ML14071A620

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Aging Management Programs Audit Report Regarding the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2 (Tac Nos. MF1879, MF1880, MF1881, and MF1882)
ML14071A620
Person / Time
Site: Byron, Braidwood  
Issue date: 03/13/2014
From: Robinson L
License Renewal Projects Branch 1
To: Gallagher M
Exelon Generation Co
Robinson L, 415-4115
References
TAC MF1879, TAC MF1880, TAC MF1881, TAC MF1882
Download: ML14071A620 (101)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 13, 2014 Mr. Michael P. Gallagher Vice President, License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

AGING MANAGEMENT PROGRAMS AUDIT REPORT REGARDING THE BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 (TAC NOS. MF1879, MF1880, MF1881, AND MF1882)

Dear Mr. Gallagher.

By letter dated May 29, 2013, Exelon Generation Company, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating licenses NPF-37, NPF-66, NPF-72, and NPF-77 for Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, respectively, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff conducted an audit of aging management programs in three phases: from August 19-30, 2013; from October 30-31, 2013; and from December 2-6,2013 The audit report is enclosed.

If you have any questions, please contact John Daily by telephone at 301-415-3873 or by e-mail at John.Dai!y@nrc.gov, or me by telephone at 301-415-4115 or by e-mail at Lindsay. Robinson@nrc.gov.

Sincerely, Lindsay R. Robinson Project Manager, Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-454, 50-455, 50-456, and 50-457

Enclosure:

As stated cc w/encl* Listserv

LRobinson DATE 3/13/14 3/13/14 OFFICE BC:RPB1 :DLR PM RPB1 :DLR NAME YDiazSanabria LRobinson DATE 3/12/14 313/14 PM:RPB1 :DLR*

JDaily 3/12/14

Letter to M.P. Gallagher from lindsay R. Robinson dated March 13, 2014

SUBJECT:

AGING MANAGEMENT PROGRAMS AUDIT REPORT REGARDING THE BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 (TAG NOS. MF1879, MF1880, MF1881, AND MF1882)

DISTRIBUTION:

EMAIL:

PUBLIC RidsNrrDir Resource RidsNrrDirRpb1 Resource RidsNrrDirRpb2 Resource RidsNrrDirRarb Resource RidsNrrDirRasb Resource RidsOgcMaiiCenter RidsNrrPMByron Resource RidsNrrPMBraidwood Resource LRobinson JDaily DMclntyre, OPA EDuncan, Rill JBenjamin, Rill AGarmoe, Rill JMcGhee, Rill JRobbins, Rill VMitlyng, Rill PChandrathil, Rill

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket Nos:

50-454. 50-455, 50-456. and 50-457 License Nos: NPF-37, NPF-66. NPF-72, and NPF-77 Licensee:

Exelon Generation Company, LLC Facility:

Byron Station, Units 1 and 2 Braidwood Station, Units 1 and 2 Location:

Byron, Illinois (Byron)

Braceville, Illinois (Braidwood)

Dates:

August 19-30.2013 (Byron)

October 30-31.2013 (Braidwood)

December 2-6. 2013 (Braidwood)

Reviewers:

J Daily, Sr. Project Manager, Division of License Renewal (DLR)

L. Robinson, Project Manager, OLR D. Morey. Branch Chief, DLR M. Marshall. Branch Chief. DLR W. Holston, Sr. Mechanical Engineer, DLR J. Wise, Mechanical Engineer, DLR S. Cuadrado De Jesus, General Engineer, DLR C. Nickell, General Engineer, DLR A. Buford, Structural Engineer, OLR A Erickson, Structural Engineer, DLR K. Green, Sr_ Mechanical Engineer, DLR J. Gavula, Mechanical Engineer, DLR W. Gardner, General Scientist, DLR A. Obodoako, Materials Engineer, Division of Engineering (DE)

C Hunt, Chemical Engineer, DE B. Fu, Mechanical Engineer. DLR S. Min, Mechanical Engineer, DLR

0. Yee, Mechanical Engineer, DLR D. Brittner, Mechanical Engineer, DLR R. Kalikian, Materials Engineer, DLR M_ Yoo, General Engineer, DLR A. Prinaris, Structural Engineer, DLR A lstar, Structural Engineer, OLR C. Doutt, Sr. Electrical Engineer, DLR D. Nguyen, Electrical Engineer, DLR R. Li. Electrical Engineer, DLR ENCLOSURE

Approved By: Yoira Diaz-Sanabria, Chief Projects Branch 1 Division of License Renewal Dennis Morey, Chief Aging Management of Reactor Systems Branch Division of License Renewal Michael Marshall, Chief Aging Management of Structures, Electrical, and Systems Branch Division of License Renewal Introduction The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) conducted an audit in three phases: a 10-day period at the Byron Station, Units 1 and 2 (Byron), in Byron, Illinois, from August 19 to August 30, 2013; a 2-day period in Rockville, Maryland, October 30 to October 31, 2013; and a 5-day period at the Braidwood Station (Braidwood), Units 1 and 2, in Braceville, Illinois, from December 2 to December 6, 2013. The three phases compose a single audit and will be referenced throughout the report as such. The purpose of the audit was to examine the aging management programs (AMPs) and related documentation of the Exelon Generation Company, LLC, (Exelon or the applicant) to verify the applicant's claims 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 the 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 1 0) "operating experience."

Exceptions to the GALL Report AMP elements will be evaluated separately as part of the staffs review of the Byron and Braidwood 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 201 0, provides staff guidance for reviewing a 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 the audit, the staff audited AMP elements 1 through 6 and 10 ("scope of program,"

"preventive actions," "parameters monitored or inspected," "detection of aging effects,"

"monitoring and trending," "acceptance criteria," and "operating experience"). These elements of the 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 seeping and screening methodology audit conducted at Byron July 29 to August 2, 2013, and at Braidwood December 2 to December 4, 2013; the seeping and screening methodology audits are evaluated separately from this audit report During the audit, if an applicant took credit for a program in the GALL Report, the staff verified that the plant program contained 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 addition to auditing AMP elements 1 through 6 and 10, the staff also audited LRA Section 4.7.3, "Mechanical Environmental Qualification," Time-Limited Aging Analyses (TLAA)

The activities and findings associated with this TLAA are documented at the end of this report In periorming the 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, 45 AMPs were reviewed and 69 breakout (discussion) sessions with applicant representatives were conducted. This report documents the staff's activities during the audit.

LRA AMP 8.2.1.1, ASME Section Xllnservice Inspection, Subsections IWB, IWC, and IWD Summary of Information in the Application. The LRA states that AMP 8.2.1.1, "ASME Section Xllnservice Inspection, Subsections IWB, IWC, and IWD," is an existing program with an enhancement that is consistent with the program elements in GALL Report AMP XI.M1, "ASME Section Xllnservice Inspection, Subsections IWB, IWC, and IWO." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report are addressed in the SER The scope of this audit report includes the enhancement necessary to make the LRA AMP consistent with the corresponding GALL Report AMP, however, it does not consider the sufficiency of the enhancement which is not necessary for consistency, which is evaluated in the SER.

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

"crack," "leak," "leakage," "flaw," "failure," "degradation," and "weld."

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

Document 1 BB-PBO-AMP-XI.M1

2. AR 01254938
3. AR 01231119 4 AR 01357298 3 LER 455-2011-002 4 AR 00177514
5. LER 456-2011-001
16. LER-455-2009-001

~

M-02619-98 Relevant Documents Reviewed Title Program Basis Document: ASME Section Xllnservi ce Inspection, Subsections IWB, IWC and IWD lSI Program FASA

, lSI Program FASA UT l~dication on Unit 1 CRDM Nozzle #69 Licensee Event report 2011-002-00, "Unit 1 Reactor Vessel Head Penetration Nozzle Weld Flaws Attribut Pressure ed to Revision I Date Revision 1, 511/2013 08/2412011 06/29/2012 04/23/2012 5.'18/2011 Primary Water Stress Corrosion Cracking" Unit 1 RPV lower Head Condition. B1R12 Exam Res Through Wall Cracking on 1A Safety Injection Pump

-,~lt,------ic9~12~5~12~~

Discharge 04/26/2011 line Due to Outside Diameter (Transgranular) Stress Corrosion Cracking Initiated at External Diameter of Pipe

. Supplemental to Reactor Coolant System Leakage

  • Characterization Resulting 1n a Condition Prohibited by Technical SpeCifications" System Materials Analysis Department Report on the Evaluation 02/10/2010 04/08/1998 1--c--~*c-=---cc-----l-of a Safety Injection Line Failure at Byro~o-=S.::ta::cti::.o"'-------
8. LS-AA-126-1 001 F ASA Self Assessment Report Revision~

~,~~~~+-~~~---~--~

19. L TR. B. yron 2006-0009 I Submittal of Analytical Evaluation of Pressurizer SeismiC 01/11/2006 Restraint Lug lndlcat.. io:-:""---------

_j Document Title Revision I Date

~0~ EC374961 Evaluation for Indication on Shear Lugs Westinghouse NDE 04/22/2009 Report #A1 R14-MT-0001

11. LER454-2012-004 Unit 1 Reactor Pressure Vessel Head Control Rod Drive 11/12/2012 Mechanism Penetration Nozzle Weld Repair Surface Indication
12. IR 01166795 Exelon Power Lab, Evaluation of a Socket Weld Leak in 06/21/2011 Line 2CV02G-2 at Braidwood Station
13. AR 00601691 ASME XI UT Inspection Code Coverage Issues on RHR Hx 04/17/2007 Vessels

' 14. AR 00979896 NRC Identified 2A RHx Weld Indication Not Dispositioned 10/1512009 --

15 AR 00980855 Relief from PWHT not in Compliance with Code or Exelon 10/17/2009 Procedure

16. AR 01128840 ANI not Given Opportunity to Rev1ew Code Weld Package on Hx 10/21/2010
17. AR 01399058 202012-NRC Green NCV-A1 R16-lSI-UT Speed in 08/09/2012 Procedure

~-

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

"detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the "operating experience" program element, the staff determined that the operating experience provided by Byron and Braidwood is bounded by industry operating experience.

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

Audit Results. Based on this audit, the staff verified that LRA program elements "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" are consistent with the corresponding program elements in GALL Report AMP XI.M1. 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 the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated.

In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR LRA AMP 8.2.1.2, Water Chemistry Summarv of Information 1n the Apphcat1on The LRA states that AMP B.2.1.2, "Water Chemistry," is an existing program that is consistent with the program elements in GALL Report AMP XI.M2. Water Chemistry." To verify this claim of consistency, the staff audited the LRA AMP.

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

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

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

Relevant Documents Reviewed Title Revision I Date Document

1. BB-PBD-AMP-XI.M2 Water Chemistry-GALL Program XI.M2-Water Chemistry Revision 1
2. CY-AP-120-1000 Primary Strateg1c Water Chemistry Plan for Recirculating Steam Revision 010 Generator Plants 3 CY-AP-120-100 Reactor Coolant System Chemistry
Revision 018
4. CY -AP-120-2000 Secondary Strategic Water Chemistry Plan for Recirculating Revision 012 Steam Generator Plants
5. CY -AP-120-200 Recirculating Steam Generator Chemistry Revision 009
6. CY -AP-120-170 Refueling Water Storage Tank/Borated Water Storage Tank Revision 6 Chemistry
7.

Review of Primary and Secondary Cycle Chemistry-Byron December 14, 2012 Unit 1, Fuel Cycle 18, by ChemStaff L"

Review of Primary and Secondary Cycle Chemistry-Braidwood November 28, 2012 Unit1, Fuel Cycle 16, by ChemStaff, 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 that the applicant currently uses a mixed amine program-ethanolamine (ETA) and methoxypropylamine (MPA)-to control pH in secondary systems.

