program would change to address the effects.

During the audit of the "operating experience" program element, the staff noted that the operating experience that the applicant provided-and that the staff identified in an independent database search-is representative of industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff).

The staff also audited the description of the LRA AMP provided in the 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 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 program elements in GALL Report AMP X. M1. The staff also identified certain aspects of the "scope of program," program element of the LRA AMP for which additional information or additional 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, 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.1.12, Fire Protection Summary of Information in the Application. The LRA states that AMP B.1.12, "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. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "C0 2," "fire door," and "fire barrier."

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 staff's search of the applicant's operating experience database.

27 Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD03 Aging Management Program Report Non-Class 1 I Revision 3 Mechanical

2. SQN-RPT-10-LRD09 Operating Experience Review Results - Aging Revision 1 Management Program Effectiveness

3. SQN-RPT-10-AMC04 Aging Management Review of Bulk Commodities Revision 2 11/29/2012

4. 0-PI-FPU-000-001.M Fire Protection Engineer Monthly Inspection Revision 0006

5. 0-PI-FPU-302-1 00.0 Visual Inspection of Electrical Cable Tray Splice Rev. 0004 Boxes - Fire Stops 6.0-PI-FPU-410-701.Q Inspection of Fire Doors Rev. 0006

7. 0-SI-EFT-039-237.0 Diesel Generator Building CO2 Fire Protection Rev. 0023 System Test (System 39) i 8. 0-SI-FPU-302-001.R Fire Barrier Visual Inspection - Auxiliary Building Rev. 0011 Elevation 690 and Below

9. 0-SI-FPU-302-004.R Fire Barrier Visual Inspection - Diesel Generator Rev. 0005 Building and ERCW Pump Station

10. 0-SI-FPU-302-005.R Fire Barrier Visual Inspection - ERCW Manholes Rev. 0004 and Hand holes

11. 0-SI-FPU-302-007.R Visual Inspection of Electrical Raceway Fire Rev. 0011 Barrier Systems 12.0-SI-FPU-410-002.R Inspection of Reactor Building Airlocks and Blast Rev. 0004 Doors, Unit 2 Radiant Energy Shield and Unit Accumulator Room Floor

13. 0-SI-FPU-41 0-703.0 Inspection of FPR Required Doors Rev. 0005

14. 1-SI-FPU-302-001.R Fire Barrier Visual Inspection - Unit1 Reactor Rev. 0004 Building Shield Wall

15. 2-SI-FPU-302-001.R I Fire Barrier Visual Inspection - Unit 2 Reactor Rev. 0006 Building Shield Wall

16. FPDP-1 Conduct of Fire Protection Rev.0002

17. NPG-SPP-03.1 Corrective Action Program Rev. 0005

18.51-237.1 Powerhouse CO 2 Fire Protection System Test Rev. 0035 (System 39)

19. SOD N2-302-400 Penetration Seal Engineering Report Revision 25 The staff conducted ifs audit of LRA program elements one through six 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.

28 During the audit and breakout session for the Fire Protection program AMP, the staff made the following observations, or identified issues for which it needed confirmation of its understanding.

These observations and issues and the applicant's confirmation are described below.

1. Parameters Monitored/Inspected The GALL Report recommends visual inspection of at least 10 percent of each type of penetration seal performed during walkdowns. Part 2 of the Sequoyah Nuclear Plant Fire Protection Report, Section 14.6, "Fire Barrier Penetrations," which contains the limiting condition for operation (LCD), states that SQN performs visual inspections of all fire barrier penetrations in fire zone boundaries protecting safety-related areas at least once per 18 months.

All of the referenced procedures for visual inspection of fire barrier penetrations appear to have acceptance criteria for the seals (e.g., no holes, cracks, or gaps that can be observed to extend through the barrier or seal; seal material is of adequate depth).

The staff confirmed that when fire barriers are inspected that the visual inspection includes an inspection of the seal. During the breakout session, the applicant stated that the inspection requires a visual inspection of the north, east, south, and west walls and the floor and ceiling, which includes any penetrations and seals.

2. Detection of Aging Effects The GALL Report recommends that if any sign of degradation is detected in the seal sample inspection, the scope of inspection is expanded to include additional seals.

However, the Sequoyah Nuclear Plant Fire Protection Report states that the licensee visually inspects all barriers (fire barrier penetrations in fire zone boundaries protecting safety-related areas, which includes the seals - see above), so no expansion of inspection scope is possible.

The procedures for fire barrier inspections state that if the barrier does not meet the acceptance criteria, then the inspector obtains a Fire Protection Impairment Permit.

Once the barrier has been restored, it is inspected under the requirements of the maintenance rule.

In the LRA, the applicant stated that it is consistent with the GALL Report because it will inspect not less than ten percent of each type of penetration seal at least once per refueling cycle, and if any signs of degradation are detected within the sample, the scope of the inspection is expanded to include additional seals.

The staff notes that visual inspection of the fire barrier, as described in the Sequoyah Nuclear Plant Fire Protection Report and in the procedures, is to determine functionality.

The recommendation in the GALL Report is related to detection of age-related degradation and is not for determination of functionality. To be consistent with the GALL Report for age-related degradation management, at least 10-percent of the seals have to be visually inspected.

The applicant is consistent with the GALL Report recommendations for the inspection of seals for the purpose of management of age-related degradation.

29

3. Visual Inspections The GALL Report recommends that "visual inspections of the halon/C0 2 fire suppression system are performed to detect any sign of corrosion." During a walkdown of aboveground tanks, the staff noted that the CO 2 tank is insulated. The Sequoyah surveillance instruction says to examine "exposed" portions of the CO2 storage tank, storage tank mountings, and CO 2 piping for deterioration and damage such as rust, loose bolts, stress cracking, or any other condition potentially affecting system operation.

Since the tank is insulated, the staff asked the applicant how much of the CO2 tank is "exposed" for visual inspection. The applicant stated that there are no exposed portions of the CO 2 tank for visual inspection.

The staff noted that the Sequoyah Nuclear Plant Fire Protection Report currently requires that the function of the CO2 system be demonstrated operable at least once per 31 days by verifying correct valve position, and at least once every 7 days by verifying CO 2 level (greater than 50% and greater than 270 psig), and at least once per 18 months by verifying valves and dampers actuate (manually or automatically), and flow from each nozzle during a "puff test."

Since a visual inspection of the tank is not possible without removing the permanent insulation, the staff asked if there is a low level alarm or low pressure alarm that is alarmed in the control room.

The applicant stated that it has a tank low level alarm that is alarmed in the control room so it would be aware if there is a CO2 leak. The FP engineer also stated that the only leaks that the system has experienced were associated with the valves, and those were replaced, and since then, it has not experienced any issues with leaks. The staff verified this through a search of the OE.

The AMC04 implies that the only type of "seal" material (other than metal or concrete) that exists is "elastomers," which include: rubber, neoprene, silicone, fluoroelastomer, ethylene propylene rubber (EPR), urethane, and ethylene propylene dienyl monomer (EPDM). Since the applicant claims that it is consistent with the GALL Report, then at least 10 percent of each type of seal should be visually inspected.

4. Seal Materials During the breakout, the staff asked if "elastomers" are the only type of material used for seals.

The applicant stated that it has many different seal configurations and each one is qualified for use in the plant as a "fire rated barrier." The applicant provided Section 5.3 of SDD N2-302-400, which provides details for each fire rated typical seal.

The staff reviewed Section 5.3 of SDD N2-302-400, and noted that the following materials can currently be used in fire rated penetrations:

ASTM A36 steel plate Dow Corning 3-6548 silicone foam aluminum-silica blanket Dow-Corning Sylgard-170 silicone elastomer Arion (KCF) grade 56493F031 fabric (or engineering approved equivalent) (single boot)

30 Promaflex sealant 2-inch (min) depth GE RTV 102 (or equivalent) caulk Dow-Corning 96-081 adhesive/sealant Carborundum Fibersil cloth 36-400U calcium silicate coated with Vimasco-760 G.E. Versilube G-351 ceramic blanket material Bellows-type boot material single layer KCF Grade 56493F031 silicone impregnated fiberglass fabric Owens-Corning 700 series fiberglass board with asphalt-saturated kraft paper single layer bond-breaker tape RTV caulk 3M CP-25WB caulk (or engineering approved equivalent) cork joint fill material Cerablanket or Cerafiber Dow-Corning 3-6648 silicone foam Chico "A" compound During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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 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 program elements in GALL Report AMP XI.M26.

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 B.1.13, Fire Water System Summary of Information in the Application. The LRA states that AMP B.1.13, "Fire Water System," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M27, "Fire Water System." To verify this claim of consistency, the staff audited the LRA AMP. 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.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the high pressure fire protection pump house and the fire water storage tanks. The staff also

31 conducted an independent search of the applicant's operating experience database using keywords: "biofoul," "clog," "damage," "degradation," "fouling," "perforation," "through wall," and "sprinkler." 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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD03 Aging Management Program Evaluation Report Revision 3 Non-Class 1 Mechanical 2.NA Sequoyah Nuclear Plant Fire Protection Report Revision 31

3. FPDP-1 Conduct of Fire Protection 03/11/2011

4. 0-SO-26-1 System Operating Instruction - High Pressure Revision Fire Protection (HPFP) 60

5. 0-AR-M-29 Fire Detection System Annunciator Response Revision 9 6.0-PI-FPU-026-122.Y HPFP Yard Flow Test Results [Two Test Results] 08/04/2008 09/19/2011 7.0-PI-FPU-026-198.H Periodic Hose Station Flow Verification of High 10101/2012 Pressure Fire Protection System Test Results

8. 0-SI-FPU-026-002. Y Auxiliary and Diesel Generator Building System 07/29/2004 26 Flow Test Results [Two Test Results] 03/18/2011 9.0-SI-FPU-026-181.0 Fire Hose Hydrostatic Test - Annual Revision 5 10.0-SI-FPU-026-181.F Fire Hose Hydrostatic Test - Triennial Revision 8

11. 0-SI-FPU-026-181-H Fire Hose Hydrostatic Test Revision 10

! 12. 0-SI-FPU-026-190.Q Accessible Fire Hose Station Visual Inspection 03/04/2012 Test Results i 13. 0-SI-FPU-026-191.0 Fire Hose Station Inspection Revision 8 14.0-SI-FPU-026-197.F Periodic Hose Station Flow Verification Revision 4 of High-Pressure Fire Protection System

15. 0-SI-FPU-026-241. R Visual Inspection of the Fire Protection Sprinkler 01/25/2012 Systems in the Auxiliary Building Test Results 16.0-SI-FPU-026-199.H ERCW Hose Station Flow Verification Results 01/26/2009

[Two Test Results] 01/22/2012 17.1-SI-FPU-026-191.R Fire Hose Station Inspection Revision 6 18.1-SI-FPU-026-241.1 Visual inspection of the Fire Protection Sprinkler Revision 4 Systems in Unit 1 Inaccessible Areas

19. PER 26625 Repair Leak in HPFP Piping Header 09/05/2003

20. PER 295020 Sprinkler Piping Flow Blockage 12/09/2010

21. PER 690236 Jockey Pump Running Continuously 03/13/2013 The staff conducted its audit of LRA program elements one through six 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,

32 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 confirm if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAI for the subjects discussed below.

• The program description of the LRA AMP states that the fire water system manages loss of material and fouling for fire protection components that are tested in accordance with the Fire Protection Report. During its review of the FSAR, the staff noted that the two safety-related standby fire/flood mode pumps are used to provide makeup to the steam generators and reactor coolant system during a flooding event. Based on the staff's review of LRA Sections 2.3.3.2,3.3,3.4, and LRA Drawing 1,2-47W850-24, "Mechanical Flow Diagram Fire protection," it appears that the suction and discharge piping of these pumps, are being age-managed by the Fire Water System program. GALL Report Item VIII.G.SP-136 recommends GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," to age-managed steel piping exposed to raw water. GALL Report Table VII. E1, "Chemical Volume and Control System (PWR)," does not include steel piping exposed to a raw water environment. It is not clear to the staff that given the scope of inspections recommended in GALL Report AMP XI.M27, that the Fire Water System program is appropriate to manage the portion of a system whose intended functions as described in 10 CFR 54.4 are to support auxiliary feedwater and reactor coolant system make-up.

• Enhancement No.4, associated with the "detection of aging effects" program element of the LRA AMP states, "[r]evise Fire Water System Program procedures to consider implementing the flow testing requirements of NFPA 25 or justify why the flow testing requirements of NFPA should not be implemented." The GALL Report AMP recommends that system flow testing be used to ensure that corrosion and biofouling are not occurring and that the system's intended function is maintained. The staff cannot complete its evaluation of the program until it understands the basis for not including flow testing, or flow testing is included in the program.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

During the audit, the staff reviewed Problem Evaluation Report (PER) 690236, which stated that the fire jockey pump is running continuously. During the audit, the applicant stated that the nominal flowrate of the fire jockey pump is 50 gallons per minute (gpm) and, in the early 2000s, leakqge was identified as 13-18 gpm. The degraded performance of the system is inconsistent with the "detection of aging effects" program element of GALL Report AMP XI.M27, which states that, "[c]ontinuous system pressure monitoring, system flow testing, and wall thickness evaluations of piping are effective means to ensure that corrosion and biofouling are not occurring and that the system's

33 intended function is maintained." The degraded performance is also inconsistent with the "parameters monitored/inspected" program element, which states, "[t]he parameters monitored are the system's ability to maintain pressure." In addition, the GALL Report AMP XI.M27 program description states, "these systems are normally maintained at required operating pressure and monitored such that loss of system pressure is immediately detected and corrective actions initiated." Jockey pump run times cannot be used to monitor for further system degradation because it is running continuously. It is not clear to the staff how the Fire Water System program will be adjusted during the period of extended operation if the jockey pump is running continuously.