During the audit of the "operating experience" program element, the staff's independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience_

The staff also audited the description of the LRA AMP provided in the UFSAR 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 the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR LRA AMP 8.2.1.3, Reactor Head Closure Stud Bolting Summary of Information in the Application. The LRA states that AMP 6.2.1.3, "Reactor Head Closure Stud Bolting," is an existing program with an exception and an enhancement that is consistent with the program elements in GALL Report AMP XI.M3, "Reactor Head Closure Stud Bolting." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified, but not resolved in this report will be addressed in the SER 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. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

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

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

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

,------- Document 1 BwMP 3100-008 2 BwMP 3100-009

3. BMP3118-1
4. BMP 3118-7
5. ER-AA-330 6 ER-AA-330-001
7. ER-AA-330-002
8. ER-AA-330-009 Relevant Documents Reviewed Title Braidwood Reactor Vessel Closure Head Installation Braidwood Reactor Vessel Closure Head Removal Byron Reactor Vessel Closure Head Removal Byron Reactor Vessel Closure Head l~stallation Conduct of lnserv1ce Inspection Activities: Common Section XI Pressure Testing; Common

. In service Inspection of Section XI Welds and Components: Comma

, ASME Section XI Repair/Replacement Program; Common Revision/

Date Revision 34A Revision 21 A Revision 33 Revision 42 Revision 09 1 9 BB PBD AMP XI M3 BBS Reactor Head Closure Stud Bolting Rev1sion 01

10. AR 01061227 Byron Unit 2 Vessel He_~d Closure Bolt# 11 vs. TS Table 1 1-1 04/2512010 11 AR 00105295 Overboring of Reactor Stud Hole# 35 Counterbore

' 04/25/2:CO:C0~2---l

12. AR 01549725 PTLR Analysis Not Revised for Rx Head Stud Configuration Change 08/22/2013 f-'"'"-*_:C-cC-cE=c-O:g'c1-.,2'c75'"-c~-+-'CC,__o.,m,.,m""onwealth Edison Braidwood Unit 2 Reactor Vessel Stud# 35 09/29/1991 14_ CN-EMT-99-99 Out-of-Service Reactor Vessel Closure Stud Evaluation 04/21/1999
15. WO 95051730 Remove/Repair Stuck Rx Vessel Closure Stud 04/19/2002 j1~.

_:5_c49:c7_:2cc5 __

+L=:i=ceccoc;c'O;e-"Renewal Personnel Misinterpret Site Procedures 12/04/2013

~

Unit2 Reactor Vessel Stuck Stud Removal A2R09 Project Plan 02/08/2012 During the audit of program elements one through six, the staff reviewed 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 to establish consistency with the corresponding elements of the GALL Report AMP.

During the audit of the "operating experience" program element, the staff found that operating experience provided by the applicant in the LRA was not complete. In addition, the staff's independent operating experience search of the applicant's on site database indicated that the applicant's operating experience was not bounded by known industry operating experience.

Specifically, the applicant's database contained information related to stuck and Inoperable reactor closure studs at both Byron Unit 2 and Braidwood Unit 2_ Based on information provided by the applicant during the audit, Braidwood Unit 2's Stud No. 35 became stuck in 1991. However, the stuck stud had enough thread engagement and was fully torqued during operations until May of 1995, at which time the stud was cut at the flange level to facilitate fuel movement activities. In 2002, the applicant initiated repair activities in an effort to restore operability to Stud No. 35. The remnant of the stuck stud was bored out. However, during machining operations, the flange stud hole for Stud No. 35 was over-bored due to human error.

Further efforts to restore the threads to Stud Hole No. 35 were suspended. As a result, since 2002, Braidwood Unit 2 Stud Hole No. 35 has been exposed to borated water during refueling outages and remains inoperable.

In addition, a similar incident occurred at Byron Unit 2 in 2010 when Stud No. 11 became stuck and had insufficient thread engagement to be tensioned. After cutting approximately 5 inches from the top end of the stuck stud, the applicant decided to abandon the stuck stud in place. In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAis for the subjects discussed below.

The applicant's operating experience discussion in the LRA did not address the removed or untensioned closure studs. In addition, no information was provided in the LRA or during the audit on the root causes of the inoperable studs. Without root causes for the failures of the studs, the staff is concerned that similar failures could occur and further challenge the integrity of the respective reactor vessel heads.

The staff is concerned that the plant-specific operating experience for Braidwood Unit 2 and Byron Unit 2 is not bounded by known industry operating experience. The staff noted that the applicant's plant-specific operating experience for its closure studs is unique and may not be bounded by industry operating experience as considered in GALL Report AMP XI. M3 Therefore, the use of the GALL Report AMP may not be adequate.

The condition of the flange hole and the stuck stud in Byron Unit 2 is unknown. The staff is concerned that boric acid corrosion of the stud and the flange hole could occur and go undetected. The staff noted that boric acid concentration may increase following each plant refueling and subsequent heat-up due to potentially increasing quantities of trapped boric acid crystals.

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

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.M3.

Based on the audit, the staff also found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.4, Boric Acid Corrosion Summary of Information in the Application. The LRA states that AMP 6.2.1.4, "Boric Acid Corrosion," is an existing program that is consistent with the program elements in GALL Report AMP XI.M10, "Boric Acid Corrosion." To verify this claim of consistency, the staff audited the LRAAMP.

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

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

Relevant Documents Reviewed Document Title

/

Revis~on I Date

1. BB PBD-AMP Program Basis Document, Boric Acid Corrosion Revision 1 XI.M10
2. ER-AP 331 Boric Acid Corrosion Control (BACC) Program Revision 6
3. ER-AP-331-1001 Boric Acid Corrosion Control (BACC) Inspection Locations, Revision 6 lm~lementation and lns(:lection Guidelines
4. ER AP-331 1002 Boric Acid Corrosion Control Program Identification, Screening, Revision 7 and Evaluation
5. ER AP-331 1003 RCS Leakage Monitoring and Action Pian Revision 5 6 ER-AP 331-1005 Boric Acid Corrosion Control (BACC) Program Performance Revision 3 Indicators
7. NA Byron Bone Acid Corrosion 1" Quarter 2013 Program Health First Quarter, 2013 Report 8 NA Braidwood Boric Acid Corrosion 1' Quarter 2013 Program First Quarter, 2013 Health R~rt
9. LS-AA-126-1 001 Braidwood Station Boric Acid Corrosion Program Focused Area Revision 5 Self Assessment (FASA)

~- ER AA-330 00~

Section XI Pressure Testing Revision 11 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 made the following additional observations:

In the LRA, the applicant stated that boric acid examinations outside containment are periodically examined in accordance with the American Society of Mechanical Engineers

{ASME) Code,Section XI. The staff verified that the ASME examinations are supplemented with quarterly walkdowns of all systems containing borated water. The staff noted that procedure ER-AP-331, "Boric Acid Corrosion Control (BACC) Program,"

states that sufficient walkdowns must be performed to ensure that 100 percent of accessible borated water systems are examined in each refueling cycle.

During the staff's review of the program basis document, BB-PBD-AMP-XI.M1 0, the staff noted that the applicant's program credits the monitoring of reactor coolant system (RCS) inventory to manage boric acid corrosion. The staff reviewed procedure ER-AP-331-1003, "RCS Leakage Monitoring and Action Plan," and noted that it defines leakage action levels and the actions to be taken at each level to ensure the safe operation of the plant.

During the audit of the "operating experience" program element, the staff's independent database search for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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.M1 0.

Based on the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated_ In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Summary of Information in the Application. The LRA states that AMP B.2.1.5, "Cracking of Nickel Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components," is an existing program that is consistent with the program elements in GALL Report AMP XI.M11B, "Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components (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 provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "CRDM," "reactor vessel,"

"vessel head," "nozzle," "penetration," "weld," "stress corrosion," "thermal sleeve," and "PWSCC."

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

Program Basis Document Cracking of Nickel Alloy Components Revision 1, and Loss of Material Due of Boric Acid-Induced Corrosion in 5/6/2013

.LI c.:Re:::a::ct:::o::_r:oC~oolant Pressure Boundary Components Document Title I Revision I Date c-c~=====--+-c-------cc---cc-----cc~*=-~=-=~=-c=----_J_=~==c..:..==---j

2. BYRON 2007-0072 Licensee Event Report (LER) 455-2007-001-00, "Reactor 6/812007
3. BYRON 2008-0119 Pressure Vessel Head Control Rod Drive Mechanism Penetration Nozzle Weld Indication Due to an lmtial Construction Weld Defect Allowing the Initiation of Primary Water Stress Corrosion Cracking" Byron Station. Unit 2, 60-Day Response to First Revised NRC Order EA-03-009, "Issuance of First Revised NRC Order (EA-03-009) Establishing Interim Inspection Requirements for 121512008 Reactor Pressure Vessel Heads at Pressurized Water Reactors"

--;o-----;-~~=-E-4 Byron Ltr 2011-0082 Licensee Event Report 2011-002-00, *'Unit 1 Reactor Pressure 5/18/2011

5. Byron 2006-0134 Vessel Head Penetration Nozzle Weld Flaws Attributed to Primary Water Stress Corrosion Cracking"

---~c=-c-c-c-ccccc-c- -"-c-ccc::ccccc-----jl.

Byron Station Unit 1, 60-Day Response to NRC Bulletin 2004-1, 121612006 "Inspection of Alloy 8211821600 Materials Used on the Fabrication

~

BYRON 2010-0042

7. BYRON 2003-0114
8. AR 00615484 9 AR 01189229
10. AR 01460556 of Pressurized Penetrations and Steam Piping Connections at Pressurized Water Reactors" Byron Station Unit 2. 9Q-Day In service Inspection Report for 8/312010 Interval 3, Period 2 (B2R15)

Byron Station Unit 1, 60-Day Response to NRC Bulletin 2003-02, 1211212003 "Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity" B2R13-PT Indications Discovered at CRDM Penetration6."B'----+C'-':c=='--

B1R17 CRDM Inspection-Volumetric Ultrasonic lndicat1on 4/10/2007 3/18/2011 1/9/2013 r-c:-~-o:c;:;c~C:~---+L~R~U~F~S~A~R~TC:able 3.2-1 Thermal Sleeve Safety Class Error Loss of UT Data Above J-groove Weld on Penetrations 04 & 08_+=-':C::=C:-----

"'-.:CC:..:::=~:".C----'-'Need to Perform Thermal Sle~e~v~e~U~T'---c~-=-~ --------1--"0:::c""'-----~

11 AR 01190247

12. AR 00623331 3121/2011 4/30/2007 LR UFSAR Table 3 2-1 Thermal Sleeve Safety Class Error Braidwood Nuclear Power Station Units 1 & 2, lSI Program Plan:

Third Ten-Year ln-s~peccc~t~lo~c~l~ct~e~"'~'~'---ccc-~~-c-c-==---+'"'="-""-c-----j Byron Station Plant Review Report: Third Ten-Year lSI Program

(

AR 01460556

14.
15. BAP 1210-1T1 1/9/2013 Revision 6, 4/21/2012 Revision 11,

Plan Volume 1, Revision 6 Unit 1 RPV Lowe~, H~~ea=d~~C~o-cd~l~tio-c-.~B~1~R~1c:2~E~,-,-m--::R~e-su~l~ts--

__ -_ -----1-=':c=:c":c=---~

Exelon Powerlabs Evaluations of a 'Boat' Sample from the

16. AR 00177514 17 3/26/2011 9/2512003 5123/2007
18. L TR-MRCDA-11-67
  1. 68 CRDM Penetration on Byro~c=U~c~lt~2'--:c-c--=- --c;-c:-c-To:---c-c-Justification of Wear Indication on Inside Surface of Byron Unit 1 Revision 2, CRDM Heco:Cusec';'"9c;'==c:-ccoco;-

~~--+4:_11,_B~/2"-0"1_.1 __ __j

f-~T=ta~c~scm'ittal of L TR RIDA-12 94,cR~e=v-. 71-Penetration 69 Thermal Revision 1.

19. CCE-12-94 f-cc-c-c--:c-:-:=c:--

Sleeve 4/2712012

,_.,2~0~. ~A~R~0~1~3~5~7~2~9~B--+~U_.Tcel~cd~ication on Unit1 CRDM Penetration 69

==---+-::4~/2=312013 E

1 CR 1558555 A1R17 PT Indications in Embedded Flaw Repair of CRDM 1

.. 9114/2~-

Penetration 69

=-----t-Oe C 395417 Technical Evaluation "Disposition of Boric Acid Residues 9/09/2013 Identified on Reactor Head Components AR17 Mode 3 Exams and During Extent of Condition Examination~s* _______._l__ ____

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 provided by the applicant and identified by the staff's 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 RAls for the subjects discussed below.

During the audit, the staff noted that the applicant performed ultrasonic testing (UT) examinations of the CRDM nozzles at Byron Unit 1 in 2011 in accordance with ASME Code Case N-729-1. During the UT examination, the applicant found that CRDM nozzles Nos. 4 and 8 experienced wear as a result of the interaction with the centering pads of CRDM nozzle thermal sleeves. In addition, the staff noted that the applicant's operating experience also indicated that the loss of ultrasonic testing (UT) signal occurred above the J~groove welds on these penetration nozzles because water couplant could not make up the gap between the UT blade probe and the CRDM nozzle in the wear areas. The applicant's operating experience further indicated that it was not possible to determine the exact thickness values of the CRDM nozzles in the wear area since the zero~degree UT probe, which could measure the nozzle thickness, could not receive a UT signal due to the noted couplant issues.

As discussed above, the applicant's UT examination of the CRDM nozzles at Byron Unit 1 found that CRDM nozzles experienced wear as a result of the interactions between CRDM nozzles and CRDM nozzle thermal sleeves. LRA Table 3.1.2~2 also indicates that the thermal sleeves of reactor vessel head nozzles are subject to loss of material due to wear. However, neither the LRA nor the applicant's program basis documents clearly describes how these wear indications will be monitored and managed to maintain the intended functions of the reactor vessel head nozzle thermal sleeves.

The staff also audited the description of the LRA AMP provided in the UFSAR 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.M11B.

Based on the audit, the staff also found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP~LR.

LRA AMP 8.2.1.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

Summary of Information in the Application. The LRA states that LRA AMP 8.2.1.6, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)," is a new program that will be 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 provided by the applicant The staff also conducted an independent search of the applicant's operating experience database using the keywords: "cast," "CASS,"

"embrittlement," "thermal aging," "ferrite," "fracture toughness," and "CF8."

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

Relevant Documents Reviewed Document Title Revision I Date

1. BB PBD-AMP-Program Basis Document Thermal Aging Embrittlement of Revision 1, XI M12 Cast Austenitic Stainless Steel 513/2013 2 Byron 2011-0103 Byron Station Unit 1 90-Day lnservice Inspection Report for 7/21/2011 lnterval3, Period 2 (B1R17)
3. BAP 1210-1T1 Byron Station Plant Review Report: Byron Station 3rd Interval Revision 10, lSI Program Plan Vol. 3 lSI Selection Document," Rev. 0 9/9/2006
4. BW110012 Braidwood Station Unit1 lnservice InspectiOn Summary Report 2/412011
5. BW100010 Bcaidwood Station Unit 2 lnsecvice Inspection Sommacy Report 1

112712010

6. CRDM-01-017 Cast latch Housing 8/23/2001
7. AR 00152254 L

I Crack Identified on 1 A RH Pump_o_'_ffu_s_e_'_____ __!_l_o*_;_o3_/2_o_o_3 __ _

During the audit of program elements one through six, the staff verified that the "preventive actions." "parameters monitored or inspected," "detection of aging effects," and "monitoring and trending" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the "scope of program" and "acceptance criteria" program elements, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAis for the subjects discussed below.

The scope of program" program element of GALL Report AMP XI.M12 states that the program manages loss of fracture toughness in potentially susceptible ASME Code Class 1 piping components made from CASS. LRA Table 3.1.2-2 identifies both CASS and non-cast stainless steel as the materials used to fabricate the control rod assembly components, which include latch housing, rod travel housing, cap, and control rod drive mechanism adapter. However, the LRA does not provide any more specific information on the materials used to fabricate these different components of the control rod assembly. By contrast, Section 15.4.8.1.1, "Design Precautions and Protection" of the applicant's UFSAR states that the latch mechanism housing and rod travel housing are each a single length of forged Type 304 stainless steel. The staff needs additional information to clarify which components of the control rod assembly are made of CASS.

GALL Report AMP XI M12 "acceptance criteria" program element states that a flaw tolerance evaluation for components with ferrite content up to 25 percent is performed according to the principles associated with ASME Code,Section XI, IWB-3640 for submerged arc welds. The GALL Report also states that the flaw tolerance evaluation for piping with greater than 25 percent ferrite is performed on a case-by-case basis by using the applicant's fracture toughness data. The LRA does not address whether the applicant has any susceptible CASS components with ferrite content greater than 25 percent. In addition, the LRA does not clearly address whether the flaw tolerance evaluation for susceptible CASS components with greater than 25 percent ferrite will be pertormed on a case-by-case basis with relevant fracture toughness data.

During the audit of the "operating experience" program element, the staff determined the need for additional information. In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

LRA Section 8.2.1.6 includes a section that discusses operating experience related to the applicant's program. However, the staff noted that the operating experience discussion does not provide operating experience that is specific to the control rod assembly components and reactor coolant fittings made of CASS. The staff needs additional information regarding the operating experience which is specific to these CASS components to ensure that any previous operating experience does not identify a need to enhance the applicant's program.

The staff also audited the description of the LRA AMP provided in the UFSAR 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," and "monitoring and trending" 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" 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 the audit the staff also found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 6.2.1.7, PWR Vessel Internals Summary of Information in the Application. The LRA states that AMP XI.M16A, "PWR Vessel Internals," is a new program with an exception that will be consistent with the program elements in GALL Report AMP XI.M16A, "PWR Vessel Internals," as documented in Draft LR-ISG-2011-04, "Updated Aging Management Criteria for Reactor Vessel Internal Components of Pressurized Water Reactors." The staff noted that Final LR-ISG-2011-04 was issued by letter dated May 28, 2013, and that the revisions in the final version were to clarify and simply the guidance documented in Draft LR-ISG-2011-04. The staff further noted that the technical content and recommendations for aging management were not altered between Draft LR-ISG-2011-04 and Final LR-ISG-2011-04. The staff noted that the applicant submitted its LRA by letter dated May 29, 2013, and did not have sufficient time to amend its LRA to address Final LR-ISG-2011-04.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program. Therefore, the staffs audit addressed only the program elements described in the applicant's program basis document and the applicant's response to applicant/licensee action items (NLAI) to MRP-227 -A, which included any supporting references and documents, inspection results from previous vessel internal inspections, and Exelon's corporate procedures for a reactor vessel internals AMP. Issues identified but not resolved in this report will be addressed in the SER The staff noted that the applicant's exception was to ensure its PWR Vessel Internals Program is consistent with Draft LR-lSG-2011-04 in order to limit the impact of the issuance of Final LR-ISG-2011-04. Thus, this audit report considers the sufficiency of the applicant's exception associated with Draft LR-ISG-2011-04 and will also be evaluated in the SER Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed on site documentation provided by the applicant. The staff also conducted an independent search of the appllcant's operating experience database for Byron Station, Units 1 and 2, using keywords:

"reactor internal," "vessel internal," "split pins," "fracture toughness," and "thermal aging." In addition, the staff also conducted an independent search of the applicant's operating experience database for Braidwood Station, Units 1 and 2, using keywords: "reactor internal," "vessel internal," "split pins," "fracture toughness," "thermal aging," "lower internals," "upper internals,"

"core support structure," and "B-N-3."

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

~1 Document BB PBD-AMP-XL16A

2. AR00685151 3 AR00684704
4. EC000349590 I 5. EC000349592
6. EC00003604 73
7. EC0000360474
8. Work Order 00617445

~ARo0310817

10. Work Order 00856130
11. Exam1nat1on Results - Braidwood Umt 1
12. Examination Results-Braidwood Umt 2
13. AR00770884
14. AR01361865
15. EC0000370641

~

WcAP-13266 Relevant Documents Reviewed

( Program Basis Document Title Revi~ion I DatCl GALL Program XI.M16A PWR Revis1on 1, Internals 05/1712013 Broken leaf found on guide tube "assembly J13 0 degree 10115/2007 A1 R13 LL-Broken leafs found during split pin replacement 10/15/2007 ___

Engineering Change-Replace Control Rod Drive Support Pins with Materials Resistant to Primary Water Stress Corrosion Cracking-B~ron Unit 1/2 Engineering Change Replace Control Rod Drive Support Pins with Materials Resistant to Primary Water Stress Corrosion Cracking -

B~ron Umt 1 !2 Alloy 600 U1 RX Vessel Control Rod Guide Tube Split Pin Rep-lacements-Braidwood Unit 1 Alloy 600 U1 RX Vessel Control Rod Gu1de Tube Split Pin Reelacements-Braidwood Unit 2 Visual Exam of the Reactor Pressure Vessel Interior Includes B-N-3 Examination Results-Byron Unit 1. R13 B1 R13 Material Found at Bottom of Reactor Vessel 03/1012005 Visual Exam of the Reactor Pressure Vessel Interior Includes B-N-3 Examination Results-Byron Unit 2. R13 B-N-3 Exammat1on Results A 1 R 16 I A1R16 B-N 3 Examination Results A2R16 A2R16 l

Initial Foreign Object Search and FME Event A2R13

  • Retrieval - Foreign Object Identified Fore1gn Material Identified on Lower Core Plate 05/03/2012 Lost parts evaluation for foreign object observed on reactor 05/12/2008 vessel lower internals SUJ2~ort ledge-Braidwood Unit 2 Baffle Former Bolt Program for the Westinghouse Owners I March 1992 Grou~ Phase 1: Plant Categorization Document Title Revision I Date

~

LTR-R\\AM-13-16, Final Reports for Braidwood Unit 1, Braidwood Unit 2, Byron 06/04/2013 RevO Unit 1, and Byron Un1t 2 for PWROG PA-MSC-0983 Cafeteria 05/10/2013--~

Tasks Del1verables

18. LTR-RIAM 13-28 MRP-191 Failure Modes, Effects, and Criticality Analysis (FMECA) Impact Assessment as a Result of Alternate Materials for ~on Units 1 and 2 and Braidwood Units 1 and 2
19. Email to Gary RE: Byron and Braidwood RX Internal Questions June 20, 2012-Becknell (Exelon) from 3:33pm Charles Meyer I (W~slinghouse)
20. Design Specific Design Specification Nuclear Reactor Internals and Rev_ 6, Specification-952630 Instrumentation Port Column Assembly 1111511989
21. RE-CS-395 Conversion of Lower Core Support Cast Dome to a Flat Plate January 26, 1971 DesiQn (flat forqed plate)
22. Work Order Visual Exam of the Reactor Pressure Vessel Interior 01267563 Includes B-N-3 Examination Re~ults-Byron Unit 1, ~17
23. Work Order Visual Exam of the Reactor Pressure Vessel Interior 01481167 Includes B-N-3 Examination Results-Byron Unit 2, R17 24 ER-AP-333 Pressurized Water Reactor Internals Management Program Revision 0
25. ER-AP-333-1001 Pressurized Water Reactor (PWR) Internals Program Revision 0
26. ER-AA-335-016 VT-3 Visual Examination of Component Supports, Revision 17 Attachments and Interiors of Reactor Vessels
27. AR01433842 Reactor Upper Internals Measurement Uncertainty October31,2012
28. AR01432409 FME: Core barrel foreign object from A2R13 October 28,-2D12-removed/relocated
29. AR00685519 Metal ring found on upper internals-Braidwood Unit 1 October 16,2007 The staff conducted its audit of LRA program elements one through nine based on the contents of the new program. Aspects of the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," "corrective actions," "confirmation process," and "administrative controls" program elements of the LRA AMP associated with the exception were evaluated during this audit for the PWR Vessel Internals AMP as explained below.

During the audit, the staff verified that the "scope of program," "preventive actions," "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," "acceptance criteria," "corrective actions," "confirmation process," and "administrative controls" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP as amended by the Draft LR-ISG-2011-04 and Final LR-ISG-2011-04. Since the applicant's only exception to its PWR Vessel Internals Program was to ensure it was consistent with Draft LR-ISG-2011-04 in order to limit the impact of the issuance of Final LR-ISG-2011-04, the staff's review of the program elements included the exception. In addition, the staff found that for the applicant's responses to AILAI for MRP-227 -A, sufficient information was not available to determine whether the responses were adequate. In order to obtain the information necessary to verify whether the applicant's responses to the AILAI items are adequate, the staff will consider issuing RAis for the subjects discussed below.

The applicant's responses to AILAI No. 2 and No. 7 identifies two components (i.e., Upper Instrumentation Conduit and Supports: brackets, clamps, terminal blocks and conduit straps; and Upper Support Plate Assembly: upper support plate, flange, and upper support ring) that were fabricated of different materials than those considered in MRP-227-A. The staff noted that additional information regarding the failure modes, effects and criticality analysis, and susceptibility evaluation pertormed for these two components is needed to assess the applicant's responses.