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 the "preventive actions," "parameters monitored or inspected," "monitoring and trending," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding program element(s) in GALL Report AMP XI.M27. The staff also identified certain aspects of the "scope of program" and "detection of aging effects" program elements of the LRA AMP 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 regarding 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 8.1.14, Flow-Accelerated Corrosion Summarv of Information in the Application. The LRA states that AMP B.1.14, "Flow-Accelerated Corrosion," is an existing program with an enhancement that will be consistent with the program elements in GALL Report AMP XI.M17, "Flow-Accelerated Corrosion." The enhancement consists of revising program procedures to examine components upstream of piping surfaces where significant wear is detected, in accordance with industry guidance. 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 applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "cavitation," "erosion," "flow accel," "impingement," "min wall," "through wall," and "wall thick."

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 staff's search of the applicant's operating experience database.

34 Relevant Documents Reviewed Document Title Revision I I Date

1. SQN-RPT-1 0-LRD-03 Aging Management Program Evaluation Revision 3 Report Non-Class I Mechanical,Section I

4.8 Flow-Accelerated Corrosion

2. SQN RPT-10-LRD08 Operating Experience Review Report Revision 0 Aging Effects Requiring Management

3. SQN RPT-10-LRD-09 Operating Experience Review Results Revision 1 Aging Management Program Effectiveness, Section 3.1.12 FAC Program

.4.0-TI-DXX-000-0001.0 Flow-Accelerated Corrosion Program Revision 7, 15.0-TI-DXX-000-0016.0 Erosive Wear Degradation Monitoring Revision 0 Program

6. DS-M4.2.1 Flow-Accelerated Corrosion Program Revision 7 Methods

7. NPG-SPP-09.7 Corrosion Control Program Revision 2

8. TVASEQ002-SQN-FAC-001 FAC System Susceptibility Evaluation 09/29/2009

9. PER 87040 Preliminary findings from Operations Assist 08/03/2005

10. NA U1R18 FAC Summary Report NA

11. NA U1C17 FAC Summary ReRort NA

12. NA I U2R18 FAC Summary Report NA

13. NA U2R17 FAC Summary R~port NA The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancement.

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. However, 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 confirm if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAI for the subject discussed below.

The "scope of program" program element of the LRA AMP states that the program includes the detection of wall thinning due to mechanisms other than flow accelerated corrosion. The GALL Report AMP states that the FAC program is described by the EPRI guidelines in NSAC-202L-R2 or R3. It is not clear to the staff that these statements are consistent because NSAC-202L-R3 specifically states that the program does not include other thinning mechanisms, such as cavitation and erosive wear. The LRA states that the Flow-Accelerated Corrosion program is consistent with GALL Report AMP XI.M17, without exception. Additional information is needed by the staff in this regard.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown

35 aging effects were identified by the applicant or the staff). However, the staff also determined that the operating experience that the applicant provided-and that the staff identified in an 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. This concerns the "scope of program" program element addressing the detection of wall thinning mechanisms other than flow-accelerated corrosion. SQN-RPT-10-LRD08, "Aging Effects Requiring Management," cites a number of PERs in which the Flow-Accelerated Corrosion program addresses loss of material due to erosion. The staff's questions will be addressed through RAI for the "scope of program" program element.

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 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 program elements in GALL Report AMP XI. M 17. However, the staff identified certain aspects of the "scope of program" program element 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 regarding operating experience is required before a determination can be made regarding 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 8.1.15, Flux Thimble Tube Inspection Summary of Information in the Application. The LRA states that AMP B.1.15, "Flux Thimble Tube Inspection," is an existing program with enhancements 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. 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 other enhancements that are not necessary for consistency, which will be evaluated in the SER Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's 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 staff's search of the applicant's operating experience database.

36 Relevant Documents Reviewed i Document Title Revision I Date 1.0-SI-DXI-000-114.3 ASME Section XIISIINDE Program Revision 18

2. NRC Bulletin No. 88-09 Thimble Tube Thinning in Westinghouse 09/30/1988 Reactors

3. 0-PI-NXX-094-001.0 Incore Seal Table Maintenance Revision 26

4. SQN-RPT-10-LRD02 Flux Thimble Tube Inspection Revision 3

5. SQN-RPT-10-LRD09 Operating Experience Review Results Revision 1

6. CEB-GEN-88PR01 Pipe Rupture Evaluation of Wear on Revision 1 Thimble Tubes

7. U1C17 Incore Flux Thimble Tubes Examination 10/2010 Report

8. U2C17 Incore Flux Thimble Tubes Examination OS/2011 Report The staff conducted its audit of LRA program elements one through six, 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's independent database search found that the operating experience that the applicant provided was representative of known industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff).

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 the GALL Report AMP XI.M37. The staff's evaluation of aspects of the program elements associated with enhancements that 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, 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.1.16, Inservice Inspection Summary of Information in the Application. The LRA states that AMP B.1. 16, "Inservice Inspection" (lSI) program manages loss of material, cracking, thermal embrittlement, flaw growth, and reduction in fracture toughness for ASME Class 1, 2, and 3 pressure retaining components, including welds, pump casings, valve bodies, integral attachments, and pressure retaining bolting using volumetric, surface, and/or visual examination and leakage testing of

37 ASME Class 1, 2, and 3 components as specified in ASME Section XI Code, 2001 Edition 2003 addendum. The applicant states that the lSI Program is an existing program that is consistent with the program elements of the GALL Report AMP XI.M1, "ASME Section Xllnservice Inspection, Subsections IWB, IWC and IWD." To verify this claim of consistency, the staff audited LRA AMP B.1.16.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "cracking," "leak," "leakage,"

"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 staff's search of the applicant's operating experience database.

38 Relevant Documents Reviewed Document Title Revisionl Date Pages

1. 0-SI-DXI-000-114.3 ASME Section XIISI/NDE Program Unit Revision 18, 1 and Unit 2 05/15/2012

2. SQN-RPT -LRD02 Aging Management Program Evaluation Revision 3, Report - Class 1 Mechanical Pages 51 to 58

3. 0-TI-DXI-000-115.0 ASME Section XI Repair/Replacement Revision 2, Program 10/14/2011

4. NPG-SPP-09.1 ASME Code and Augmented Programs Revision 2, 12/19/2012

5. NPG-SPP-09.1.2 ASME Section XI System Pressure test Revision 0, Program 02/15/2012

6. CRP-ISO-02-001 Evaluation of TVAN Augmented 08/23/2002 Examination Program

7. CRP-ISO-05-001 NDE Program Assessment 06/17/2005

8. SQN-RPT-10-LRD09 Operating Experience Review Report Rev. 1 AMP Effectiveness

9. PER-158119 Generic Review of BFN PER-150493, 11/26/2008 Instrument Line Leak

10. PER-227816 Instrumentation Tube Fittings 05/03/2010 Replacement Process Discourages Replacement of Damaged Fittings

11. PER-252289 Tube Fitting Replacement Enhancement 09/16/2010

12. PER-16274 Thru Wall Leak was discovered on the 04/11/2000 ERCW Pipe Leading to Valve 0-67-1514

13. WO-00-003141-000 Work Order for Repair of Leaking Pipe 04/11/2000 Leading to Valve 0-67-1514 14.PER-22127 Dye Penetrant Examination of ERCW 03/04/2002 weld to Valve 0-67-1514

15. ML050550413 Sequoyah Unit 1 - lSI Summary Report- 02/15/2005 Cycle 13

16. ML121850006 Sequoyah Unit 1 - lSI Summary Report- 06/29/2012 Cycle 18

17. ML052350675 Sequoyah Unit 2 - lSI Summary Report- 08/10/2005 Cycle 12

18. ML100541580 Sequoyah Unit 2 - lSI Summary Report- 02/19/2010 Cycle 16 During the audit the staff verified that "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's independent database search found that the operating experience that the applicant provided was representative of known industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff).

39 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 of the GALL Report AMP XI.M1.

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 adequate 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.1.17, Inservice Inspection -IWF Summary of Information in the Application. The LRA states that AMP B.1.17, "Inseryice Inspection - IWF," is an existing program with enhancement 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, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of auxiliary building, diesel generator building, and essential raw cooling water (ERCW) building.

The staff also conducted an independent search of the applicant's operating experience documents.

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SON-RPT-1 0-LRD05 SON Licensee Renewal Project, Aging Revision 1 Management Program Evaluation Report Civil/Structural (Basis Document)

2. N-VT-1 Visual Examination Procedure for ASME Revision 44 Section XI Preservice and Inservice

3. 0-S1-DXI-000-114-3 ASME Section XI ISIINDE Program Unit 1 and Revision 18 Unit 2

4. R-0055 Tennessee Valley Authority, Record of Visual 04/10/2009 Examination, ERCWSH-05, Strainer Support

5. Third Interval lSI Plan 04/21/2006 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancement.

40 During the audit, the staff verified that the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," 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 "monitoring and trending," 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 confirm if this program element is consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAI for the subject discussed below ..

GALL Report AMP XI.S3, "monitoring and trending," program element states that examinations of ASME Class 1, 2, 3, and metal containment (MC) component supports that reveal indications that exceed the acceptance standards and require corrective measures are extended to include additional examinations in accordance with ASME Code Section IWF-2430. However, during the audit, the staff noted cases in which conditions were found during IWF examinations that appeared to be degraded. An engineering evaluation determined that the as-found component was acceptable-as-is, but the component was still re-worked to as-new condition. The licensee did not apply ASME Sections IWF-2420 and IWF-2430 for successive or additional examinations. It is not clear how this approach is consistent with the GALL Report AMP, which discusses the imposition of the ASME Code Section XI, which imposes the lSI requirements per 10 CFR 50.55a. Therefore, the staff plans to issue an RAI requesting the applicant to clarify why it did not apply ASME Sections IWF-2420 and IWF-2430 for successive or additional examinations.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided and that the staff identified in an independent database search is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also deterrnined that the operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subject discussed below.

GALL Report recommends that the extent, frequency, and examination methods for Class 1, 2, 3, and MC component supports are based on ASME Section XI, Subsection IWF per 10 CFR 50.55a. There is a reasonable assurance that properly implemented IWF inspection program will be effective to detect, evaluate, or repair age-related degradation before there is a loss of component support intended function. However, during the audit, the staff performed a walkdown of the essential raw cooling water (ERCW) building and noted that one of the strainer's supports is exposed to continuous leakage with evidence of corrosion of bolts and support plates. Therefore, the staff plans to issue RAI requesting the applicant to describe the actions planned to ensure that corrosion is mitigated and that the degradation of the strainer's support will not prevent it to perform its intended function 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.

41 Audit Results. Based on this audit, the staff verified that the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S3. The staff's 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 the "monitoring and trending,"

program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on this audit, the staff identified that additional information regarding 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 B.1.18, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. The LRA states that AMP B.1.18, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems," is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M23, "Inspection of Overhead Heavy Loads and Light Loads (Related to Refueling)

Handling Systems." 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.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "crane" and "trolley."

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

42 Relevant Documents Reviewed Document Title Revision I Date

11. SQN-RPT-10-LRD05 Inspection of Overhead Heavy Load and Light Revision 1 Load (Related to Refueling) Handling Systems Program Book i 2. SQN-RPT-10-LRD09 Operating Experience Review Results- Aging Revision 1 Management Program Effectiveness

3. 0-MI-MIN-000-014.0 Rigging Equipment and Portable Hoist Control, Revision 7 Inspection and Testing 4.0-MIN-ECR-079-930.0 Manipulator Crane Checkout Revision 0011

5. 0-MI-ECR-079-095 Spent Fuel Pit Bridge Crane Periodic Inspection Revision 0012

. 6. 0-MI-ECR-303-911.0 Reactor Building (Polar) Crane Periodic Revision Inspection 0009

7. PER 63096 Auxiliary Building crane bridge trucks developed 2004 cracks in the welds and base metal causing the crane to be inoperable

8. PER 66902 Auxiliary building crane rail bolts were found 2004 broken and rubbing the seismic restraints The staff conducted its audit of LRA program elements one through six 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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, 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 this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this 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 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, 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.