The applicant's response to A/LA I No. 3 states there are no vendor specific requirements to inspect the replacement control rod guide tube (CRGT) split pins; however, through the station's participation in industry groups and the evaluation of industry operating experience, this position may change as warranted. Regardless, Section 3.5.2.3 of the safety evaluation (SE), Rev.1, for MRP-227-A states "it is recommended that the evaluation consider the need to replace the Alloy X-750 support pins (split pins), if applicable, or inspect the replacement Type 316 stainless steel support pins (split pins) to ensure that cracking has been mitigated and that aging degradation is adequately monitored during the extended period of operation." Since the applicant has already replaced all of its X-750 split pins at Byron and Braidwood Stations, the staff noted that additional information is needed to assess that cracking of the replacement Type 316 stainless steel support pins (split pins) has been mitigated and will be adequately managed during the period of extended operation.

The applicant's response to A/LAI No. 8, Part 5, states the Fatigue Monitoring Program will be enhanced to evaluate the effects of the reactor coolant system water environment on the reactor vessel internal components with existing fatigue cumulative usage factor (CUF) analyses to satisfy the evaluation requirements of ASME Code, Section Ill, Subsections NG-2160 and NG-3121. However, the applicant did not provide the reactor vessel internal (RVI) components that will be evaluated for environmentally assisted fatigue or the methods in which environmentally assisted fatigue will be incorporated into the existing calculations.

The staff noted that the inspection tables in LRA Appendix C include the recommended inspection outlines in MRP-227 -A for Westinghouse plants. However, the staff noted the applicant's inspection tables also include the management of additional aging effects that were not assessed in MRP-227 -A. For the management of these additional effects, the staff noted that the examination criteria/acceptance criteria are not included in these inspection tables. The staff noted that it is necessary that when inspections are performed, the appropriate examination criteria/acceptance criteria are defined for the aging effects that are managed.

The staff also noted that a potential RAI may be necessary pending industry resolution of NLAI No. 1.

During its audit, the staff confirmed in WCAP-13266 and design drawings for the baffle assembly that the reactor vessel internals design for Byron and Braidwood do not include baffle-edge bolts. During its audit, the staff also noted that Westinghouse confirmed the following components are not fabricated from CASS from a review of design drawings and certified material test reports for Byron and Braidwood:

CRGT upper flange CRGT intermediate flange CRGT bottom flange lower support plate core support column secondary core support column

~ 18 ~

During the audit of the ~operating experience" program element, the staff's independent database search for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience. In addition, the staff noted that as part of implementing MRP-227 -A, the applicant will prov1de a summary report of all inspections and monitoring, items requiring evaluation, and new repairs to be used by the MRP to compile an overall industry report to track industry progress, aid in evaluation of significant issues, identification of fleet trends, and determination of any needed revisions to MRP-227 -A The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR as amended by Draft LR-ISG~2011~04 and Final LR~ISG~2011-04.

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," "acceptance criteria," corrective actions," "confirmation process," and '*administrative controls" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XLM16A as amended by Draft LR~ISG-2011~04 and Final LR-ISG 2011-04. The staff also identified certain aspects of the applicant's response to A/LAI items for MRP-227 -A and its associated program elements of the LRA AMP for which additional information or additional evaluation is required before adequacy of the LRA AMP can be determined.

Based on the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.8, Flow-Accelerated Corrosion Summary of Information in the Application. The LRA states that AMP B.2.1 8, "Flow-Accelerated Corrosion," is an existing program that is consistent with the program elements in GALL Report AMP XI.M17, "Flow-Accelerated Corrosion." To verify this claim of consistency, the staff audited the LRA AMP Issues identified but not resolved in this report will be addressed in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database for the Byron and Braidwood Stations using the keywords related to flow-accelerated corrosion (FAG): "wall thin," "wall thick," "perforat," "min wall," "impinge," "erosi," *'flow accel," "FAC," and "cavitat."

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

1-Document BB-PBD-AMP-XI.M17 ER-AA-430 ER-AA-430-1 001 Relevant Documents Reviewed Title Program Basis Document Flow-Accelerated Corrosion Conduct of Flow Accelerated Corrosion Activities Guidelines for Flow Accelerated Corrosion Activities

~

Revision I Date Revision 1

--1-"R"'ev"'i s"'ion,.5,__-.j

_rR.evision 7 Document I

Title Revision I Date Revision 4 ER-AA-430-1 002

Feedwater Heater Shell Inspection ER-AA-430-1 004 Erosion 1n Piping and Components Guide Revision 0 NES-MS-03.1 Piping Minimum Wall Thickness Calculation Revision 5
IT-AA-101 Digital Technology Software Quality Assuranc~ Procedure Revision 8 1----- --

IT-AA-101-1001 DTSQA Classifications Revision 7 wo 01450663 FAC Activities Byron 1 Refuel18 Summary Report 07/31/12 AR 01412470 By1R18 FAC Component 1FW085B Exam Failure

' 09/13/12 AR 01415234 R2 By1R18 FAC Component SNM1DV006-1 Exam Failure 09/19/12 AR 01415327 By1R18 FAC Component 1FW085D Exam Failure 09/19/12 AR 01416484 R2 Impingement Damage on Line 1 SD01 K Elbow 09/21/12 wo 01306880 FAC Activities Byron 1 Refuel17 Summary Report 03/14/11 wo 01358402 FAC ~ctivities Byron 2 Refuel16 Summary Report 09/19/11 AR 01362960 Br1 Erosion Identified in Drain Pipe for Component Cooling Pump 05/05/12 1 CCA6AC-3/4~inch AR 00292875 Br FAG Program Documents Require Update 01/20/05 AR 00550067 A2R12 -14, Visual Inspection of Steam Generator Steam Drum 10/27/06

~1199165 Region FAC Web-Based Database Miss1ng Information 04/07/11 6200.106-01 CSI Technologies Report, Braidwood Unit1, CHECWORKS SFA Revision 0 Update for Measurem~~~_Uncertainly Recapture 6200.106-02 CSI Technologies Report, Braidwood Uni12, CHECWORKS SFA Revision 0 Update for Measurement Uncertainty Recapture During the audit of program elements one through six, the staff verified that the 'preventive actions," "parameters monitored or inspected," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the "scope of program," "detection of aging effects," and "monitoring and trending," program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAis for the subjects discussed below.

The "scope of program," udetection of acting effects," and "monitoring and trending" program elements of the GALL Report AMP recommend that the program manage carbon steel piping as described by the EPRI guidelines in NSAC-202L, "Recommendations for an Effective Flow-Accelerated Corrosion Program," Revision 2 or Revision 3. NSAC-202L states that it is directed at wall thinning caused by FAC and that it does not address other thinning mechanisms. AR 01415234 addresses FAC component SNM1 DV006-1 and notes that the wall thinning was due to droplet impingement a non-FAC aging mechanism. Also, AR 1416484 addresses the FAC examination of stainless steel component 180319 and notes impingement damage on the elbow. Although LRA Section 8.2.1.8 states that the program is consistent with GALL Report AMP XI.M17, the program, as currently implemented, includes aging mechanisms other than FAC and also manages materials other than carbon steel. Both of these aspects are inconsistent with the GALL Report AMP, and it is not clear to the staff how the applicant will resolve these inconsistencies.

LRA Section 8.2.1.8 states "for each examined component, a verified and validated web-based computer program, such as FAC Manager, is utilized in conjunction with CHECWORKS to calculate component wear, wear rate, projected thickness, and remaining life." However, the CHECWORKS and FAC Manager software programs are classified as Category DO, "Screened," which do not require any validation or verification in accordance with Exelon's software quality assurance procedure. The staff noted that NSAC-202L recommends that appropriate quality assurance be applied to all phases of the FAC program, and that plant predictive models and inspection location selections be independently checked. The staff also noted that operating experience from past LRAs included failures of FAG programs to predict wall thinning, which resulted in steam leaks.

These program failures were caused by an improper level of verification for CHECWORKS modeling data. It was not clear to the staff what level of verification is required by the applicant's implementing procedures_

During the audit of the "operating experience" program element, the staff's independent database search for the Byron and Braidwood Stations found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M17. The staff also identified certain aspects of the "scope of program," "detection of aging effects," and "monitoring and trending," 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 at Byron Station is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.9, Bolting Integrity Summary of Information in the Application. The LRA states that AMP 8.2 1.9, "Bolting Integrity,"

is an existing program with enhancements that wilt be consistent with the program elements in GALL Report AMP XI.M18, "Botting 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 staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database, using keywords: "bolt," "preload." "crack," "leak,"

"erosi," and "corros."

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

Relevant Documents Reviewed Document Title Revision I Date

1. BB-PBD-AMP-XI.M18 Program Bas1s Document, Bolting Integrity Revision 1
2. ER-AA-330-001 Section XI Pressure Testing Revision 10 --
3. ER-AA-330-002 lnservice Inspection of Section XI Welds and Components Revision 9
4. ER-AA-2030 Conduct of Plant Engineering Manual Revision 13
5. MA-MW-736-600 Torquing and Tightening of ~oiled Connections Revision 4 6 BMP 3122-4 Essential Service Water Make-up Repair Revision 16
7. BwMP 3300-091

. Lake Screen House D1ver Related Inspections

Revision 25 8 AR 01141591 2A DG Emergency Stopped Due to 011 Leak

'1111712010.-

9. ER-AA-2003 System Performance Monitoring and Analysis Rev1s1on 9 rm PMID 00174169-01 OA WW PP 10 YR Rebuild NA
11. PMID 00174170-01 08 WN PP 10 YR Rebuild NA
12. PMID 00100354 Essential Service Water Make-up Repair NA
13. PMID 00039106 Motor Driven Jockey Pump (6A FP)

NA

14. PMID 00039107 Motor Driven Jockey Pump (68 FP)

NA

15. PMID 00039099 OFP03PA-M Refurbishment NA
16. PMID 00039101 OFP03P8 6-Year Maintenance NA
17. PMID 00099262 Perform Inspection (3A FP)

NA

18. PMID 00099266 Perform Inspection (38 FP)

NA

~~-

PMID 00099267 Inspect or Replace Pump (6A FP)

NA

20. PMID 00099270 Inspect or Replace Pump (68 FP)

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 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, the staff also made the following observations regarding the inspection of bolting in submerged water environments, which is not specifically addressed in the GALL Report AMP The program description of the LRA AMP and the "scope of program" program element in the program basis document, BB-PBD-AMP-XI.M18, state that inspection of closure bolting on pressure retaining joints in submerged environments will be performed in conjunction with associated component maintenance activities. The staff reviewed maintenance documents ("PMlDs" in the table above) that describe the scheduled maintenance frequencies for the submerged components. These frequencies are as follows:

o well water system deep well pumps (Byron): 10 years o

service water pumps (Byron): 8 years o

fire protect1on pumps (Byron): 18 months (pump 3B), 5 years (pump 3A) o fire protection jockey pumps (Byron)* no defined frequency o

fire protection pumps (Braidwood): 12 years (pump 3PB), 15 years (pump 3PA) o fire protection jockey pumps (Braidwood): 3 years The staff's evaluation of the sufficiency of these opportunities to inspect the submerged bolting will be documented in the SER During the audit of the "operating experience" program element, the staff's independent database search for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided m the UFSAR 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.M18. The staff's evaluation of the applicant's management of the aging of submerged bolting. which is not discussed in the GALL Report AMP, will be addressed in the SER.

Based on the audit, the staff also verified that the operating experience at Byron and Braidwood Stations is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the program description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 6.2.1.10, Steam Generators Summary of Information in the Application. The LRA states that AMP B. 2.1.1 0, "Steam Generators," is an existing program with enhancements and an exception that is consistent with the program elements in GALL Report AMP Xl.M19, "Steam Generators." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. 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. This audit report also does not consider the sufficiency of exceptions, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "alloy 690," "alloy 600," and "tubes."

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

Relevant Documents Reviewed Document Title Revision f Date 1 88-P8D-AMP-Steam Generators Revision 1, XI.M19 05/01/2013

2. ER-AP-420-001 Byron/Braidwood Unit1 Steam Generator Eddy Current Revision 10 Activities
3. ER-AP-420 Steam Generator Management Program Revision 11
4. CY-AP-120-340
  • Primary-to-Secondary Leak Program Revision 6

~

I Document Title Revision I Date

5. CY-AP-120-1000 Primary Strategic Water Chemistry Plan for Recirculating Steam Revision 10 Generator Plants 6 CY -AP-120-2000 Secondary Strategic Water Chemistry Plan for Recirculating ReviSion 12 Steam Generator Plants 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. Aspects of the "parameters monitored or inspected" program element of the LRA AMP associated with the exception were not evaluated during the audit. Aspects of these program elements that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the "scope of program," preventive actions," detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the "parameters monitored or inspected" program element not associated with the exception are consistent with the corresponding program element in the GALL Report AMP. The staff's evaluation of aspects of this program element associated with the exception will be addressed in the SER.

During the audit of the "operating experience" program element, the staff's independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. The staff also audited the description of the LRA AMP provided in the UFSAR 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," "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 also verified that for the "parameters monitored or inspected" program element, the aspects of the LRA AMP program element not associated with the exception are consistent with the corresponding program element in GALL Report AMP XI.M19. The staff's evaluation of aspects of the program element associated with the exception will be addressed in the SER Based on the audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR LRA AMP 8.2.1.11, Open-Cycle Cooling Water System Summary of Information in the Application. The LRA states that AMP 8.2.1.11, "Open-Cycle Cooling Water System," is an existing program with an enhancement that will be consistent with the program elements in GALL Report AMP XI.M20, "Open-Cycle Cooling Water System." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER The scope of this audit report includes 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 on site documentation provided by the applicant In addition, the staff conducted walkdowns of major structures and components associated with the service water system including various pumps and heat exchangers at both Bryon and Braidwood, the essential service water cooling towers, and the river screen house at Byron. The staff also conducted an independent search of the applicant's operating experience databases using keywords: MIC," "blockage," "cooler," "heat exch," "heat trans," "coat," and "biofouL" The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date 1 BB-PBD AMP-XI.M20 Program Basis Document Open-Cycle Cooling water System Revision 1

2. ER-AA-340 GL 89-13 Program Implementing Procedure Revision 7 3 ER-AA-340-1 001 GL 89-13 Program Implementation Instructional Guide Revision 9
4. ER-AA-340-1 002 Service Water Heat Exchanger Inspection Guide Revision 5
5. ER-AA-340-2000 Balance-of-Plant Heat Exchanger Inspection. Testing, and Rev1sion 6 Maintenance Guide
6. ER-AA-5400 Buried Piping and Raw _Water Corrosion Program Guide Revision 5
7. ER-AA-5400-1001 Raw Water Corrosion Program Guide Revision 4 r-s----Bvp 800-30 Essential Service Water Fouling Monitoring Program Revision 14 *-

(GL 89-13 Program Basis Document)

9. BAP 560-3 Byron Cooling Water Chemistry Monitoring Program Revision 10 1 D. NES-MS-03.1 Piping Minimum Wall Thickness Calculation Revision 5 11 AR00092606 Corrosion/Pitting of Gasket Surface 2A DG JW Channel Head 01/28/2002 12 AR01218755 Past Inoperable Aux Feedwater Train 05/21111 ---
13. AR00950907 Inadequate Follow-Up for Failed DG Hx Coatings 08/07/09
14. W000999972-01 Examination of 1SXA9A-6" 01/31/2008
15. W001282977-01 Examination of 1 SXB7 A-8" 01/25/2010
16. W01103391 Examination of OSX97 AC-24" 04/2112010 17 W001346601 I Examination of 2SXA9A-6" 09/25/2011 18 Drawing M-946 Revision C Chem1cal Feed System Quill Design and Installation DetailS Essential Service Water (SX) Units 1 and 2 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," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff found that for the "scope of program," "detection of aging effects," and "monitoring and trending" program elements, sufficient information were not available to determine whether they were consistent with the corresponding elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAis for the subject discussed below.

The "scope of program," "detection of aging effects," and "monitoring and trending" program elements in the GALL Report AMP state that the program activities are in accordance with the applicant's docketed response to NRC Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety-Related Components.** Exelon responded to GL 89-13 on January 29, 1990, and addressed Item Ill (with respect to establishing maintenance program activities to ensure that corrosion of piping and components cannot degrade the performance of the system) by stating "[c]orrosion rates are continuously monitored with a corrator and with corrosion coupons of the appropriate metallurgy." However, the program basis document, BB-PBD-AMP-XI.M20, did not discuss these activities, and it was not clear to the staff whether Exelon's Open-Cycle Cooling Water System program would be performed in accordance with its docketed response to GL 89-13.

During the AMP audit, the staff verified that titanium alloy piping components (used in the service water system) that cite item 3.3.1-123 are constructed of a titanium material grade that is listed as not susceptible to loss of material and cracking. During the audit, the staff also noted that the plant-specific drawing states that the titanium material may be substituted with stainless steel.

During the audit of the "operating experience" program element, the staff's independent database search for Byron and Braidwood Stations found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M20. The staff identified that some aspects of the "scope of program," "detection of aging effects," and "monitoring and trending," program elements of the LRA AMP will require additional information or additional evaluation before consistency can be determined.

Based on this audit, the staff also verified that the operating experience at the Byron and Braidwood Stations is bounded by the operating experience for which the GALL Report program was evaluated In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.12, Closed Treated Water Systems Summary of Information in the Application. The LRA states that AMP B.2.1.12, "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. 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 provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "corros," "erosi," "crack," "pit,"

"microbiologic," "MIG," and "foul."

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

Relevant Documents Reviewed Document Title Revision I Date 1. BB-PBD-AMP-XLM21A Program Basis Document, Closed Treated Water Systems Revision 1 2 CY -AA-120-400 Closed Cooling Water Chemistry Revision 13

3. CY -AA-120-4000 Closed Cooling Water Chemistry Strategic Plan Revision 4
4. NA System Health Report, Byron Common Unit, Unit 1, and Unit 2 Second Quarter, Component Cooling 2013
5. NA System Health Report, Braidwood Common Unit, Unit1, and Second Quarter, Unit 2 Component Cooling 2013
6. NA Closed Treated Water Systems Program Summary, Bryon and NA Braidwood, Units 1 and 2
7. BB-AMRBD-MEAE Materials, Environments, and Aging Effects-Aging Revision 2 Management Review Basis Document
8. AR 01243542 Erosion found on the OW002CA west end condenser water box 7/2512011

~Wo 01365423 OCC01A Eddy Current Testing and Inspection 2/6/2012

10. Drawing 4618097 Byron Units 1 and 2 Component Cooling Water Heat Exc. Inlet 3/5/2007 j

and Outlet Tube Plate Assembly (Clad) 111 Drawing 878C789 Braidwood Units 1 and 2 Heat Exchanger Tube Plate Complete 611811974 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 whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAis for the subject discussed below_

The "detection of aging effects" program element of the GALL Report AMP recommends that visual inspections be conducted whenever the system boundary is opened in order to verify the effectiveness of the water chemistry controls in mitigating aging effects. In its review of implementing procedures associated with the applicant's program, the staff noted that these opportunistic inspections are not part of the existing program. The staff also noted that the applicant did not propose an enhancement to its program to include these inspections.

During the audit, the staff made the following additional observations:

The program basis document, BB-PBD-AMP-XI.M21A, states that corrosion monitoring (e.g., corrosion coupons) is not used. The program includes monthly monitoring of total iron and total copper as an indication of corrosion.

Two chemical treatments are used in the program. The staff reviewed CY-M-120-400,

Closed Cooling Water Chemistry," and confirmed that the applicant's chemical treatment approach is consistent with EPRI 1007820, "Closed Cooling Water Chemistry Guideline," Revision 1."

o A nitrite-based chemical treatment uses sodium nitrite as a carbon steel corrosion inhibitor, a filming azole (tolyltriazole) as a copper corrosion inhibitor, and sodium hydroxide for pH control.

o A glycol-based chemical treatment is used as a corrosion inhibitor and antifreeze control.

The program monitors for microbiologically-influenced corrosion (MIC); however, the applicant stated that the addition of biocides to the closed treated water systems has not been necessary. The staff reviewed CY-AA-120-400, "Closed Cooling Water Chemistry," and confirmed that MIG is monitored by measuring adenosine triphosphate (ATP), and the program includes ATP goal ranges and guidance for when measurements fall outside the range. During the audit, the staff did not identify any operating experience associated with the need to add biocides to address elevated ATP levels.

The existing program includes eddy current surveillances to detect cracking in the emergency diesel generator jacket water coolers, which are constructed of copper with greater than 15 percent zinc. The applicant stated that these surveillances are not based on operating experience with cracking of the jacket water coolers; but rather, they reflect a conservative practice. During the audit, the staff did not identify any operating experience associated with cracking of the coolers.

LRA Table 3.3.2-5 states that the component cooling water heat exchanger tube sheets are constructed of carbon or low alloy steel with nickel alloy cladding. However, during the audit, the staff reviewed drawings 4618D97 (Byron) and 878C789 (Braidwood) and confirmed with the applicant that the nickel alloy cladding is present only on the service water side of the tube sheet. The component cooling water side of the tubesheet is carbon or low alloy steel.

During the audit of the "operating experience" program element, the staff's independent database search for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement The staff verified this description is consistent with the description provided in the SRP-LR However, as discussed above, the staff will consider issuing RAis regarding the need to enhance the program to include opportunistic inspections and such an enhancement would appear in the UFSAR supplement.

Audit Results. Based on 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 program elements in GALL Report AMP XI.M21A. The staff also identified certain aspects of "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 the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In

. addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR LRA AMP 8.2.1.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summarv of Information m the AppiJcatJon The LRA states that AMP 8.2.1.13, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems," is an existing program with enhancements that win be consistent with the program elements in GALL Report AMP XLM23, ""Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems." To verify this claim of consistency, the staff audited the LRA AMP. 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 provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database for Byron and Braidwood Station using keywords:

"crane," "loss of material," and "wear."

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

Relevant Documents Reviewed Document Title Revision I Date 1 88-PBD-AMP-Inspection of Overhead Heavy load and Light Load (Related to Revision 1 XI M23 Refueling) Handling Systems Aging Management Program Basis Document 2 MA-AA-716-021 Rigging and Lifting Program lnspec!ion Procedure Revision ~2..__-

3. MA-AA-716-022

, Control of Heavy loads Program Revision 11

4. AR 00144059 Fuel handling crane problems were discovered during yearly 0210712003 crane inspection Leakage on the south bridge motor oil seals North bridge motor cover missing hold down bolts and was broken off 5 AR 00199448 Condition report on problems found during crane inspection found 01/26/2004 during yearly turbine building crane inspection
6. OBMSR HC-3 Fueling Handling Building Overhead Traveling Bridge Crane Revision 10

~

AR 00180292 Monthly/Yearly lnspectio~

Loose bolting on main steel girder rail connecting plate. This 10/09/2003 mechanical connection could cause a concern if the bolting 1----*

becomes dislodged and falls into the reactor cavity.

8. AR 00651354 NRC Concern with Bypassing FHB Crane Interlocks 07/18/2007
9. AR 00662034 Fuel Building Crane Trolley Rubbing Rail at Rail Jointffie 08/18/2007
10. AR01116777 1 Trolley Gear Box Bound and Degraded Gear Teeth 1 09123t2o1o 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 for Bryon and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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 the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.14, Compressed Air Monitoring Summary of Information in the Application. The LRA states that AMP B.2.1.14, "Compressed Air Monitoring," is an existing program with an enhancement and an exception 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. This audit report does not consider the sufficiency of the exception, which will be evaluated in the SER.

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

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

Relevant Documents Reviewed Document Title Revision I Date 1 88-PBD-AMP-Compressed Air Monitoring-GALL Program Xi.M33-Revision 1 XI.M24 Compressed Air Monitoring

~*--

Byron Action Request Report {ARs)

2. AR 00531203 I Instrument air line associated w/FW reg valves fretting 09/15/2006 3 AR 00660181 Small instrument air leak upstream of 2MS004D-I/A 08114!2007
4. AR 00719605 Loss of station air and instrument air 01/08/2008 5 AR 00883117 NRC ID'ed def tag in field that sh_?uld have been removed 02120!2009
6. AR 00884116 2ES005 instrument air line leak at elbow upstream of spring 02/23/2009
7. AR 01273458 Copper tubing line cracked at 2SD002C solenoid 10/06/2011
8. AR 01502257 Water found 18 U-2 instrument air system components/piping 1 04/15(2013 Document
9. AR 01532845 I

1 Revision I Oat~ l Title

! Significant I/ A leak near 2:c;C-cDC:2:_1c:O::_Ac__,-=--c-c:-::c-c--- __

L:c/07'-1~06:::r2:c0:_1c:3:__---j rcc-,.-cccc=c-----rcc-.