43 LRA AMP B.1.19,lnternal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The LRA states that AMP B.1.19, "Internal Surfaces in Miscellaneous Piping and Ducting Components," is a new program that is consistent with the program elements in GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components." To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "fouling," "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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD03 Internal Surfaces in Miscellaneous Piping Revision 3 and Ducting Components Program Book

2. SQN-RPT-10-LRD09 Operating Experience Review Report- Aging Revision 1 Management Program Effectiveness

3. PER 24406 Degrading performance of component cooling 03/09/1999 heat exchanger was drained and opened for inspection and cleaning

4. PER 153397 Several WO's have been written on the clogging 09/26/2008 of various building floor drain systems. The drain clogging problems seems to be happening more frequently due to through wall leaks in other systems and degraded drain piping.

5. PER 207413 QA observation of work in the auxiliary building 11/08/1999 observed extensive external corrosion on the inlet and discharge side of both 2A and 2B Incore instrument room chiller pump piping

6. PER 171629 Diesel generator exhaust piping indicates this pipe 05/18/2009 will drop below the calculated allowable wall thickness. The time to failure changes from November 2010 to 2017, there will be several more inspections between this time.

During the audit of program elements one through six, 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 that the applicant provided-and that the staff identified in an independent

44 database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in a 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subject discussed below.

• The Operating Experience Summary Report and "operating experience" program element state that the Internal Surfaces in Miscellaneous Piping and Ducting Components program is inappropriate to use for copper-alloy exposed to condensation and carbon steel exposed to waste water in ventilation, station drain, waste disposal and diesel generator systems due to repetitive losses of component intended function due to aging effects. However there are several instances in the LRA where Internal Surfaces in Miscellaneous Piping and Ducting Components program is being used to manage those material/environment/system combinations.

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 "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 program elements in GALL Report AMP XI.M38. The staff also identified certain aspects of the "scope of program" program element of the LRA AMP for which additional evaluation is required. This evaluation will be conducted during the review of the operating experience RAI.

Based on this audit, the staff identified that additional information regarding 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 B.1.20, Masonry Wall Summary of Information in the Application. The LRA states that AMP B.1.20, "Masonry Wall," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.S5, "Masonry Walls." To verify this claim of consistency, the staff audited the LRA AMP. 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, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted a walkdown of the Diesel Generator Building. The staff also conducted an independent search of the applicant's operating experience database using keywords: "masonry," "crack," "mortar," and "block."

45 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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-1 0-LRD-05 Aging management Program Evaluation Revision 1 Report Civil/Structural (Basis Document)

2. SQN-RPT-10-LRD09 Operating Experience Review Results - Aging Revision 1 Management Program Effectiveness

3. SQN-DC-V-1.1.1 Reinforced Concrete Block Walls Revision 5 11/15/1995

4. SQN-CI-96.02 Procedure For Walkdown of Structures for Revision 1 Maintenance Rule 10/4/2000

5. PER 81388 Cracked Block Walls 04/16/2010 The staff conducted its audit of LRA program elements one through six 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. The staff also verified that currently, masonry walls are being monitored as part of the existing Structures Monitoring program and that the Masonry Wall AMP described in the LRA will continue to be implemented as part of the Structures Monitoring AMP through the period of extended operation. Therefore, the staff reviewed the Structures Monitoring AMP and verified that the elements of the Masonry Wall AMP have been incorporated in to the Structures Monitoring AMP, as recommended in the GALL Report.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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. The staff notes that the enhancements to the Masonry Wall program are included in the FSAR supplement as enhancements to the Structures Monitoring program.

Audit Results. Based on this 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 program elements in GALL Report AMP XI.S5, and have been incorporated into the Structures Monitoring program.

46 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 B.1.21, Metal Enclosed Bus Inspection Summary of Information in the Application. The LRA states that AMP B.1.21 "Metal Enclosed Bus Inspection" is a new program that is consistent with the program elements in the GALL Report AMP XI.E4, "Metal Enclosed Bus." 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 applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the switchyard, metal enclosed buses outside the auxiliary and turbine buildings, and the switchgear in the auxiliary buildings. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "metal enclosed bus," "cracked insulation,"

"bus connection loosening, and "debris buildup."

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD04 Aging Management Program Evaluation Revision 1 Results - Metal Enclosed Bus Inspection

2. SQN-RPT-10-LRD09 Operating Experience Report - Aging Revision 1 Management Program Effectiveness

3. PER 166884 Dual Unit Trip 9/10/2010

4. WO 08-771489-000 6.9 kV Start up Bus 1A Unit BDS 1A & 1C 03/29/2009 Feed Bus

5. SR 702081 Evaluate Torque Practices Used in SQN 03/26/2013 Non-Segregated Bus PMs

6. SQN-1-Bus-202-CC/CE 6.9 kV Start up Bus 1A Unit BDS 1A & 1C 09/15/2010 Feed Bus (2,000A)

During the audit of program elements one through six, the staff verified that the "scope of program," "preventive actions," "parameters monitored/inspected," "detection of aging effects,"

"monitoring and trending," and "acceptance criteria" program element(s) 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in an 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

47 information necessary to determine if the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subjects discussed below.

• In LRA Section B.1.21, under Element 10, operating experience, the applicant states that there is no operating experience at SON involving the aging effects managed by this program. However, during the metal enclosed bus walk down, the staff became aware of a metal enclosed bus failure that occurred in 2009.

The cause of this event was due to cracked bus insulation and moisture intrusion. The staff is concerned that a similar failure mode may occur in the in scope MEBs during the extended period of operation. SON operating experience may not support the applicant's conclusion that LRA AMP B.1.21 will provide reasonable assurance that the aging effects will be managed such that the in scope MEBs will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

• During the review of SON-1-Bus-202-CC/CE, the staff identified an issue with torque check in the plant procedure. Section 5.7.e of the procedure requires verifying that bolts have the proper torque. Re-torquing is not recommended per industry guidance such as EPRI Technical Report (TR) -104213, "Bolted Joint Maintenance & Application Guide." The staff will consider issuing a RAI to request the applicant to explain the practice used to perform torque checks verses the industry recommended practice not to re-torque once the fastener is in service practice.

• During the breakout meeting, the applicant indicated that it currently performs thermography of the MEB connections with the MEB covers in place with the bus fully loaded. The applicant also indicated that the thermography test case was not able to identify enough detail (by temperature between individual components was not apparent) to consider this method effective. The staff noted that typically, Infrared (IR) windows are installed on metal enclosed bus covers for the purpose of thermography inspection. Without IR windows, the MEB cover may mask the temperature difference between the buses and may not be able to detect bus connection high resistance due to bolt loosening.

The staff also audited the description of the LRA AMP provided in the Section A.1.21 of 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 the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program element(s) of the LRA AMP are consistent with the corresponding program element(s) in the GALL Report AMP XI.E4.

Based on this audit, the staff also identified that additional information regarding 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.

48 LRA AMP 8.1.22, Neutron-Absorbing Material Monitoring Summary of Information in the Application. The LRA states that AMP B.1.22, "Neutron Absorbing Material Monitoring," is an existing program with enhancements that will be 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. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the spent fuel pool. The staff also conducted an independent search of the applicant's operating experience database using keywords: "Boral," "neutron attenuation," and "coupon."

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. PER 34047 Fuel Assembly N-48 Binding in SFP Rack DD-39 04/05/2004

2. PER 585127 Fuel Assembly M42 could not be inserted in SFP 08/14/2012 location P-39

3. PER 166812 Fuel Distortion Impact on B.5.b move in SFP 04/26/2009

4. SQN-RPT-10-LRD03 Neutron Absorbing Material Monitoring Revision 3 5.0-TI-NUC-000-009.0 Spent Fuel Pool Coupon Tree Surveillance 09/21/2011 The staff conducted its audit of LRA program elements one through six 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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 the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and

49 trending," and "acceptance criteria" program elements of the LRA AMP 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, 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 8.1.23, Nickel Alloy Inspection Summary of Information in the Application. The LRA states that AMP B.1.23, "Nickel Alloy Inspection" is an existing program that is consistent with the program elements in GALL Report AMP XI.M11 B, "Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid Induced Corrosion in Reactor Coolant Pressure Boundary Components (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 applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "nozzle," "weld," "vessel head," "bottom head," "cracking," "stress corrosion cracking," 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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date .

1. SON-RPT-1 0-LRD02 Sequoyah License Renewal Project Aging Revision 3 Management Program Evaluation Report Class 1 Mechanical, Section 4.0, Nickel Alloy Inspection Program

2. SON-RPT-10-LRD09 Sequoyah License Renewal Project Revision 1 Operating Experience Review Results-Aging Management Program Effectiveness, Section 3.1.19, Nickel Alloy Inspection Program

3. NETP-113 PWR Alloy 600 Program and Other Revision1, AUQmented Inspection Requirements 9/17/2012 4.0-SI-DXI-000-114.3 ASME Section XI ISI/NDE Unit 1 and Unit 2 Revision 18, 5/15/2012 5.0-TI-STP-000-301.0 ASME Section XI Pressure Testing Program Revision 2, Basis Document 10/4/2011

6. 1-SI-SXI-068-201.0 Leakage Test of the Reactor Coolant Revision 8, Pressure Boundary 8110/2012

7. LTR-PCAM-04-26 Location of Alloy 600 and Dissimilar Metal Revision 0, Alloy 82/182 Welds in the Reactor Coolant 8110/2007 System

50 Document Title Revision I Date

8. R-0087 Examination Summary and Resolution Data 111/4/2009 Sheet

9. R-0114 Examination Summary and Resolution Da 5/2009 Sheet

10. Unit 1 Refueling Outage 18 Day 6/29/2012 Inservice Inspection Summary Report

11. Unit 1 Cycle 17 Day Inservice 2/14/2011 Inspection Summary Report

12. Unit 2 Cycle 17 Day Inservice 9/20/2011 Inspection Summary Report

13. PER 100748 Boric Acid Corrosion on Reactor Coolant 4/11/2006 Pressure Vessel Lower Head Components (Unit 1)

14. PER 131924 Reactor Vessel Head Lower Penetration 10/12/2007 NRC Identified Concerns (Unit 1)

15. PER 206864 Nozzle Cover Leakage (Unit 2) 11/03/2009

16. 0-TI-DXX-000-09 Boric Acid Corrosion Control Program Revision 8, 4/15/2011

17. Engineering Evaluation: Reactor Pressure 04/21/2006 Vessel Bottom Head Examination Results Sequoyah Nuclear Plant - Unit 1 Cycle 14 Refueling Outage

18. PER 127129 Reactor Vessel Head Adapter Thermal 7/05/2007 Sleeve

19. TVA-07-96 Westinghouse Letter, Tennessee Valley 10/10/2007 Authority Sequoyah Units 1 & 2 And Watts Bar Unit 1: Thermal Sleeve Wear Evaluation Transmittal of Thermal Sleeve Wear Evaluation Report

20. LTR-RIDA-07-176 Westinghouse Report, Thermal Sleeve 10/9/2007 Wear Evaluation for Sequoyah Units 1 & 2 and Watts Bar Unit 1

21. WCAP-16903-P Addendum to Analytical Reports for Revision 0, Sequoyah Units 1 and 2 Reactor Vessels April 2008

22. TB-07-2 Westinghouse Technical Bulletin, Reactor Revision 1 Vessel Head Adapter Thermal Sleeve Wear

23. Sequoyah Unit 1, Cycle 15 - RPV Closure 10/16/2007 Head Nozzle Thermal Sleeve Wear Visual Examination

24. Engineering Evaluation of SON Unit 1 and 4/8/2008 Unit 2 Thermal Sleeve Wear *

25. PER 132139 Unit 1 RPV Nozzle Thinning 10/16/2007

26. PER 138340 The Unit 1 Engineering Evaluation for TB 02/15/2008 07-2 R1 Did Not Address Unit 2

27. Drawing No. 6038338 Sequoyah Units 1 & 2 RV Head Map Revision 1, B 08/01/2006

28. Drawing No. 541 F980 PWR Thermal Sleeve 11/14/1985

51 During the audit of program elements one through six, 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. For the "detection of aging effects" 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 confirm if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAI for the subjects discussed below.

• The "detection of aging effects" program element, as described in the program basis document, indicates that the Nickel Alloy Inspection Program detects reactor coolant pressure boundary cracking and leakage due to primary water stress corrosion cracking (PWSCC), consistent with the GALL Report AMP. During the audit, the staff noted that the visual examination of the Unit 1 reactor vessel bottom head and keyway area identified evidence of borated-water leakage and corrosion during the 2006 refueling outage. However, the LRA does not address if the leakage resulted from aging-related degradation of reactor vessel and piping components. The staff also needs to clarify how the applicant's program manages and resolves the situation that borated-water leakage and associated corrosion products interfere with the visual examination of the components that are included in the program scope.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided and that the staff identified in an independent database search indicates that a previously unknown aging effect was identified in the reactor vessel upper head penetration nozzles during the volumetric examination specified in the applicant's program. The staff will consider issuing RAI for the subject discussed below.

• During the volumetric examination of the Unit 1 reactor vessel upper head penetrations in 2007, wear indications were found on control rod drive mechanism (CRDM) penetration nozzles 1, 2, 3, 4 and 5. These wear indications were due to the interaction between the inside surfaces of the CRDM penetration nozzles and the centering pads of the CRDM thermal sleeves located inside the penetration nozzles. However, the LRA or applicant's program basis document does not clearly describe how these wear indications will be monitored and managed to maintain the integrity of the reactor head penetration nozzles and to prevent potential reactor coolant pressure boundary leakage.

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 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 program elements in GALL Report AMP XI.M11 B. The staff also identified certain aspects of the "detection of aging effects" program element of the LRA AMP, 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 regarding operating experience is required before a determination can be made regarding the sufficiency of the applicant's aging management to detect and manage the effects of aging. In addition, the staff

52 verified that the description provided in the FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.24, Non-EQ Cable Connections Summary of Information in the Application. The LRA states that AMP B.1.24, "Non-EQ Cable Connections," is a new program that is consistent with the program elements in the 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 will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "cable connections,"

"increased connection resistance," "ohmic heating", and "cable connection loosening."

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-1 0-LRD04 Aging Management Program Evaluation Results Revision 1

- Non-EQ Cable Connections Program

2. LR-ISG-2007 -02 Changes to Generic Aging Lesson Learned Revision 1 Report Aging Management Program XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Req uirements"

3. SQN-RPT-10-AME01 Aging Management Review Electrical Systems Revision 0

4. SQN-RPT-10-LRD09 Operating Experience Report- Aging Revision 1 Management Program Effectiveness FEI690 White Paper on GALL AMP XI.E6 (Electrical 09/05/2006 Cables)

During the audit of program elements one through six, 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 element(s) 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subject discussed below.

53

• In LRA Section B.1.24, under Element 10, operating experience, the applicant states that The Non-EQ Cable Connections Program is a new program. Industry operating experience will be considered in the implementation of this program. Plant operating experience will be gained as the program is executed and will be factored into the program via the confirmation and corrective action elements of the SQN 10 CFR Part 50 Appendix B quality assurance program. SRP-LR Section A.1.2.3.1 0 states that for new AMPs that have yet to be implemented at an applicant's facility, the programs have not yet generated any operating experience (OE). However, there may be other relevant plant-specific OE at the plant that is relevant to the AMP's program elements even though the OE was not identified as a result of implementation of the new program.

Thus, for new programs, an applicant may need to consider the impact of relevant OE that results from the past implementation of its existing AMPs that are existing programs and the impact of relevant generic OE on developing the program elements. Therefore, operating experience applicable to a new program should be discussed. In the License Renewal Interim Staff Guidance (LR-ISG) 2011-05, the staff stated that it intends for the ongoing review of operating experience to inform every AMP, regardless of the AMP's implementation schedule. Reviewing operating experience should be on an ongoing review basis to ensure the effectiveness of license renewal AMPs.

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 the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program element(s) of the LRA AMP are consistent with the corresponding program element(s) in the GALL Report AMP XI.E6.

Based on this audit, the staff also identified that additional information regarding 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 8.1.25, Non-EQ Inaccessible Power Cables (400 V to 35 kV)

Summarv of Information in the Application. The LRA states that AMP B.1.25, "Non-EQ Inaccessible Power Cables (400 V to 35 kV)," is a new program 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.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the switchyard, selected manholes, and the 6.9 kV Switchgear in the Turbine and Auxiliary buildings that feed the inscope cables of the program. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "manhole," "submerged cable," "buried cable," and "inaccessible cable."

54 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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

. 1. SON-RPT-10-LRD04 Aging Management Program Evaluation Results Revis' Electrical

12. SON-RPT-10-LRD09 Operating Experience Review Results - Aging Revision 1 Management Program Effectiveness

• 3. Letter to S.L Harvey Letter from T. Noe (Director of Site Engineering), 3/12/2013

• LP 4J-C Response to Corporate Oversight- Level 1 Escalation letter, (ERCW Duct Bank Dewatering Efforts)

4. Pictures Pictures of conduit plugging at ECRW pump 2/28/2013 station

5. PER 432510 PER Summary of Corrective Action 10/22/2012

6. SON PER 622595 Apparent Cause Evaluation Report 10/11/2012 ACE Report Water in Manholes/Handholes

7. SON PER 589672 Apparent Cause Evaluation Report 08/08/2012 ACE Report Water in Manholes/Handholes

8. SON PER 585074 Apparent Cause Evaluation Report Revision 0, ACE Report Manholes with Standing Water Not Being 07/25/2012 Pumped in Timely Fashion 9.05000327/2012002 Integrated Inspection Report 4/30/2012

10. AC 35W830-4 Manhole layout Drawing Revision 1

11. AC 15N810-4 Manhole layout Drawing Revision I

EE

12. AC 15W810-13 Manhole layout Drawing Revision H

13. Supporting SON License Renewal 03/28/2013 Information NRC Request for Supporting Information

14. Letter of 5/4/2007 Letter from Wetzel B.A. to the NRC, "Browns Ferry 05104/2007 Nuclear Plant (BFN) Units 1, 2 and 3, Sequoyah Nuclear Plant (SON) Units 1 and 2, and Watts Bar Nuclear Plant (WBN) Unit 1- Nuclear Regulatory Commission (NRC) Generic Letter (GL) 2007-01:

Inaccessible or Underground Power Cable failures that disable accident mitigation systems or cause plant transients- 90 day response." I During the audit of program elements one through six, 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the

55 operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subjects discussed below.

• GALL AMP XI,E3 states that periodic actions are taken to prevent inaccessible cables from being exposed to significant moisture, defined as periodic exposures to moisture that last more than a few days. Examples of periodic actions are inspecting for water collection in manholes and conduits and draining water as needed. The inspection should include direct observation that cables are not wetted or submerged, and cables/spices and cable support structures are intact, and that dewatering/drainage systems (sump pumps) and associated alarms operate properly. During review of the applicant's operating experience, work orders, problem evaluation reports (PERs), and inspection reports, the staff identified unresolved cases of unacceptable levels of water in the manholes and handholes, which could potentially expose in-scope power cables to significant moisture and/or cable submergence. When a power cable is exposed to wet or submerged conditions for which it is not designed, an aging effect of reduced insulation resistance may result, causing a decrease in the dielectric strength of the conductor insulation. This insulation degradation caused by wetting or submergence can potentially lead to failure of the cable's insulation system. The applicant's manhole inspections, including maintenance of sump pumps and cable support structures may not be adequate to prevent the submergence of in-scope inaccessible power cables.

Additional information, that demonstrates proactive and satisfactory manhole, sump pump, and cable support structure inspection and maintenance corrective actions to prevent in-scope inaccessible power cables from being exposed to significant moisture is required before a determination can be made regarding the sufficiency of the LRA AMP 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 if 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 RAI for the subjects discussed below.

• LRA FSAR supplement Section A.1.25 does not include the test techniques consistent with SRP Rev. 2, Table 3.0-1, as follows: "the applicant can assess the condition of the cable insulation with reasonable confidence using one or more of the following techniques: Dielectric loss (Dissipation Factor/Power Factor), AC Voltage withstand, Partial Discharge, Step Voltage, Time Domain Reflectometry, Insulation Resistance and Polarization Index, Line Resonance Analysis, or other testing that is state-of-the-art at the time the tests are performed. One or more tests are used to determine the condition of the cables so they will continue to meet their intended function during the period of extended operation." In the absence of these testing techniques, it makes the FSAR supplement inconsistent with basis document SQN-RPT-10-LRD04 and the GALL Report AMP XI.E3, Program Description, and Detection of Aging Effects, which list the specific tests.

• LRA FSAR supplement Section A.1.25 does not provide periodic inspection specifics consistent with SRP Rev. 2, Table 3.0-1 as follows: "the applicant shall include periodic inspection specifics as follows: The inspection should include direct observation that

56 cables are not wetted or submerged, that cablesl splices and cable support structures are intact, and dewatering/ drainage systems (Le., sump pumps) and associated alarms operate properly. In addition, operation of dewatering devices should be inspected and operation verified prior to any known or predicted heavy rain or flooding events." In the absence of these specifics for periodic inspection, it makes the FSAR supplement inconsistent with the basis document SQN-RPT-10-LRD04 and with the GALL Report AMP XI.E3, Preventive Actions.

Audit Results. Based on this 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 element(s) of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI. E3.

Based on this audit, the staff also identified that additional information regarding 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 8.1.26, Non-EQ Instrumentation Circuits Test Review Summary of Information in the Application. The LRA states that AMP B.1.26, "Non-EQ Instrumentation Circuits Test ReView," is a new program 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.

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

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "discoloration,"

"instrumentation cable," "melting cable," "radiation monitor" and "reduced insulation resistance."

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

The applicant provided these document or they were identified in the staff's search of the applicant's operating experience database.

57 Relevant Documents Reviewed Document Title Revision I Date

1. SON-RPT-1 0-LRD04 Aging Management Program Evaluation Results Revision 1

- Electrical Non-EO Instrumentation Circuits Test Review Program

2. O-PI-IXX-092-N45.0 Calibration of Power Range Nuclear Revision Instrumentation System Following Incore/Excore 28 Detection Calibration

3. O-PI-NUC-092-036.0 Incore-Excore Detector Calibration Revision 12

4. O-SI-ICC-090-125.A Channel Calibration of Main Control Room Intake Revision Radiation Monitor O-R-90-125 (Train A) 20

5. O-PI-ICC-090-205 Channel Calibration of Main Control Room Revision 3 Emergency Intake Radiation Monitor (Train A)

6. SON-RPT-10-LRD09 Operating Experience Report - Aging Revision 1 Management Program Effectiveness

7. SON-RPT-10-AME01 Aging Management Review Electrical Systems Revision 0 During the audit of program elements one through six, 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 element(s) 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subject discussed below.

• In LRA Section B.1.26, under Element 10, operating experience, the applicant states that The Non-EO Instrumentation Circuits Test Review Program is a new program.

Industry operating experience will be considered in the implementation of this program.

Plant operating experience will be gained as the program is executed and will be factored into the program via the confirmation and corrective action elements of the SON 10 CFR Part 50 Appendix B quality assurance program. SRP-LR Section A.1.2.3.1 0 states that for new AMPs that have yet to be implemented at an applicant's facility, the programs have not yet generated any operating experience (OE). However, there may be other plant-specific OE that is relevant to the AMP's program elements even though the OE was not identified as a result of implementation of the new program. Thus, for new programs, an applicant may need to consider the impact of relevant OE from the past implementation of its existing AMPs and the impact of relevant generic OE on developing the program elements. Therefore, operating experience applicable to a new program should be discussed. In the License Renewal Interim Staff Guidance (LR-ISG) 2011-05, the staff stated that it intends for the ongoing review of operating experience to inform every AMP, regardless of the AMP's implementation schedule. Reviewing

58 operating experience should be on an ongoing review basis to ensure the effectiveness of license renewal AMPs.

The staff also audited the description of the LRA AMP provided in the FSAR supplement Section A.1.26. The staff found that sufficient information was not available to determine if the description provided in the UFSAR Supplement was an adequate description of the LRA AMP.

To obtain the information necessary to verify the sufficiency of the UFSAR Supplement program description, the staff will consider issuing RAI for the subject(s) discussed below.

• SRP Table 3.0-1, FSAR Supplement for Aging Management of Applicable Systems under AMP XI, E2 states that in cases where cables are not part of a calibration or surveillance program, a proven test (such as insulation resistance tests, time domain reflectometry tests, or other test judged to be effective as justified in the application) for detecting deterioration of insulation system are performed. LRA Section A.1.26 states that for sensitive instrumentation circuit cables that are disconnected during instrumentation calibrations, testing will be performed using a proven method for detecting deterioration for the insulation. The applicant does not identify the type of tests (e.g., such as insulation resistance tests, time domain reflectometry tests, or other test judged to be effective as justified in the application) that can be used in the FSAR supplement. In the absence of these testing techniques, the FSAR supplement is inconsistent with GALL Report AMP XI.E2 and SRP Table 3.0-1, which provides guidance on the specific tests.

Audit Results. Based on this 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 program elements in GALL Report AMP XI.E2.

Based on this audit, the staff also identified that additional information regarding 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 8.1.27, Non-EQ Insulated Cables and Connections Summary of Information in the Application. The LRA states that AMP B2.1.27, "Non-EQ Insulated Cable and Connections," is a new program 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. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of representative plant areas and also conducted an independent search of the applicant's operating experience database using keywords: "cable corrosion," "cable cracking," and "cable degrade."

59 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 applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SON-RPT-1 0-lRD04 B1.27 Non-EO Insulated Cable and Connections Revision 1

2. PERS 19943 Cables in Conduit 1FE 86 are Showing Signs of 04/16/2004 the Outer Insulation Breaking Down

3. PERS 168892 Degraded Cable 04/20/2009 During the audit of program elements one through six, the staff verified that the "scope of program," "preventive actions," "parameters monitored/inspected," "detection of aging effects,"

"monitoring and trending," and "acceptance criteria" program element(s) 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the lRA AMP, the staff will consider issuing RAI for the subject discussed below.