Braidwood Action Request Reports=~(A~R~s~):_ ____

ro--cc==~-

lA dewpoint measurement out "o'-f ~*p~e=c~-_..hi~g:::h _______

--lc0:::9~10:::5:::1<c20:::0:::2c_ __

~

10. 00121753

\\A leak Upstream of Valve 08/04/2005 f-c~~~~~----rC~o'-n~fl~ic'-t~B~e7tw~ec:e=n~U~F=S*A~R'a'-n-d~B=vvv==s~A~c-ce-p~ta_n_c_e~C~,i~te-,~,a----t~1~1~12~1~12~0~0~5----j

11. 00359833
12. 00426295 Elbow on Air Line Degraded 01/31/200:::7 __ --1 Instrument Air Leak Near 1 B Sl Accumulator 10/01/2007 1/A Leak Upstream of lsolatlo'-n'-;-V~a~w~e~fo~,~2~L~c=-~H=o~1=01:-----

04/23/2008

13. 00585962
14. 00678074
15. 00766438 Water in Station Air Penetration 09/23/2008

~~~~--~~~~~~~~~c-c--c---~--~~~~~--

Acceptance Criteria per BVWS 800-2 Not Met on lA Sampling 06/26/2009 00821267

16.
17. 00935919 Copper Tubing Leaking Air 12/15!2009 f-c~~~:~~----rD~e~g~,=a~da~tc:io=n=o~f~ln=s=t,=ome~n~t~A~i,~T=o~b-,n-g~W~it~h~in-1~C=v~0=1~F=A~V--ault----~=o~41~0~1~r2~0~1~1------j
18. 01005631
19. 01196316 2ES032A Instrument Air Supply Leak 05/06/20._11._ _ __,

Instrument Air Sampling Acceptance Critena Not Met 06/08/2013

20. 01212894 21 01522808 06/28/2013

==c__cc_c_ ______ _,_~IA'-"D~ew=po~i~nt=S=ampling Re-Test from 6f7-Results 22 01530460 Byron Procedures

~~~~----~-~~~~~~~=

Unit Zero Quarterly lnstrumen:::l A~i~'~T~e~st~in~9,________________

Revis1on 0

23. OBOSR IA-2
24.
25.

26 27 OBOSR IA-3 1BOSR IA-3 2BOSR IA-3 1BOSR IA-R1 Unit Zero Instrument 1}1-="~D~cy..__,.e~' T=e~s~t=in~g _____________ --------f-';R~e~'~'*~io~n'-0;---------i' Unit One Instrument Air Dryer Testing Revision 1

~~~. --

Unit Two Instrument Air Dryer Testlcng"--~-----------------+-'.R'evision 0 Instrument Air Surveillance For Refuel Outages Revision 3 Instrument Air Surveillance For Refuel Outages Revision 2

~~~~~~-+~~~~~~~~~~----------~~==~----i Instrument Air Dryer Weekly Surveillance Revision =5-----j

28. 2BOSR IA-R1
29. OBOSR IA-W1 Braidwood p~,~o~c~ed~u:::"'"::--------------

~~~70~~~----,-~,n-s~t,-,m~e~nt~A~i~,=s~a~m~p~li~ng~~R~e~q~oi,'e~m'-e~o~t~s __________________ -i~R~e~'~~'o~n~7c-____ 1 Instrument Air Dryer Weekly Surveillance Revision 11

30. BwVS 800-2 31 OBwOS IA-W1 Unit 0 Instrument Air Dryer Filter Changeout Surveillance Revision 2:'E'-1:----I

~~~~~-~~~~~~~~~~~~~-

Unit2 Instrument Air Dryer Filter Changeout Surveillance Revision 1 E1 32 BwMS 3150-004

33. BwMS 3150-005
34. BwMS 3150-006 Unil1 Instrument Air Dryer Filter Changeout Surveillance Revision 4 35 BwMP 3305-057

. Disassembly/Reassembly of Anderson Greenwood Wafer Check I Valves (Type CV1 B)

Common Procedures

  • 36. ER-AA-70'C0~-4~0=5=.-----r~C~o-m-p-,e~s~s~e~d~A~,-, M;-c'-on11ormg Agmg Management Program Rev1s1on OA Draft

:------+o-----:---c-----:-----1 37 :::M~A~-~A~A~-7=3~3~-1~0=0~1-, ---~G=-,~,d~a-n-ce for Check Valve General Visuallnspect1on I Revisi_o_n_7------~

Draft

_l__

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. Aspects of the "parameters monitored or inspected," program element of the LRA AMP associated with the exception were not evaluated during this audit. Aspects of this program element that are not associated with the exception were evaluated and are described below.

During the audit, the staff verified that the "scope of program," "preventive actions," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the "parameters monitored or inspected," program element not associated with the exception are consistent with the corresponding program element in the GALL Report AMP. The staff's evaluation of aspects of this program element associated with the exception will be addressed in the SER.

During the audit of the "operating experience" program element, the staffs independent database search for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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," "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.M24. The staff also verified that the aspects of LRA AMP program element "parameters monitored or inspected" not associated with the exception are consistent with the corresponding program element in GALL Report AMP XI.M24. The staff's evaluation of aspects of the program element associated with exception will be addressed in the SER.

Based on the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.15, Fire Protection Summary of Information in the Application. The LRA states that AMP 8.2.1.15, '"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 provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "carbon dioxide," "C02," "fire barrier," and "halon."

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

I Document

1. 88-PBO-AMP-XI M26
2. 00168282 3 00264702
4. 00365171
5. 00442526 --

Relevant Documents Rev.,i,.,e.,w,..e,.,d,_ ___ ~--~~~~

Title Revision I Date Ftre Protection-GALL Program XI.M26-Fire Protection Revision 1 Byron Action Request Reports (ARs)

RSH C02 tank \\eve I trending down 07/1912003 --

10 Ton C02 Tank Trend Shows Slow Loss of Level 10/1812004 RSH C02 Tank Level Less Than TRM Minimum 08121/2005 Turbine Bldg C02 Tank Lostng Inventory 01/1612006 Document I

Title Revision I Date

6. 00601728 Fireproof Thermafiber Insulation Impairment 03/09/2007
7. 00689994 Thermography Identifies Potential RSH CO Tank Leak 10/26/2007
8. 00616504 Degraded Sealant 04/12/2007
9. 00668957 Aggregate Review ?f Degraded Fire Barners 09107!2007

-to. 01020924 Missing Fireproofing on Structural Steel 01125/2010 11 01055128 0080461 Door Fails Semi-Annual Inspection 04/10/2010

12. 01126376 Degraded Fire Proofing 10114/2010
13. 01289049 Fireproofing on Column Outside 18 AF Pump Room Degraded 11/10/2010
14. 01145445 River Screen House C02 Tank Level Trending Down at 1% Daily 11/2812010 Braidwood Action Request Reports (ARs)
15. 00250423 I Fireproofing Needs Repa1r on Beam

-I o9/07!20o4

16. 00357743 Deficient DO Piping Fire Wrap in 2B DIG Room 07/28/2005
17. 00357752 Deficient DO Piping Fire Wrap in 1 B DIG Room 07/28/2005
18. 00571309 Small Halon Leaks @ 4 UCSR Halon Bottles 12/19/2006
19. 00696549 NOS Adverse Finding_ Inoperable and Degraded F1re Barriers 11/08/2007
20. 00760718 Upper Cable Spreading Rm Degraded Seal E0383301 04!08!2008
21. 00774899 PBI# 11243 Oegr. Struct Steel Fireproofing-U1 Cable Tunnel 05/13/2008 22 00776231 PBI #1125~ Fireproofing is Breached Exposing Web of Beam 05/15/2008
23. 00780238 Caulk Missing from Thennafiber in FireNent Barrier 05/28/2008 24 01033161 C02 Leak on 2CW158 02/19/2010
25. 01261302 Potential Fire Barrier Degradation at L-Wall 09/09/2011 Byron Procedures
26. NA Byron Units 1 & 2 Technical Requirements Manual I Revision 5 27 OBVSR 10 g_S-1 Fire Rated Assemblies Visual Inspection

. Revision~-

28. OBVSR 10.g.6-1 Fire Barrier Penetration Visual Inspection 18 Month Surveillance Revision 10 29 OBMSR 3.10.g.4 Fire Door Semi-Annual Inspection Revision 14
30. OBMSR 3.1 0. g. 7 TRM Fire Damper 18-Month Visual Inspection Revision 14
31. OBMSR 3.10 e.2 Upper Cable Spreading Room Halon 1301 Fire Protection System Revision 9 Semi-Annual Inspection
32. MA-BY-EM Upper Cable Spreading Room Halon System Actuation Revision 11 FP001-001 Surveillance
33. MA-BY-EM Diesel Generator and Day Tank Room Low Pressure C02 System Revision 8 FP003 Detection Test
34. MA-BY-EM I Unit 1 (2)B Diesel Driven Aux. Feedwater Pump Room & Day Tank Revision 8 FP004 Room Low Pressure C02 System Actuation
35. MA-BY-EM I Low Pressure C02 System Air Actuation Revision 6 FP009
36. OBOSR 10.d.2-1 j_ C02 Tank Level and Pressure Weekly Surveillance Revision 2 Braidwood Procedures
37. SwAP 1110-1 Fire Protection Program System Requirements I Revision 31 38 BwMS FP 7.1.E-1 Fire Rated Assemblies Visual Inspection Revision 5
39. MA-BR-EM Fire Barrier Penetration Visual Inspection Revision 4 00008 40 BwMS 3350-002 Semi-Annuallnspect1on of Fire Protection Program Required Fire Revision 8 Doors 41 BwMP 3300-052 18 Month Visual Inspection of All Safety Related Fire Dampers Revision 11
42. BwHS 4009-118 Upper Cable Spreading Room Halon Fire Protection System Revision 5 I

Document Revision I Date I I 43. MA-BR-EM I Title

  • Diesel Generator and Day Tank Room Low Pressure C02 System Revision 17 FP003 Air Actuation Test
44. MA-BR-EM 1 (2)8 Diesel Driven Aux. Feedwater Pump Room & Day Tank Revision 9 FP004 Room Low Pressure C02 System Air Actuation Test 45_ MA-BR-EM Upper Cable Spreading Room Low Pressure C02 System Air Revision 10 FP006 Actuation Test Common Procedures 46 CC-AA-211 I Fire Protection Program Revision 4
47. OP-AA-201-001 I Fire Marshal Tours Revision 5 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 "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 Fire Protection program AMP, the staff made the foHowing observation regarding the "parameters monitored/inspected" program element.

The GALL Report recommends periodic visual inspections and function tests be performed to examine for signs of corrosion that may lead to the loss of material of the halon/C02 fire suppression system In BB-PBD-AMP-XIM26, the applicant stated the following The BBS Fire Protection aging management program directs the periodic surveillance of the Halon and low-pressure carbon dioxide fire suppression systems within the scope of license renewal to ensure operability and reliability.

Surveillance procedures will be enhanced to include visual inspections of the external surface of the Halon and low-pressure carbon dioxide system piping and components in conjunction with functional testing of the systems. The visual inspections will be performed to examine for signs of corrosion that may lead to loss of material and to ensure that there is no blockage or obstruction of the spray nozzles.

The staff asked if the external surfaces of the C02 tank could be inspected due to insulation.

The applicant stated that the external surface of the tank could not be inspected.

The staff noted that the Byron, Units 1 and 2, Technical Requirements Manual currently requires that the function of the C02 system be demonstrated operable by verifying correct valve position every 92 days, by verifying C02 level (greater than 69% [Byron] or 70% [Braidwood] and greater than 275 psig and less than 357 psig) at least once every 7 days, by verifying valves and dampers actuate (manually and actual or simulated) at least once per 18 months, and by visually verifying each nozzle for integrity and discharge path unobstructed every 18 months.

Since a visual inspection of the tank is not possible without removing the permanent insulation, the staff asked if there is an alarm that is monitored in the control room to indicate a problem with the tank. The applicant stated that it has a tank low pressure alarm that is alarmed in the control room. The staff later confirmed this information by reviewing Appendix 5.4 to the Byron/Braidwood Nuclear Stations Fire Protection Report, Amendment 25, dated December 2012.