• In lRA Section B.1.24, under Element 10, operating experience, the applicant states that The Non-EO Cable Connections Program is a new program. Industry operating experience will be considered in the implementation of this program. Plant operating experience will be gained as the program is executed and will be factored into the program via the confirmation and corrective action elements of the SON 10 CFR 50 Appendix B quality assurance program. SRP-lR Section A.1.2.3.1 0 states that for new AMPs that have yet to be implemented at an applicant's facility, the programs have not yet generated any operating experience (OE). However, there may be other relevant plant-specific OE at the plant that is relevant to the AMP's program elements even though the OE was not identified as a result of implementation of the new program.

Thus, for new programs, an applicant may need to consider the impact of relevant OE that results from the past implementation of its existing AMPs that are existing programs and the impact of relevant generic OE on developing the program elements. Therefore, operating experience applicable to a new program should be discussed. Inthe license Renewal Interim Staff Guidance (lR-ISG) 2011-05, the staff stated that it intends for the ongoing review of operating experience to inform every AMP, regardless of the AMP's implementation schedule. Reviewing operating experience should be on an ongoing review basis to ensure the effectiveness of license renewal AMPs.

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.

60 Audit Results. Based on this 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 element(s) of the LRA AMP are consistent with the corresponding program element(s) in the GALL Report AMP XI.E1.

Based on this audit, the staff also identified that additional information regarding 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 8.1.28, Oil Analysis Summary of Information in the Applications. The LRA states that AMP B.1.28, "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, which will be evaluated in the SER.

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

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD03 Aging Management Program Evaluation Report Revision 3 Non-Class 1 Mechanical

2. 0-TI-PDM-000-002.0 I Oil Sampling and Monitoring Revision 5

3. NPG-SPP-03.1 Corrective Action Program Revision 5

4. PER 22427 Oil analysis results from oil samples of the RCP 2 5/16/2002 4 inboard and outboard bearing reservoirs

15. PER 18331 Review of OE 17415 12/20/2004

6. PER 17877 Results for the quarterly oil sample taken on 9/13/2002 5/29/2001

7. PER 145363 CSST A winding X, dissolved gas oil analysis 12/17/2009 I 8. PER 327744 Change out oil in the Main Turbine Oil systems 02/24/2011 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program.

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

61 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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 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 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 8.1.29, One-Time Inspection Summary of Information in the Application. The LRA states that AMP B.1.29, "One-Time Inspection," is a new program that will be consistent with the program elements in GALL Report AMP XI.M32, "One-Time Inspection." To verify this claim of consistency, the staff audited the LRAAMP.

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

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 staff's search of the applicant's operating experience database.

62 Relevant Documents Reviewed Document Title Revisionl Date

1. SQN-RPT-10-LRD03 Aging Management Program Evaluation Report Revision 3 Non-Class 1 Mechanical

2. SQN-RPT-10-AMM03 Aging Management Review of the Reactor Revision 1 oolant Pressure Boundary

! 3. SQN-RPT-10-AMM03 achment 2 - Aging Management Review Revision 1 Result

! 4. SQN-RPT-10-AMM03 Attachment 1 - Components subjected to AMR Revision 1 5.1,2-47W813-1-ISI Flow Diagram Reactor Coolant System 03-11-91 During the audit of program elements one through six, 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 the staff noted the following:

The "scope of program" program element of the LRA AMP B.1.29 includes the reactor vessel flange leak-off lines. It was unclear to the staff why the applicant included this in the One-Time Inspection program. However, based on its review of the Flow Diagram Reactor Coolant System; the staff noted that this piping is also included in the Inservice Inspection program.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the staff identified in an independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the staff identified in an 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 this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this 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 program element in GALL Report AMP XI.M32. 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.

LRA AMP B.1.30, One-Time Inspection - Small-Bore Piping Summary of Information in the Application. The LRA states that AMP B.1.30, "One-Time Inspection - Small-Bore Piping Program," is a new program that is consistent with the program elements of the GALL Report AMP XI.M35, "One-Time Inspection of ASME Code Class 1 Small-Bore Piping." The applicant stated that it will implement this program within six years

63 prior to the period of extended operation. 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 applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent database search of the applicant's operating experience database using the following keywords:

"cracking," "failure," "socket," "butt," "thermal," "fatigue," 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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title .... . . nl I Date

1. SQN-RPT-10-LRD02 One-Time Inspection Small-Bore Piping Revision 3 Pages 12-18

2. SQN-RPT-10-LRD09 Operating Experience Review Results Revision 1 Page 97

3. EPRI -1022564 MRP-146, Management of Thermal Fatigue June 2011 in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines

.4. SQN121016-01 Sequoyah Units 1 and 2, License Renewal Revision 0, Project Request for Information 10/16/2012

5. WO-09-773437 -000 Routine Work Order, ASME Section XI, 04/06/2009

• Replacement of Class 1, 1-1/2 inch NPS Piping Downstream of Check Valve 1-63-587 Due to Indications Found During NDE Examination I 6. PER-167979 Loop 2 Safety Injection Socket Weld Indication, 04/07/2009 Unit1 Cycle 16

7. SQ950384PER Pipe Fracture Upstream of Carbon Steel to 05/11/1995 Stainless Steel Socket Weld on 2-ULV-7-542 During the audit of program elements one through six, 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. 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 confirm 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 LRA program description does not provide the total number of in-scope weld population for its units. The GALL Report AMP "detection of aging effects" program element recommends that jf an applicant has never experienced a failure of its ASME Code Class 1 piping and has extensive operating history (>30 years) at time of submitting the application, the inspection sam pie size should be at least 3 percent of the weld population or a maximum of 10 welds of each weld type for each operating unit. It is not clear to the staff how the sample size would be calculated, since the total population of Class 1 butt welds and socket welds for each of the applicant's units within-scope of the program are not provided in the applicant's LRA. In

64 addition, the "detection of aging effects" program element of the GALL AMP recommends that for socket welds, opportunistic destructive examination can be performed in lieu of volumetric examination. Because more information can be obtained from a destructive examination than from nondestructive examination, the applicant may take credit for each weld destructively examined as being equivalent to having volumetrically examined two welds. The LRA program description is not clear if the applicant will use opportunistic destructive examination for butt welds, and how it will be credited in lieu if volumetric.

During the audit of the "operating experience" program element, the staff's independent database search found that the operating experience that the applicant provided was representative of known industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff).

The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff found that with the exception of the "detection of aging effects" program element discussed above, the description provided in the FSAR supplement is an adequate description of the LRA AMP.

Audit Results. Based on this audit, the staff verified that the "scope of program," "preventive actions," "parameters monitored or inspected," "monitoring and trending," "acceptance criteria,"

and "operating experience" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M35. The staff also identified certain aspects of the "detection of aging effects" program element of the LRA AMP for which additional information or additional 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, when implemented by the applicant, will be sufficient to detect and manage the effects of aging. In addition, with the exception of the issues identified in the "detection of aging effects" program element as previously discussed, the staff verified that the description provided in the applicant's FSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP B.1.32, Protective Coating Monitoring and Maintenance Summary of Information in the Application. The LRA states that AMP B.1.32, "Protective Coating Monitoring and Maintenance," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.S8, "Protective Coating Monitoring and Maintenance Program." To verify this claim of consistency, the staff audited the LRAAMP.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "service levell," and "coating."

The table below lists the documents that the staff and found to be relevant to the audit. The applicant provided these documents or the staff identified them in its search of the applicant's operating experience database.

65 Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD05 Protective Coatings and Maintenance Program Revision 1

2. SQN-RPT-10-LRD05 Operating Experience Review Results - Aging Revision 1 Management Program Effectiveness

3. NPG-SPP-03.1 Corrective Action Program Revision 5

4. PM014351000 Preventive Maintenance Work Instructions

5. PM014342000 Preventive Maintenance Work Instructions

6. PM014741000 Preventive Maintenance Work Instructions

7. PM014732000 Preventive Maintenance Work Instructions

8. PM014381000 Preventive Maintenance Work Instructions

9. PM014392000 Preventive Maintenance Work Instructions

10. SRN-G-55-30 TVA General Engineering Specification No. G-55 Revision For Technical and Programmatic Requirements 18 for the Protective Coating Program for TVA Nuclear Plants

11. SQN-DC-V-2.9 Design Criteria for Protective Coatings for the 4/30/1973 Interior of the Containment Vessel and Items Located Within the Containment Vessel

12. M&AI-5.3 Application and Repair of Protective Coatings Revision 12

13. 0-TI-DXX-000-01 0.0 Protective Coatings Program for Coating Service Revision 0 Level I and II and Corrosive Environment Applications

14. TVA-NQA-PLN89-A Nuclear Quality Assurance Plan (NQAP) Revision 27

15. PER 603442 Coating inspection results not evaluated by 9/28/2012 Engineering per G-55

16. PER 602322 Coating inspection program deficiencies 9/18/2012 The staff conducted its audit of LRA program elements one through six based on the contents of the new 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 that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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 il) consistent with the description provided in the SRP-LR.

66 Audit Results. Based on this 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 program elements in GALL Report AMP XI.S8. The staff's evaluation of aspects of the program elements associated with enhancements that 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, 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 8.1.33, Reactor Head Closure Studs Summarv of Information in the Application. The LRA states that AMP B.1.33, "Reactor Head Closure Studs Program," is an existing program with enhancements 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. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "bolt," "bolting," "closure stud,"

"stress corrosion cracking," "wear," "cracking," and "stuck."

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

The applicant provided these documents or the staff identified them in its search of the applicant's operating experience database.

67 Relevant Documents Reviewed Document Title Revision I Date

1. SON-RPT-10-LRD02 Aging Management Program Evaluation Report Revision 3 Class I Mechanical - Reactor Head Closure Studs

2. 1-SI-SXI-068-201.0 Leakage Test of Reactor Coolant Pressure Revision Boundary, Unit 1 0008

3. 2-SI-SXI-068-201.0 Leakage Test of Reactor Coolant Pressure Revision Boundary, Unit 2 0007

3. 0-SI-DXI-000-114.3 ASME Section XI, ISI/NDE Program Unit 1 and Revision 2 0018 4.0-TI-DXI-000-115.0 ASME Section XI Repair/Replacement Program Revision 0002

5. NPG-SPP-03.1 SON Corrective Action Program Revision 0005

6. SON-RPT-10-LRD09 Operating Experience Review Results - Aging Revision 1

• Management Program Effectiveness I 7.0-MI-MRR-068-006.0 Installation of Reactor Pressure Vessel Revision 38

• Head and Attachments

8. MSDS FEL-PRO N-5000 Lubricant 11/15/1995 The staff conducted its audit of LRA program elements one through six 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's independent database search found that the operating experience that the applicant provided was representative of known industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff).

The staff also audited the description of the LRA AMP provided in the 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 "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 program elements in the GALL Report AMP XI. M3.

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.

68 LRA AMP B.1.34, Reactor Vessel Internals Summary of Information in the Application. The LRA states that AMP 8.1.34, "Reactor Vessel Internals," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP X1.16A, "PWR Vessel Internals," as documented in Draft LR-ISG-2011-04. 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 as documented in draft LR-ISG-2011-04.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "vessel internals," "reactor vessel internals," and "8-N-3."

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-1 O-LRD02 Sequoyah License Renewal Project Revision 3 Aging Management Program Evaluation Report - Class 1 Mechanical - Reactor Vessel Internals Program

2. SQN-RPT-10-LRD09 Sequoyah License Renewal Project- Revision 1 Operating Experience Review Results Aging Management Program Effectiveness

3. NETP-119 PWR Reactor Vessel Internals Program Revision 0

4. WCAP-14577 Westinghouse Owners Group Revision 1-A Transmittal of Approved Version of WOG Aging Management Report, "License Renewal Evaluation: Aging Management for Reactor Internals"

5. LTR-RIDA-12-43 Sequoyah Units 1 and 2 (TVAlTEN) Plant Revision 1 Life Extension - Information Request for Reactor Internals

6. SQN120713-02 Sequoyah Units 1 and 2 - License Revision 0 Renewal Project - Request For Information (RFI)

7. NUREG/CR-4513 Estimation of Fracture Toughness of Cast Revision 1 I Stainless Steels During Thermal Aging in

, I LWR Systems

69 Document Title Date

8. SON-RPT-10-LRD02 Sequoyah License Renewal Project Revision 3 Aging Management Program Evaluation Report - Class 1 Mechanical Attachment 2 Calculation of Delta Ferrite for Lower Core Support Plate.

9. Change Request Form Replace control rod guide tube split pins October 15,

- D20919 Unit 1 2001

10. Change Request Replace control rod guide tube split pins April 1, 2002 Form - D20920 Unit 2

11. N-VT-8, Rev. 0010 Visual Examination of PWR Vessel November 7, Interiors and Core Support Structures 2009 Unit 2: Cycle 16

12. WCAP-17691-P DRAFT - PWR Vessel Internals Program Revision O-A Plan for Aging Management of Reactor Internals at Sequoyah Unit 2

13. CN-RIDA-12-39 Sequoyah Units 1 and 2 Lower Internals Revision 0 Hold-Down Capability Evaluation for the HDS Height Measurement

14. 0-SI-DXI-000-114.2 Augmented Examination (Unit 1) - Control May, 19,2006 ATT10 Rod Guide Tube Flexures

15. 71C62-54114-1 Sequoyah and Watts Bar Nuclear Plant January 19, Guide Tube Flexures 1984

16. WCAP-13266 Baffle-Former Bolt Program for the Revision 1 Westinghouse Owners Group - Phase 1:

Plant Categorization

17. N-VT-8 Report # 8382 - Record of Reactor Rev. 9 Vessel Examination (EVT-1 and VT-3) May 2,2006

-l:j Report # 6746 Record of Reactor Rev. 9 Vessel Examination (EVT-1 and VT-3) May 18, 2005

19. Sequoyah Nuclear Plant (SON) - Unit 2 August 10, 2005 Cycle 13 (U2C13) 90-Day Inservice Inspection (lSI) Summary Report The staff conducted its audit of LRA program elements one through six 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," and "monitoring and trending," program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP as documented in draft LR-ISG-2011-04. In addition, the staff found that for the "detection of aging effects," and "acceptance criteria" program element, sufficient information was not available to determine if they were consistent with the corresponding program elements of the GALL Report AMP as documented in draft LR-ISG-2011-04. In addition, sufficient information was not available to determine the adequacy of the applicant's responses to the ApplicanULicensee Action Items for MRP-227-A. To obtain the information necessary to confirm if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAI for the subjects discussed below.

70

• The "detection of aging effects" and "acceptance criteria" program elements of the LRA AMP states an enhancement is needed to address the physical measurements of the Unit 1 hold down spring. Action/Licensee Action Item NO.5 of MRP-227-A requires the identification of the plant-specific acceptance criteria to be applied when performing the physical measurements. The applicant's proposed enhancements does not address Action/Licensee Action Item NO.5 of MRP-227 -A and did not provide the acceptance criteria for the Unit 1 Type 304 stainless steel hold-down springs.

• The applicant's program elements did not address the Unit 2 Type 403 hold down spring and were not excluded from the scope of Applicant/Licensee Action Item NO.5 for MRP-227-A The applicant did not address the Unit 2 hold down spring made of Type 403 stainless steel in its response to Applicant/Licensee Action Item NO.5 in LRA Appendix C or justify that "loss of material - wear" and "loss of preload" are not applicable aging effects.

• Action/Licensee Action Item NO.8 states, in part, that the existing fatigue CUF analyses for reactor vessel internals shall include the effects of the reactor coolant system water environment. LRA Section 4.3 and LRA Appendix C do not address the effects of the reactor coolant system water environment as discussed in Part 5 of Action/Licensee Action Item NO.8.

• The applicant's program elements did not address the aging management of the replaced control rod guide tube (CRGT) assembly support pins (I.e., split pins) that were made from cold-worked Type 316 austenitic stainless steel materials. LRA Appendix C states that the effects of aging on these split pins will be managed in the period of extended operation based on operating experience. The applicant's approach for aging management is not appropriate based on the staff's SE, Rev. 1, for MRP-227, Applicant/Licensee Action Item NO.3 and SRP-LR Section A 1.2.3.4. In addition, it is not appropriate for the applicant to rely solely on the operating experience at other plants as a means of aging management for its split pins.

• The applicant's program elements do not address difference in material fabrication for the Control Rod Guide Tube: Guide plates/cards between MRP-227 -A and those at Sequoyah Units 1 and 2. It is not clear if the results in MRP-227 -A for the Type 304 austenitic stainless steel guide plates (cards) are applicable to the applicant's CASS guide plates/cards and if the applicant's response to AlLAI No.2 is accurate. In addition, considering that the applicant's guide plate (cards) are fabricated of CASS, this component should be evaluated as part of AlLAI NO.7 to consider the possible loss of fracture toughness due to thermal and irradiation embrittlement as a potential aging effect.

• LRA Appendix C indicates that the Unit 2 hold down spring is fabricated of Type 403 stainless steel, which is a martensitic stainless steel. Table 5-1 of MRP-191 indicates that Type 403 stainless steel hold down spring may be subject to thermal embrittlement.

Applicant/Licensee Action Item No. 7 specifically discusses the performance of a plant specific analysis for reactor vessel internal components fabricated from martensitic stainless steel materials. It is not clear if the applicant performed this analysis for the Unit 2 Type 403 hold down spring to consider the possible loss of fracture toughness due to thermal and irradiation embrittlement.

71

• The "detection of aging effects" program element of the LRA AMP states indicates that the "Existing Programs" components were taken from Table 4-9 in MRP-227-A. It is not clear if the applicant performed a review during the Integrated Plant Assessment process when developing the LRA to confirm if the components listed in Table 4-9 in MRP-227 -A encompass the plant-specific "Existing Programs" components at Sequoyah Units 1 and 2. The staff also identified discrepancies in the LRA regarding which components are "Existing Programs" and how they are managed.

During its audit, the staff reviewed the applicant's susceptibility evaluation for thermal embrittlement of the lower core support plate for Units 1 and 2. The staff noted that the applicant's evaluation determined the ferrite content for lower core support plate for Units 1 and 2 using Hull's equivalent factor equations, as documented in NUREG/CR-4513, based on the chemical compositions from the certified material test reports (CMTR). The staff also noted that the CMTRs did not indicate lower core support plate for Units 1 and 2 were niobium bearing. The staff noted that the ferrite content calculated for the lower core support plates are less then the threshold established in NUREG/CR-4513 for susceptibly to thermal embrittlement.

During the audit of the "operating experience" program element, the staff noted that the operating experience that the applicant provided-and that the staff identified in an independent database search-is representative of industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff).

The staff also audited the description of the LRA AMP provided in the FSAR Supplement. The staff verified this description is consistent with the description provided in the SRP-LR as documented in draft LR-ISG-2011-04.

Audit Results. Based on this audit, the staff verified that the "scope of program," "preventive actions," "parameters monitored or inspected," and "monitoring and trending," program element of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M16A as documented in draft LR-ISG-2011-04. The staff also identified certain aspects of the "detection of aging effects," and "acceptance criteria" program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined. In addition, the staff also identified certain aspects of the applicant's responses to the Applicant/Licensee Action Items for MRP-227 -A for which additional information or additional evaluation is required before adequacy can be determined.

Based on this audit, the staff also verified that the operating experience is representative of industry operating experience. In addition, the staff verified that the description provided in the FSAR Supplement is consistent with the description provided.

LRA AMP B.1.35, Reactor Vessel Surveillance Summary of Information in the Application. The LRA states that AMP B.1.35, "Reactor Vessel Surveillance" is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M31, "Reactor Vessel Surveillance." To verify this claim of consistency, the staff audited the LRA AMP. 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.

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

"embrittlement," "capsule," "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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-1 0-LRD02 Sequoyah License Renewal Project Aging Revision 3 Management Program Evaluation Report Class 1 Mechanical, Section 4.7, Reactor Vessel Surveillance Program

2. SQN-RPT-10-LRD09 Sequoyah License Renewal Project Operating Revision 1 Experience Review Results - Aging Management Program Effectiveness, Section 3.1.25, Reactor Vessel Surveillance Program

3. WCAP-15224 Analysis of Capsule Y from the Tennessee Revision 0, Valley Authority Sequoyah Unit 1 Reactor June 1999 Vessel Radiation Surveillance Program

4. WCAP-15320 Analysis of Capsule Y from the Tennessee Revision 0, Valley Authority Sequoyah Unit 2 Reactor December Vessel Radiation Surveillance Program 1999

5. Tennessee Valley Authority Sequoyah Unit 1, Revision 4, Pressure Temperature Limits Report July 2003

6. Tennessee Valley Authority Sequoyah Unit 2, Revision 5, Pressure Temperature Limits Report July 2003

7. SI-255 Surveillance Program for Reactor Irradiation Revision 9, Specimen 4/18/2011

8. Tennessee Valley Authority Letter to the NRC, 1/10/2013 Sequoyah Reactor Pressure Vessel Surveillance Capsule Withdrawal Schedule Revision Due to License Renewal Amendment

! 9. WCAP-17539-NP Sequoyah Units 1 and 2 Time-Limited Aging Revision 0, Analysis on Reactor Vessel Integrity March 2012 The staff conducted its audit of LRA program elements one through six 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,"

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 they it was consistent with the corresponding program element of the GALL Report AMP. To obtain the information necessary to confirm jf this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAI for the subjects discussed below.

73

• The "detection of aging effects" program element of GALL Report AMP XI.M31 states that the program withdraws one capsule at an outage in which the capsule receives a neutron fluence of between one and two times the peak reactor vessel wall neutron fluence at the end of the period of extended operation and tests the capsule in accordance with ASTM E 185-82. However, the applicant's "detection of aging effects" program element, as modified by the enhancement for the program element, does not clearly indicate that one capsule will be withdrawn and tested at a fast neutron fluence level between one and two times the peak neutron fluence projected for the end of the period of extended operation.

• In addition, the "detection of aging effects" program element of GALL Report AMP XI.M31 states that plant-specific and fleet operating experience should be considered in determining the withdrawal schedule for all capsules; the withdrawal schedule shall be submitted as part of a license renewal application for NRC review and approval in accordance with 10 CFR Part 50 Appendix H. During the audit, the staff noted that by I

letter dated January 10, 2013, the applicant submitted to the NRC its proposed changes to the surveillance capsule withdrawal schedule. However, the LRA does not address specific discussion regarding these proposed changes to the capsule withdrawal schedule. The staff found a need to clarify if these proposed changes to the capsule schedule are consistent with GALL Report AMP XI.M31.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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 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 program elements of GALL Report AMP XI.M31, "Reactor Vessel Surveillance." The staff also identified certain aspects of the "detection of aging effects" program element of the LRA AMP, 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 regarding 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 B.1.36, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Summary of Information in the Application. The LRA states that AMP B.1.36, "RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants," is an existing

74 program with enhancements that is consistent with the program elements in GALL Report AMP XI.S7, "RG. 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants." To verify this claim of consistency, the staff audited the LRA AMP. 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, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted a walkdown of the essential raw cooling water pumping station. The staff also conducted an independent search of the applicant's operating experience database using keywords: "concrete," "corrosion,"

"cracking," "erosion," "leaching," "pitting," "rus!," and "spalling."

The table below lists the documents that the staff and found to be relevant to the audit. The applicant provided these documents or the staff identified them in its search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD05 Aging Management Program Evaluation Revision 1 Report Civil/Structural (Basis Document)

2. SQN-RPT-10-LRD09 Operating Experience Review Results- Revision 1 Aging Management Program Effectiveness

3. SQN-CI-96.02 Procedure for Walkdown of Structures for Revision 1 Maintenance Rule

4. TI-4 Maintenance Rule Performance Indicator Revision 1 Monitoring, Trending and Reporting 10 CFR 50.65

5. 0-PI-ENV-000-002.0 Inspection of Ponds, Channels and Dikes Revision 0 11/23/2009

6. PER 63083 HH-52B Concrete [chipped/broken off the top 07/17/2004 southeast corner of ERCW]

The staff conducted its audit of LRA program elements one through six 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. The staff also verified that currently, water-control structures are being monitored as part of the eXisting Structures Monitoring program and that the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP described in the LRA will continue to be implemented as part of the Structures Monitoring AMP, through the period of extended operation. Therefore, the staff reviewed the Structures Monitoring AMP and verified that the elements of the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP have been incorporated in to the Structures Monitoring AMP, as recommended in the GALL Report.

75 During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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. The staff notes that the enhancements to the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program are included in the FSAR supplement as enhancements to the Structures Monitoring program.

Audit Results. Based on this 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 program elements in GALL Report AMP XI.S7, and have been incorporated into the Structures Monitoring program.

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 B.1.37, Selective Leaching Summary of Information in the Application. The LRA states that AMP B.1.37, "Selective Leaching," is a new program that will be consistent with the program elements in GALL Report AMP XI.M33, "Selective Leaching of Materials." To verify this claim of consistency, the staff audited documents associated with the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "copper," "bronze," "cast,"

"dealum," "dezinc," "dealloy," "degraph," and "leach."

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD03 Aging Management Program Evaluation Revision 3 Report Non-Class 1 Mechanical

2. SQN-RPT-10-LRD09 Operating Experience Review Results - Aging Revision 1 Management Program Effectiveness

76 During the audit of program elements one through six, 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 will be consistent with the corresponding elements of the GALL Report AMP.

The Selective Leaching program is a new program. The applicant did not cite any operating experience in the LRA. However, the applicant stated that it performed a review of operating experience and identified no occurrence of selective leaching. During the audit, the staff performed an independent search of the applicant's operating experience database using the keywords referenced above and did not find any relevant operating experience. The staff determined that the lack of relevant operating experience identified by the applicant and confirmed by the staff's 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 this description is consistent with the description provided in the SRP-LR.

Audit Results. Based on this 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 will be consistent with the corresponding program elements in GALL Report AMP XI.M33.