During the audit of the "operating experience" program element, the staffs independent database search for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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 the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.16, Fire Water System Summary of Information in the Application. The LRA states that AMP B.2.1.16, "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. Subsequent to the applicant's issuance of the LRA, the staff issued LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation." The staff evaluated the program using the revised recommendations in LR-ISG-2012-02. 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 which are not necessary for consistency and will be evaluated in the SER.

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

"bacteria," "biological," "blockage," "clog," "leak," and "microbiological influenced corrosion" The staff conducted an independent review of the Braidwood operating experience database using keywords: "bacteria," "biofoul," "block," "clog," leak," "MIC," "microbiological," and "microbiological influenced corrosion "

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

Relevant Documents Reviewed Document I

Title I Rev;s;on I Date.I Documents Reviewed During the Byron Audit 1

BB~PBD-AMP-XI.M27 Program Basis Document Fire Water System I Revision 1

2. AR 00594075 Common Cause Analysis of Piping Leaks in the Fire Protection

' 02121/2007 System - Byron [associated with LS-AA-125-1 003, Revision 1 0]

3. AR 01520239 Through Wall Leak on OFP078 06101/2013 4 AR 01199519 UT Identified Pipe Thickness Below 87.5 percent ofT nom 04108/2011

. 5. PMRQ 00160166 Sample FP Water for Biological Growth-Braidwood 0411612012

6. AR 00850094 OBWVS FP.7.1.T-1 Flawed Methodology and Acceptance 11126/2008 Criteria [Fire Protection System Flow Test - Braidwood]
7. OBOSR FP-02 Quarterly Sprinkler System Visual Inspection and Main Drain Revision 12 Test Surveillance B. OBwOS FP.3.2.Q-1 Auxiliary Building Sprinkler Systems Inspectors Test Surveillance Revision 14
9. OBwOS FP FP-AFT3 Charcoal Absorber Filter OVC02FA Manual Deluge System Revision 3 Nozzles Air Flow Test
10. 1BMSR 3.10 c.12-1 Unit 1 A-Train Diesel Fuel Oil Storage Tank Room Foam Spray Revis1on 0 Headers and Deluge Nozzles Air Flow Test
11. 1BOSR FP-BA1 Unit One System Aux Transformer Deluge System Flush Revision 5
12. Graft New Procedure 50 Year Sample Testing of Fi~e Water System Sprinkler Heads Revision A
13. OBOSR 10.c.3-1 Annual Sprinkler and Deluge System Visual Inspection and Main Revision 6 Drain Test Surveillance, Review included results of August 31, 2012, Test Results WO 01471059
14. 2006-653 UT Report for OFPC2BA-6", associated with AR 00571074 12/19/2006
15. 2011-249 UT Report for OFP13A-10"', associated with AR 01199519 04/08/2011 16 2005-345 UT Report for OFP609, associated with AR 00350620 07/06/2005 17 2007-104 Ultrasonic Thickness Testing Report for OFP07B-12"', associated 03/20/2007 with AR 00637331
18. AR 01088598 Fire Protection Sprinkler Alarm Not Clearing - Byron 07/07/2010
19. AR 01482910 Tubing for OPI-FP8039B Found Clogged-Byron 03/0412013
20. AR 00798599 OFP222G Valve Blockage-Byron 07/21/2008 Documents Reviewed During the Braidwood Audit 21 PMID 169300 Braidwood Fire protection System Decay Test [The staff also I 02/2712013 reviewed the results of the tests conducted on 02129/2012, I
22. PMID 120596 08114/2011. 08/14/2010, and 08115/2009]

Byron Fire protection System Decay Test [The staff also 1 o7to912012 reviewed the results of the tests conducted on 07111/2011.

07/13/201, and 07/14/2009]

23. AR 00093761 Failed Deluge Nozzle Air Flow Test OVAOSFD 0210212002 -.~
24. AR 00236875 Unitt DOST ]Diesel Oil Storage Tank] Room Foam Sprinkler 0711712004 Header and Deluge Nozzle Air Flow Test

~- AR 01441681 F1re Protection Leak South East of Service Building Annex 11/17/2012 26 AR 00717568 08 Fire Protection Jockey Pump Casting Rusted Through 0110212008

~: 00717951 Allowing Bypass Flow Large Amount of FP System OOS [Out of Service] or Degraded 01!03/2008 28 00130749 Deluge SAT [System Auxiliary Transformer] Testing Fail~res 11/08/2002

29. 00223406

] SAT 142-1 Deluge System Spray Nozzles Clogged 05/25/2004 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" and "preventive actions" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP (as revised by LR-ISG-2012-02). In addition, the staff found that for the "parameters monitored or inspected," "detection of aging effects," "monitoring and trending," and "acceptance criteria" program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

During the audit, the staff found examples of test results and operating experience to indicate that flow obstructions could be impacting system performance for Byron. Based on its review of plant-specific procedures and confirmation by the plant personnel during the audit, the staff noted that there are no planned internal visual inspections of sprinkler piping. In addition to the plant-specific operating experience related to potential flow obstructions, NRC Information Notice (IN} 2013-06, "Corrosion in Fire Protection Piping Due to Air and Water Interaction," contains industry operating experience concerning flow blockage in fire sprinkler piping due to buildup of corrosion products.

During the audit of the "operating experience" program element, the staff's independent Byron database search found that the operating experience provided by the applicant is not bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). In order to obtain the information necessary to determine whether 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 its search of Byron plant-specific operating experience, the staff noted that in addition to AR 00594075, AR 01520239, and AR 01199519 cited in the above Table of Relevant Documents Reviewed, 2 ARs from 2007 (00601718 and 00637331}, 4 ARs from 2006 (00551046, 00571074,00473937, 00509627}, 6 ARs from 2005 (00350620, 00328570, 00292042, 00432251, 00350620, and 00432251), 1 from 2004 (00239533),

and 3 from 2002 (00123666, 00109602, and 00107979) related to leaks in the Fire Water System. The "operating experience" program element of the Fire Water System program states that in March 2007, a common cause analysis was performed to identify any commonalities between through-wall leaks in the Fire Water System. The analysis concluded that the likely cause of the leaks was microbiologically-influenced corrosion (MIC). Enhancement No 2 addresses chemical additions to prevent or minimize MIC. In addition, the applicant used guided wave inspections to identify locations of potential wall thinning caused by MIC. It appears to the staff that the corrective actions may have been effective to date because they include both chemical treatments and inspections to appropriately identify components that should be replaced. The program basis document does not state the minimum number of inspections to be conducted.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR; however, changes to the UFSAR supplement may be necessary as a result of the above potential RAis.

Audit Results. Based on the audit, the staff verified that the "scope of program" and "preventive actions" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M27. The staff's evaluation of aspects of the program element associated with enhancements which are not necessary for consistency will be addressed in the SER. The staff also identified certain aspects of the "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.

Based on the audit, the staff also found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR; however, changes to the UFSAR supplement may be necessary as a result of the above potential RAis_

LRA AMP 8.2.1.17, Aboveground Metallic Tanks Summary of Information in the Application. The LRA states that AMP 8.2.1.17, "Aboveground Metallic Tanks," is a new program with exceptions that is consistent with the program elements in GALL Report AMP XI.M29, "Aboveground Metallic Tanks." To verify this claim of consistency, the staff audited the LRA AMP. Subsequent to the applicant's issuance of the LRA, the staff issued LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation." The staff evaluated the program using the revised recommendations in LR-ISG-2012-02. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staff's audit addressed only the program elements described in the applicant's basis document and plant-specific operating experience. 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 provided by the applicant. In addition, the staff conducted walkdowns of the condensate storage tanks (CSTs), CST valve pits, refueling water storage tank (RWST) vents and upper concrete structure, and 25,000 gallon and 50,000 gallon diesel fuel oil storage tanks (Byron only). The staff also conducted an independent search of the operating experience database using keywords: "min wall," "through wall," and "tank

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

Relevant Documents Reviewed Document I

Title j Revision I Date Documents Reviewed During Byron Audit

1. BB-PBO-AMP-Program Basis Document Aboveground Metallic Tanks Revision 1 XI M29
2. 101537-2-1 Spec# L-2878 General Elevation [CST]- Byron

, Rev1sion 1

~101537-2-14 Spec# L-2878 General Elevation [CST]- Byron

, Revision 1

4. 5-4012 General Plan [CST]- Byron Revis1on 4
5. AR 01407570 Unit 2 CST Metal Flashing has Dropped 1-1/2 inch at Top-Byr~n 08/31/2012
6. AR 01407574 Unit 1 CST Metal Flashing Needs Inspection and Re-caulking-08/31/2012 Byron
7. AR 01184976 Reapply sealant to Unit 1 CST-Byron 03/08/2011

~,

Document Title Revision I Date AR 01529489 5-Year Inspection of Unit 1 CST-Byron [including annotation 06/27/2013 that, "[!]he caulking at the bottom of the tank and the top of the tank that goes around the entire perimeter is separated or missing at multiple areas]

9. AR 0646380 Water Seepage at Botto~ of Unit1 CST-Braidwood 07/02/2007
10. AR 00684137 Unit 2 CST Water Leakage Observed at Base 10112/2007 11 AR 00667495 Water at Base at Unit 2 CST [including annotation that insulation 09104/2007 had dropped] - Byron
12. LS-AA-125-1 003 Apparent Cause-Six Buried Fire Protection Leaks have No date available Occurred at Braidwood Station Since September 2011 Documents Reviewed During Braidwood Audit
13. 09.099H1350.001 &

Letter Tank Industry Consultants to Exelon, Summary Report on 1 06/0112009 002 Weld Inspection of Primary Water Tanks OPW02TA and OPW02TB at Exelon Braidwood StaliOn

14. ED-BRW-97-0050 Internal memo, Cracks Observed in Primary Water Storage Tanks 01116/1997 (oPW02TA and TB
15. AR 00646380 Water Seepage at Bottom of Unit 1 ~ondensate Storage Tank __

07102/20~

16 AR 00667495 Water at Base of Unit 2 Condensate Storage Tank 08/27/20~7 17 AR 00767002 Unit2 Condensate Storage Tank Possible Indication in Wall 04/2412008 Above Water Line I

L" AR 01525252 Condensate Storage Tank has Several Areas Where Rain Can 06111/2013 Penetrate Top Ring The staff conducted its audit of LRA program elements one through six based on the contents of the new program. Aspects of the "scope of program," "preventive actions," and "detection of aging effects" program elements of the LRA AMP associated with the exception were evaluated during this audit.

During the audit, the staff verified that the "preventive actions" and "monitoring and trending" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP (as revised by LR-ISG-2012-02). The staff also verified that aspects of the "scope of program," '*preventive actions," and "detection of aging effects" program elements not associated with the exception are consistent with the corresponding program elements in the GALL Report AMP. The staff's evaluation of aspects of these program elements associated with the exception will be addressed in the SER. In addition, the staff found that for the "scope of program," "parameters monitored or inspected," "detection of aging effects," and "acceptance criteria" program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAis for the subjects discussed below.

The "scope of program," '"parameters monitored or inspected," and "detection of aging effects" program elements of the LRA AMP state that lagging and insulation will be removed on a sample basis to demonstrate that the lagging, roof flashing, insulation, and the sealant are effective in preventing moisture intrusion and in preventing significant loss of material to the aluminum tank external surfaces. The GALL Report AMP infers that the entire external surface of a tank is visual!y inspected; however, it does not address insulated tanks. During the audit, the staff noted that the applicant proposed to remove the tank insulation from 4 1-square-foot locations equidistant around the tank circumference at the base of each tank and 4 1-square-foot locations equidistant 18 inches above the tank base and offset from the lower inspections. The staff noted that the tanks have several attachments (e.g., instruments, heaters, ladders) that penetrate the insulation and jacketing. The penetrations represent locations of higher susceptibility to rain water intrusion; and therefore, inspection locations should be selected accordingly.

As stated in the "operating experience" program element, the CSTs at both Byron and Braidwood have either lost jacketing integrity or water was noted at the base of the tank from rain water penetrating down between the jacketing, insulation, and the tanks' outside surface.

During the audit, the staff noted that the tank insulation consists of foam glass insulation and fiberglass insulation. The staff lacks sufficient information to conclude that this insulation is chloride and halide free. Chlorides and halides could cause pitting and cracking in aluminum tanks. In addition, Byron's cooling towers are treated with a chlorine-based chemical. At Braidwood, an apparent cause evaluation of leaks in buried fire protection piping notes that for a segment of stainless steel piping, LS-AA-125-1003: "[w]here the coating was disbanded, severe external pitting was identified, which included the location of the leak." This indicates the potential presence of chloride or halides in the soil and atmosphere at Braidwood because pitting in stainless steel material typically only occurs in the presence of chlorides or halides.