Based on this audit, the staff also verified that the lack of relevant operating experience is sufficient to indicate that the LRA AMP 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 6.1.38, Service Water Integrity Summary of Information in the Application. The LRA states that AMP B.1.38, "Service Water Integrity," is an existing program that is consistent with the program elements in GALL Report AMP XI.M20, "Open-Cycle Cooling Water System." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the essential raw cooling water (ERCW) pumphouse and limited portions of the intake pumping station. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "biofoul," "block," "clog," "coating," "fouling," and "service water."

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 staff's search of the applicant's operating experience database.

77 Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-1 0-LRD03 Aging Management Program Evaluation Revision 3 Report Non-Class I Mechanical, Section 4.12, Service Water Integrity

2. SQN-RPT-10-LRD08 Effects ReqUiring Management Operating Experience Review Report ll."in" Revision 0

3. SQN-RPT-10-LRD09 Operating Experience Review Results Revision 1 Aging Management Program Effectiveness, Section 3.1.27, Service Water Integrity

4. 0-PI-CEM-000-460.4 ERCW Quaternary Amine Treatment 25 Monitoring 5.0-PI-OPS-067-003.0 ERCW System Flushing for Molluscicide Revision 5 Injection, Plant Inspections, and Post Maintenance Testing

• 6.0-PI-SFT-067-004.A ERCW Train A Flushing Revision 11 7.0-PI-SFT-067-004.B CW Train "B" Train System Flush Revision 9 8.0-PI-SFT-070-002.0 rformance Testing of Component Cooling Revision 11 at Exchangers OB1, OB2 9.0-TI-SXX-000-146.0 ogram for Implementing NRC Generic Revision 3 tter 89-13

10. NPG-SPP-09.7 rrosion Control Program Revision 2

11. NA GE Power & Water Corrosion Coupon NA Guidelines

12. NA GE Corrosion Rate Guidelines for Open NA Evaporative Cooling Water Systems

13. NA GE Power &Water Weight Loss Coupons NA

14. NA GE Water & Process Raw Water Treatment February 2013 Program

15. NA System Health Report, Essential Raw Cooling 1/31/2012 Water

16. NA System Health Report, Essential Raw Cooling 5/31/2012 Water

17. NA System Health Report, Essential Raw Cooling 9/30/2012 Water

18. NA System Health Report, Essential Raw Cooling 1/31/2013 Water During the audit of program elements one through six, 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, 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 confirm if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAI for the subject discussed below.

• The "scope of program" program element of the LRA AMP states that the Service Water Integrity program addresses loss of material and fouling of components exposed to the

78 ERCW system as described in the SON response to NRC Generic Letter (GL) 89-13. It is not clear to the staff that this statement is consistent because SON-RPT-10-LRD08, "Aging Effects Requiring Management," cited a number of PERs related to loss of material caused by cavitation in raw water systems. In addition, SON-RPT-10-LRD09, Section 3.1.27, "Service Water Integrity," refers to the MIC [microbiologically influenced corrosion] and Cavitation Degradation Monitoring Program O-PI-DXX-OOO-704.1 and states that the program performs quarterly testing using ultrasonic inspections of the Raw Cooling Water (RCW) and Emergency Raw Cooling Water (ERCW) systems.

However, GALL Report AMP XI.M20 does not address loss of material due to cavitation in open-cycle cooling water systems. Since SON appears to be managing loss of material due to cavitation through the Service Water Integrity program, the AMP is inconsistent with the GALL Report. However, the LRA states that the Service Water Integrity program is consistent with AMP XI-M20, without exceptions or enhancements.

Additional information is needed by the staff in this regard.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). However, the staff determined that the operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subject discussed below.

• The staff noted a number of leaks due to erosion or MIC in its review of the operating experience at SON. In addition, the quarterly System Health Reports for the ERCW system discussed SON-08-0053, "ERCW Piping Replacement." Although SON appears to have recognized the need for a comprehensive program to address ongoing degradation in the system, the program basis documents did not provide any details regarding the scope and schedule of the ongoing ERCW piping replacement project.

Additional information is needed by the staff in this regard.

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 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 program elements in GALL Report AMP XI.M20. However, the staff identified certain aspects of the "scope of program" program element of the LRA AMP 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 regarding 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.

79 LRA AMP 8.1.39, Steam Generator Integrity Summary of Information in the Application. The LRA states that AMP B.1.39, "Steam Generator Integrity," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M19, "Steam Generator Tube Integrity." 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, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "alloy 690," "stress corrosion cracking," and "tubes."

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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. Inservice Inspection Unit 1 Cycle 18 - 180-Day Steam Generator 12/17/2012 Report Inspection Report

2. SQN-RPT-10-LRD02 Steam Generator Integrity Program Revision 3

3. NEDP-16 Steam Generator Program Revision 0013 07/31/2012

4. 1-SI-SXI-068-114.3 Steam Generator Tubing Inservice Inspection Revision 0015 and Augmented Inspections 01/20/2012

5. 2-SI-SXI-068-114.3 Steam Generator Tubing Inservice Inspection Revision 0016 and Augmented Inspections 01/20/2012

6. 1-MI-MXX-003-002.0 Steam Generator Secondary Side Revision 0005 Maintenance Activities 04/05/2011

7. 1-MI-MXX-068-005.0 Steam Generator Primary Side Maintenance Revision 0009 Activities 03/12/2012

8. 2-MI-MXX-003-002.0 Steam Generator Secondary Side Revision 0007 Maintenance Activities 04/05/2011

9. 2-MI-MXX-068-005.0 Steam Generator Primary Side Maintenance Revision 0013 04/05/2011 The staff conducted its audit of LRA program elements one through six 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 that the applicant provided-and that the staff identified in an independent

80 database search-is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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 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 program elements in GALL Report AMP XI.M19. The staff's evaluation of aspects of the program element associated with enhancements that 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, 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 8.1.40, Structures Monitoring Summary of Information in the Application. The LRA states that AMP B.1.40, "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, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. In addition, the staff conducted walkdowns of the Turbine Building, Diesel Generator Building, and Essential Raw Cooling Water pumping station.

The staff also conducted an independent search of the applicant's operating experience database using keywords: "concrete," "corrosion," "damage," "degradation," "erosion,"

"excavation," "leaching," "loss of material," "rust," and "spalling."

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 staff's search of the applicant's operating experience database.

81 Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD05 Aging Management Program Evaluation Revision 1 Report Civil/Structural (Basis Document)

2. SQN-RPT-10-LRD09 Operating Experience Review Results Revision 1 Aging Management Effectiveness

3. NPG-SPP-03.4 Maintenance Rule Performance Revision 1 Indicator Monitoring, Trending and 5/7/2012 Reporting - 10 CFR 50.65

4. SQN 111115-03 License Renewal Project Request for Revision 0 Information - Provide Results of SQN 11/15/2011 groundwater sample analysis

5. SQN-CI-96.02 Procedure for Walkdown of Structures Revision 1 for Maintenance Rule 10/4/2000

6. 0-PI-ENV-000-002.0 Inspection of Ponds, Channels and Revision 0 Dikes 11/23/2009

7. G-29B-S01 PS 4.MA.4 TVA General Engineering Specification 6/4/2010 P.S. 4.M.4A (R5) For "G-29B-S01:

ASME Section III and Non-ASME Section III (Including AISC, ANSI/ASME B31.1, and ANSI B31.5) Bolting Material"

8. SQN-RPT-10-AMC01 Aging Management Review of the Revision 3 Reactor Building 11/29/2012

9. SQN-RPT-10-AMC02 Aging Management Review of Water- Revision 3 Control Structures 11/29/2012

10. SQN-RPT-10-AMC03 Aging Management Review of the Revision 3 Turbine Building, Aux/Control Building 11129/2012 and Other Structures

11. SQN-RPT-10-AMC04 Aging Management Review of Bulk Revision 2 Commodities 11/29/2012

12. SCG-1S-596RO 2-3-4-5 Maintenance Rule Structures Inspection Revision 0

13. PER No. 25360 Turbine Building Elevation 662, the east 11/25/2003 and south walls have years of deposits

14. PER No. 74308 Ground Water Inleakage 02/04/2005

15. PER No. 212536 Turbine Building Groundwater Intrusion 12/31/2009

16. PER No. 14381 Floor Degradation, TB el 685, US 04/16/2010

17. PER No. 175878 Additional Equipment Building Concrete 04/16/2010 Structure Cracking

18. WO # 09-777570-000 Concrete Structure of Additional 3/18/2013 Equipment Building - Make Repairs to (date cracking degradation of wall grouting retrieved)

19. PER No. 275529 NRC Identified Spalling/Cracking on the 2/7/2011 outside of the Reactor Shield Wall The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

82 During the audit, the staff verified that the "scope of program," "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 "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 confirm if these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAt for the subjects discussed below.

• The "Preventive Action" program element of the LRA AMP states that the preventive actions of Section 2 of Research Council for Structural Connections (RCSC),

"Specification for Structural Joints Using ASTM A325 and A490 Bolts," have been considered in existing procedures for ASTM A325 and A490 bolting. The GALL Report AMP recommends that if structural bolting consists of ASTM A325, ASTM F1852, and/or ASTM A490 bolts, the preventive actions for storage, lubricants, and stress corrosion cracking potential discussed in Section 2 of RCSC need to be used. It is not clear that the applicant's preventive action program element is consistent with the recommendation of the GALL Report AMP XI.S6, which for preventive actions, recommends the use of RCSC specifications.

• The "Detection of Aging Effects" program element of the LRA AMP states that the inspection and evaluation personnel qualifications are consistent with industry guidelines and standards and guidance for implementing 10 CFR 50.65 and meet the intent of ACI 349.3R; however, the qualification of personnel described in the procedures does not align with those described in ACI 349.3R. The GALL Report AMP recommends that inspector qualification be consistent with industry guidelines and standards. It is not clear that the qualification of personnel will be consistent with the recommendations of GALL Report AMP XI.S6.

• The "Acceptance Criteria" program element of the LRA AMP states that the program will be enhanced to prescribe acceptance criteria considering information provided in industry codes, standards, and guidelines including NEI 96-03, ACI 201.1 R-92, ANSIIASCE 11-99, and ACI 349.3R; however, the acceptance criteria described in the procedures are qualitative and do not align with the quantitative criteria described in ACI 349.3R. The GALL Report AMP recommends that plants, who are not committed to ACI 349.3R and elect to use plant-specific criteria for concrete structures, describe the criteria and provide a technical basis for deviation from those in ACI 349.3R. It is not clear that the acceptance criteria will be consistent with that in ACI 349.3R, or if the applicant is electing to use plant-specific criteria.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that the staff identified in an 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 applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAI for the subjects discussed below.

83

• A review of plant operating experience has shown that the Turbine Building has been experiencing groundwater infiltration through degraded expansion/isolation joints for at least 16 years. During a walkdown, the staff noted water in-leakage through degraded expansion and isolation joints and cracks, and identified leaching, spalling, and rust colored stains on the Turbine Building walls; additional water seepage was observed through cracks in the basement floor. Additional information is needed to demonstrate that the turbine building reinforced concrete is appropriately age managed, that its structural integrity remains, and that the intended function will be maintained during the period of extended operation.

• During a walkdown of the spent fuel pool, the staff noted what appeared to be leaching on the outer surfaces of the spent fuel pool concrete walls, indicating past leakage of the spent fuel pool. The staff also noted that one of the leak chase channels was not collecting any leakage, which may be indicative of blockage in the channel. It is not clear if the channel system functions as intended and channels are clear and free of blockage, which could cause leakage of borated water through the floor and walls of the spent fuel pool.

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 the "scope of program," "parameters monitored or inspected," and "monitoring and trending," program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S6. The staff also identified certain aspects of the "preventive actions," "detection of aging effects," and "acceptance criteria" program elements of the LRA AMP 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 regarding 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 8.1.41, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

Summary of Information in the Application. The LRA states that LRA AMP 8.1.41, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)," is a new program that is consistent with the program elements in GALL Report AMP XI.M12, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)." 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 applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "embrittlement," "thermal aging," "casting," "CASS," "cast stainless," "cracking," "leakage," "stress corrosion cracking,"

"ferrite," and "fracture toughness"

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

The applicant provided these documents or the staff identified them in its search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SON-RPT-1 0-LRD02 Sequoyah License Renewal Project Aging Revision 3 Management Program Evaluation Report Class 1 Mechanical, Section 3.2, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) Program

2. SON-RPT-10-LRD09 Sequoyah License Renewal Project Operating Revision 1 Experience Review Results - Aging Management Program Effectiveness, Section 3.2.12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Program 3.EPRI Report Evaluation of Thermal Aging Embrittlement of January 2001 1000976 Cast Austenitic Stainless Steel Components

4. WCAP-14575-A Aging Management Evaluation for Class 1 December Piping and Associated Pressure Boundary 2000 Components i 5. Sequoyah Nuclear Plant (SON) - Unit 1 Cycle 8/4/2006 14 (U1C14) 90-Day Inservice Inspection (lSI)

Summary Report

6. Unit 1 Cycle 17 Day Inservice Inspection 2/14/2011 Summary Report

7. Unit 2 Cycle 17 Day Inservice Inspection 9/20/2011 Summary Report I

During the audit of program elements one through six, the staff verified that the "detection of aging effects," "preventive actions," "monitoring and trending," "parameters monitored and inspected," 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, 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 confirm if this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAI for the subjects discussed below.

• The "scope of program" program element of GALL Report AMP XI.M12 states that in the susceptibility screening method, ferrite content is calculated by using the Hull's equivalent factor (described in NUREG/CR-4513, Revision 1) or a staff-approved method for calculating delta ferrite in CASS materials. However, the applicant's program basis document does not clearly address if the applicant's screening method for susceptibility to thermal aging embrittlement uses the Hull's equivalent factor or a staff-approved method.

• The "scope of program" program element of GALL Report AMP XI.M12 states that for all pump casings and valve bodies greater than a nominal pipe size (NPS) of 4 inches, the

85 existing ASME Code,Section XI inspection requirements, including the alternative requirements of ASME Code Case N-481 for pump casings, are adequate; therefore, screening for susceptibility to thermal aging embrittlement is not needed. ASME Code Case N-481 , in part, addresses a flaw tolerance evaluation to demonstrate the safety and serviceability of pump casings in consideration of thermal aging embrittlement. The staff noted that by letter dated August 4, 2006, the applicant submitted its lSI summary report for Unit 1 Cycle 14. The inspection report indicates that a flaw tolerance evaluation for the reactor coolant pump casings was performed in accordance with ASME Code Case N-481. However, the LRA does not address the applicant's flaw tolerance evaluation results. Therefore, the staff needs to clarify if the applicant's evaluation for adequate flaw tolerance remains valid for the period of extended operation. Since this concern is potentially related with a time-limited aging analysis (TLAA) , the staff will consider issuing an RAI in its review of LRA Section 4.1, "Identification of Time-limited Aging Analyses."

During the audit of the "operating experience" program element, the staff's independent database search found that the operating experience that the applicant provided was representative of known industry operating experience (i.e., the applicant nor the staff identified any previously unknown aging effects).

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 if 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 applicant's FSAR supplement, in part, states that for potentially susceptible components, aging management is accomplished through qualified visual inspections, such as enhanced volumetric examination, qualified ultrasonic testing methodology, or component-specific flaw tolerance evaluation. In its review, the staff found a need that in the FSAR supplement description, "qualified visual inspections, such as enhanced volumetric examination," should be corrected to "qualified visual inspections, such as enhanced visual examination," consistent with GALL Report AMP XI.M12. The staff also noted that LRA Sections B.1.41 and 3.1.2.2.6 should correctly identify the inspection methods used in the program in a similar manner.

Audit Results. Based on this 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 program elements in GALL Report AMP XI.M12. The staff also identified certain aspects of the "scope of program" program element of the LRA AMP, for which additional information or additional 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 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.

86 LRA AMP 8.1.42, Water Chemistry Control- Closed Treated Water Systems Summary of Information in the Application. The LRA states that AMP B.1,42, "Water Chemistry Control- Closed Treated Water Systems," is an existing program with enhancements that will be 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. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using keywords: "component cooling", "CCS",

"glycol", "chilled", "corrosive," "cracking," "crevice," "degradation," "fouling," "microbiological,"

"pitting," "rust," and "stress corrosion 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 staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-10-LRD03 Aging Management Program Evaluation Revision 3 Report, Non-Class 1 Mechanical

2. SQN-RPT-10-LRD09 Operating Experience Review Results- Revision 1 Aging Management Program Effectiveness

3. SQN-RPT-10-LRD08 Operating Experience Review Report Revision 0 Aging Effects Requiring Management

4. 0-CAP-CEM-SU-003 Chemistry Trending Program Revision 0000, 06/03/2008

5. 0-PI-CEM-000-001.0 Periodic Chemistry Requirements for Revision Security Backup Diesel Generator and High 0009, Pressure Fire Protection Diesel Pump 11/02/2007 Engine Coolant

6. 0-PI-CEM-000-001.3 Periodic Chemistry Requirements for Chilled Revision Water Systems 0009, 11/02/2007

7. 0-PI-CEM-070-001.2 Periodic Chemistry Requirements for Revision Component Cooling System 0011, 04/05/2009

8. 0-PI-CEM-082-001.1 Periodic Chemistry Requirements for Revision Emergency Diesel Generator Cooling Water 0011, 06/24/2010

9. 0-SI-FPU-026-020. R Diesel Fire Pump 18-Month Inspection Revision 0008, 08/11/2010

10. 0-TI-CEM-000-001,4 Auxiliary System and Common System Revision Chemistry Specifications 0024, 12/14/2012

87 Document Title ReViSion]

Date

11. CHEM-003 Sequoyah Nuclear - Closed Cooling Water Revision 2, Chemistry StrategiC Plan 09/02/2009

12. NPG-SPP-09.7 Corrosion Control Program Revision 0002, 04/11/2012

13. PM# 063606271 Glycol system sample collection NA

14. NA The Dow Chemical Company Dowtherm 11/15/2012 SR-1/Dowfrost HD Sample Analysis Report (Glycol system Unit 1 and 2 chemistry analysis)

15. NA Auxiliary and Containment Building l,u/u".:.u12 Ventilation System Health Report 01/31/2013 I 16.NA AlC and Chillers System Health Report 10101/2012 01/31/2013

17. NA Component Cooling System Health Report 10101/20~

01/31/20

• 18. SQN-RPT-10-AMM27 Aging Management Review of the Main and Revision 2 Auxiliary Feedwater System

19. SQN-RPT-10-AMM29 Aging Management Review of Nonsafety- Revision 2 related Systems and Components Affecting Safety-related Systems The staff conducted its audit of LRA program elements one through six 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. The staff's verification of consistency included a review of the applicant's aging management activities for microbiologically-influenced corrosion (MIC). The staff had identified this subject for particular review because the LRA did not include MIC as an aging mechanism for closed treated water auxiliary systems. The staff reviewed the applicant's water chemistry procedures and verified that they include monitoring and trending of microbiological activity in closed treated water systems in accordance with EPRI Report 1007820, "Closed Cooling Water Chemistry Guideline, Revision 1," which is consistent with GALL Report guidance. The staff also noted that the applicant's water chemistry procedures include corrective actions should levels of microbiological activity fall outside of specifications.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (I.e., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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.

88 Audit Results. Based on this 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 program elements in GALL Report AMP XI.M21A.

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 8.1.43, Water Chemistry Control - Primary and Secondary Summary of Information in the Application. The LRA states that AMP B.1.43, "Water Chemistry Control- Primary and Secondary," 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 applicant's staff and reviewed onsite documentation that the applicant provided. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "chloride," "conductivity,"

"dissolved oxygen," "fluoride," "iron," "lithium," "oxygen," "sulfate," and "zinc."

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 staff's search of the applicant's operating experience database.

89 Relevant Documents Reviewed Document Title Revision I Date

1. SQN-RPT-1 0-LRD03 Aging Management Program Evaluation Revision 3 Report Non-Class 1 Mechanical

2. SQN-RPT-10-LRD09 Operating Experience Review Results Revision 1 Aging Management Program Effectiveness

3. 0-CAP-CEM-SU-003 Chemistry Trending Program Revision 0000

4. 0-TI-CEM-000-001.1 Secondary Chemistry Specifications Revision 0044

5. 0-TI-CEM-000-001.2 Secondary Chemistry Online Revision 0008 Instrumentation Specifications and Requirements

6. 0-TI-CEM-000-001.3 Primary Chemistry Specifications Revision 0066

7. 0-TI-CEM-260-011.26 Chemical Analytical Methods For Metals Revision 008 Preparation for Analysis

8. 0-TI-CEM-260-011.29 Chemical Analytical Methods for l~H Revision 0010 9.0-TI-CEM-260-011.15 Chemical Analytical Methods - Ion Revision 0016 Chromatography-Dionex Bench Systems

10. CHDP-1 System Chemistry Control Revision 0002

11. CHDP-2 Conduct of Chemistry Control Revision 0002

12. CHEM-001 Secondary Chemistry Strategic Plan Revision 0007

13. CHEM-002 Primary Water Chemistry Program Strategic Revision 0007 Plan

14. NPG-SPP-03.1 Corrective Action Program Revision 0005

15. NPG-SPP-05.3 Chemistry Control Revision 0003

16. INPO 06-007 Guidelines for the Conduct of Chemistry at Nuclear Power Stations

17. EPRI TR-104811, Molar Ratio Control Application Guidelines: January 1996 Volume 3 Hideout Return Evaluation Guidelines During the audit of program elements one through six, 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 and breakout session for the Water Chemistry Control - Primary and Secondary AMP, the staff made the following observations, or identified issues for which it needed confirmation of its understanding. These observations and issues and the applicant's confirmation are described below.

1. Parameters Monitored/Inspected The GALL Report recommends that the concentrations of corrosive impurities listed in the EPRI water chemistry guidelines be monitored to mitigate loss of material, cracking, and reduction of heat transfer, and that water quality is maintained in accordance with the guidance. The EPRI water chemistry guidelines cited in the GALL Report are EPRI 1014986 (PWR Primary Water Chemistry Guidelines-Revision 6) and EPRI 1016555 (PWR Secondary Water Chemistry Guidelines-Revision 7).

90 During the staff's review of the Aging Management Program Evaluation Report (AMPER), it noted that, in addition to the EPRI water chemistry guidelines cited above, Sequoyah Nuclear Plant stated that it also maintains water quality in accordance with the guidelines in EPRI TR-104811-V3 for secondary water. The staff reviewed EPRI 1016555 and noted that in Section 3.4.2, "Molar Ratio Control (For Recirculating Steam Generators)," EPRI refers users to EPRI TR-1 04811 for additional information relative to the application and effectiveness of molar ratio control (MRC). Additionally, EPRI 1016555 states:

MRC was introduced in Revision 3 of the Secondary Water Chemistry Guidelines as a diagnostic parameter for RSGs. It was included as a control parameter in Revisions 4 and 5 for consideration by each utility, and was included as a diagnostic parameter in Revisions 6 and 7 for those plants that adopted an MRC program. ALARA chemistry control is a requirement for adopting an MRC program.

MRC Guidelines (EPRI TR-104811) [4J were developed for utilities to use in designing a plant-specific program.

Since the EPRI Water Chemistry Guidelines references EPRI TR-104811, the applicant's use of EPRI TR1 04811 is consistent with the intent of the GALL Report.

2. Parameters Monitored/Inspected The GALL Report recommends that water quality be maintained in accordance with the EPRI water chemistry guidelines - EPRI 1014986 (PWR Primary Water Chemistry Guidelines-Revision 6) and EPRI 1016555 (PWR Secondary Water Chemistry Guidelines-Revision 7).

During its review of the AMPER, the staff noted that the implementing procedure for primary water chemistry states, "Specifications shall meet the intent of EPRI Primary Water Chemistry guidelines. Any deviation to guidelines, mandatory requirements, or shall requirements will be in accordance with RCDP-2 and documented in the Primary Strategic Plan."

The staff reviewed CHEM-002, "Primary Water Chemistry Program Strategic Plan," and noted that for any deviation from the EPRI Primary Water Chemistry Guidelines, or for those values for which a corresponding value does not exist in the EPRI Primary Water Chemistry Guidelines, the applicant documents the basis for the deviation or value.

A similar scenario exists for the secondary water chemistry program.

3. Monitoring and Trending The GALL Report recommends that chemistry parameter data be recorded, evaluated, and trended in accordance with the EPRI water chemistry guidelines. However, in the AMPER, the applicant stated that U[c]hemistry parameter data are recorded, evaluated, and trended accordance with the INPO good practices, which are consistent with EPRI water chemistry guidelines."

91 The staff reviewed 0-CAP-CEM-SU-003, "Chemistry Trending Program," which references INPO Good Practices CY-704 (lNPO 85-039), Rev. 1, "Chemistry Analytical Data Reviews." INPO 85-039 is no longer in use (by INPO) and the later 1988 INPO document has been superseded by INPO 06-007, which the applicant stated it is now using.

EPR11016555, PWR Secondary Water Chemistry Guidelines, Revision 7, states, "Additional organizational and administrative guidelines are presented in the INPO Guidelines for the Conduct of Chemistry at Nuclear Power Stations (lNPO 06-007) [8].

Utility personnel are encouraged to combine the recommendations in this chapter with the INPO recommendations when developing/revising their site-specific programs."

Additionally, in Chapter 7 of the EPRI Guidelines, it states, "ASTM and other sources have developed specific standards and guidelines for QA/QC practices that are applicable to power plant chemistry programs. The QA/QC program given in INPO 06-007 Guidelines [1] addresses chemistry control at nuclear power stations."

Based on the above, the staff verified that use of INPO 06-007 meets the intent of the EPRI Water Chemistry Guidelines.

During the audit of the "operating experience" program element, the staff determined that the operating experience that the applicant provided-and that the staff identified in an independent database search-is bounded by industry operating experience (Le., no previously unknown aging effects were identified by the applicant or the staff). The staff also determined that the operating experience that the applicant provided-and that 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 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 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, 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.