Based on the potential for chloride contamination from the atmosphere or tank insulation, it is not clear to the staff that inspecting 16 1-square-foot locations will be adequate to provide reasonable assurance that the tanks' current licensing basis intended function(s) will be met during the period of extended operation. In addition, if chlorides are present, visual inspections may not be sufficient to detect cracking.

Further, if cracking could be an applicable aging effect, the "acceptance criteria" program element should have acceptance criteria for cracks.

There have been several instances of OE related to age-related degradation of tanks.

Tanks with defects variously described as wall thinning, pinhole leaks, cracks, and through-wall flaws have been identified by detecting external leakage rather than through internal inspections. None of the leaks or degraded coatings has resulted in a loss of intended function; however, the number of identified conditions adverse to quality and the continued aging of the tanks indicate a need to ensure that internal tank inspections are conducted throughout the PEO. In addition, the staff identified an indoor tank with external stress corrosion cracking (SCC) that, except for its location, would normally be within the scope of GALL Report AMP XI.M29. As such, in regard to the recommendations in the revised GALL Report Xl.M29, the staff position is as follows:

a.

Most water-filled indoor tanks are currently managed by GALL Report AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," and GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components." Neither of these AMPs has a recommendation to conduct periodic volumetric examinations of the bottom of the tank or internal inspections. Based on industry OE, the staff believes that some indoor tanks should have internal inspections. These include indoor welded storage tanks that meet a(( of the following criteria:

1.

have a large volume (i.e., greater than 100,000 gallons)

11.

are designed to near-atmospheric internal pressures iii.

sit on concrete IV.

are exposed internally to water

b.

Periodic inspections of the tank's bottom surface should be conducted (i.e., each 1 0-year period starting 10 years before the period of extended operation) unless there is a basis for conducting a one-time inspection. The basis could be established based on soil sampling demonstrating that the soil under the tank is not corrosive or the bottom of the tank is cathodically protected.

During the AMP audit, the staff could not conclude that there were no indoor tanks meeting the above criteria In addition, the staff noted that the applicant had proposed to conduct tank bottom ultrasonic inspections within 5 years prior to entering the period of extended operation; between years 5 and 1 0 of the period of extended operation; and, whenever a tank is drained.

During the audit of the "operating experience" (OE) program element of the LRA, the staff determined that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (e.g., no previously unknown aging effects were identified by the applicant or the staff). In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

Based on a search of the applicant's corrective action database, an indication exists in the tank wall above the water line of the Braidwood Unit 2 CST. The applicant's evaluation of the indication is as follows:

As discussed in the original followup, the indication appears to start away from the edge of the top plate element. stays in a straight line configuration down to the seam weld, projects over the surface of the weld, then changes to a curved shape below the seam weld until it stops approximately even with the bottom flange of the roof support structural member. In addition, it appears by color/darkness changes that the width of the indication changes. These characteristics, along with the apparent width on the photos, do not represent a normal crack profile or propagation path. Also of note is the fact that this is the first internal inspection performed on the Unit 2 CST. This indication has most likely existed for the life of the tank.

During the audit, the applicant stated that it would be conducting a follow-up internal visual inspection of the tank to determine if the indication has grown. The GALL Report recommends that a one-time inspection be conducted for the internal surfaces of an aluminum tank exposed to treated water. However. with a known indication as described above, periodic inspections would be appropriate if the indication is not repaired prior to the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR, pending resolution of the above RAls.

Audit Results. Based on this audit, the staff verified that the "preventive actions" and "monitoring and trending" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M29. The staff's evaluation of

aspects of the program elements associated with exceptions will be addressed in the SER. The staff also identified certain aspects of the "scope of program," "parameters monitored or inspected," "detection of aging effects," and "acceptance criteria" program elements of the LRA AMP for which additional information or additional evaluation is required before a determination can be determined.

Based on the audit, the staff also found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.18, Fuel Oil Chemistry Summary of Information in the Application. The LRA states that AMP 6.2.1.18, "Fuel Oil Chemistry," is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M30, "Fuel Oil Chemistry." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP; however, it does not consider the sufficiency of enhancements which is 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 provided by the applicant. In addition, the staff conducted walk downs of the diesel generator fuel oil storage tanks, day tanks, and fire protection fuel oil tanks. The staff also conducted an independent search of the applicant's operating experience database using keywords: "Fuel Oil," 'Tanks," and "Diesel Fuel."

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

Relevant Documents Reviewed Document Title Revision I Date

1. ASTM 0975 Standard Specification for Diesel Fuel Oils 988 Braidwood 068 Byron TASTM 04057 Standard Practice for Manual Sampling of Petroleum and 04057 95 Petroleum Products
3. Technical Diesel Fuel Oil (Byron)

Amendments 1 06 Specification 3.8.3 and 171

4. Technical Diesel Fuel Oil (Braidwood)

Amendments 98 and Specification 3.8 3 165

  • 5 GALL Report Generic Aging Lessons Learned Revision 2
6. LRA License Renewal Application Revision 1
7. Technical Diesel Fuel Testing program (Byron)

Revision 52 Requirement Manual, La~p~p~eo~d~;,_M ______ _l ---------------------------------- ---~----------- J

~pendixM

8. Technical Diesel Fuel Testing program (Braidwood)

Revision 48 Requirement Manual, Document Title Revision f Date

9. Program Basis Fuel Oil Chemistry Revision 1 Document BYRON
10. Action Request NRC Identified Small Zero Shift of DP Indication 1 o3/1812oo7
11. Action Request Industrial Safety 0/G Fuel Oil Tank Sampling
06/29/2008
12. Act1on Request Corrosion on Diesel Fuel Offload Valve 10/30/2008
13. Action Request Small Fuel Oil Leak 08 Diesel Driven ~ire Pump 01/0812010 14 Action Request OB Fire Protection Oil Storage Tank Needs Cleaned 10/02/2010
15. Action Request Process Hole that May Bypass TS Surveillance 02/2112011 BRAIDWOOD
16. AR 00081421 Elevated particulate in tank 11/02/2001
17. AR 00112838 High Particulate found in monthly 00005! fuel oil sample 12/07/2001
18. AR00117114 Diesel Driven Fire pump Fuel Oil Storage Tank high Particulate 07/26/2002
19. AR 00277549 Elevated Particulate in OD005t 06!24!2005
20. AR 00666772 Inconsistent Diesel Fu~~ Sample for the 1 D002TA Tank 08/31/2007 21 AR 00834613 Excessive ~1odiesel Rejects Diesel Fuel Delivery 12/23/2008 --
22. AR 00876981 Elevated Particulate in 2D002TB Fuel Oil Sample 02/05/2009
23. BWOSR 3.8.3.2-Braidwood Sampling Methodology Rev 4 1
24. 1 BOSR 8.3.3-1 Byron Sampling Methodology Rev. 1
25. BB-PBD-AMP-Table of Tank Inspection Frequencies pg. 43 to 45 Rev. 1 XI.M30 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 for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP Xl.30. The staff's evaluation of aspects of the program elements associated with enhancements will be addressed in the SER.

Based on the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.19, Reactor Vessel Surveillance Summary of Information in the Application. The LRA states that AMP 8.2.1.1 9, "Reactor Vessel Surveillance," is an existing program with an enhancement 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 the enhancement necessary to make the LRA AMP consistent with the corresponding GALL Report AMP; however, it does not consider the sufficiency of the enhancement which is 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 on site documentation provided by the applicant The staff also conducted an independent database search of the applicant's operating experience database using the keywords: "reactor pressure vessel," "reactor vessel," "surveillance," "capsule," "fluence," and "embrittlement" The table below lists the documents which were reviewed by the staff and were found relevant to the audit These documents were provided by the applicant or were identified in the staffs search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date 1 BB-PBD-AMP-Program Basis Document. Reactor Vessel Surveillance Revision 1, XI.M31 5/3/2013 2 AR 00684551 10/14/2007 Postpone RPV Specimen Removal To A1 R14

~. AR 00734399 Postpone Unit 2 RPV Specimen Removal !O A2R14 2/11/2008

4. ER-AA-370 Reactor Coolant Pressure Boundary (RCPB) Integrity Revision 8
5. WCAP-17250-Ex-Vessel Neutron Dosimetry Program for Byron Unit 1 Cycle 16 Revision 0, NP September 2010
6. WCAP-17194-Ex-Vessel Neutron Dosimetry Program for Braidwood Unit 1 Cycle 14 Revision 0, NP March 2010
7.

Byron Unit 1 Pressure and Temperature Limits Report (PTLR)

' December 2006

' i 8 Byron Unit 2 Pressure and Temperature Limits Report (PTLR)

December 2006

9.

Braidwood Unit 1 Pressure and Temperature Limits Report (PTLR)

Revision 4

10.

Braidwood Unit 2 Pressure and Temperature Limits Report (PTLR)

Revision 4

11. RS-11-099
  • Request for License Amendment Regarding Measurement Uncertainty 6/2312011 Recapture (MUR) Power Uprate
12. RS-11-169 Additional Information Supporting Request for License Amendment Regarding 1111/2011 Measurement Uncertainty Recapture Power Uprate
13. WCAP-15316 Analysis of Capsule W from Commonwealth Edison Company Braidwood Revision 1, Unit 1 Reactor Vessel Radiation Surveillance Program December 1999
14. WCAP-15369 Analysis of Capsule W from Commonwealth Edison Company Braidwood Revision 1, Unit 2 Reactor Vessel Radiation Surveillance Program March 2000
15. WCAP-15123 Analysis of Capsule W from Commonwealth Edison Company Byron Unitt Revision 1, Reactor Vessel Radiation Surveillance Program January 1999 Document Title Revision I Date
16. WCAP~15176 Analysis of Capsule X from Commonwealth Ed1son Company Byron Unit 2 March 1999 Reactor Vessel Radiation Surveillance Program 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 "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 whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing a RAI for the subject discussed below.

Appendix H to 10 CFR Part 50 states, "Surveillance specimen capsules must be located near the inside vessel wall in the beltline region so that the specimen irradiation history duplicates, to the extent practicable within the physical constraints of the system, the neutron spectrum, temperature history, and maximum neutron fluence experienced by the reactor vessel inner surface." GALL Report AMP XI.M31 recommends that one capsule be withdrawn at an outage in which the capsule has received 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. The LRA does not contain information regarding the withdrawal and testing of a surveillance capsule, consistent with GALL Report AMP XI.M31. In addition, the staff noted discrepancies in neutron fluence values between the LRA and previous submittals.

During the audit of the "operating experience" program element, the staff determined that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (e.g., 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 UFSAR. 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.M31. The staff's evaluation of aspects of any program element associated with the enhancement which is not necessary for consistency, will be addressed in the SER. 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 the 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 UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.20, One-Time Inspection Summary of Information in the Application. The LRA states that AMP 8.2.1.20, One-Time Inspection," is a new program that will be consistent with the program elements in GALL Report AMP Xl.32, "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 on site documentation provided by the applicant. 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 were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision I Date

1. ASME Boiler and Rules for In-service Inspection of Nuclear Power Plant July 1, 2003 Pressure Vessel Code ComponentsSection XI, Division 1 2_ EPRI Material Reliability Program: Inspection Standards for PWR July 2009 Report TR-1016609 Internal
3. EPRI Nondestructive Evaluation: Update on License Renewal November 2011 Report TR-1 022931 One-Time Inspection and Best NDE practices
4. ER-AA-335-004 Ultrasonic (Ul) Measurement of Material Thickness and Revis1on 6 Interfering Conditions
5. ER-AA-335-038 Examination of Non-Magnetic Heat _Exchanger Rev1s1on 3
6. ER-AA-700-302 One-Time Inspection Program Draft Revision Oa 7 ER-AA-700-301 One-Time Inspection Program Draft Revision Oa
8. BY-SSBD-OTI BYRON-One-Time Inspection Sample Basis Document Draft Revision 0
9. BB-PBD-AMP-BYRON and BRAIDWOOD-Program Basis Document Revision 1 XLM32 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's independent database search for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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 Xl.32.

Based on the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.21, Selective Leaching Summary of Information in the Application. The LRA states that AMP 8.2.1.21, "Selective Leaching," is a new program that is consistent with the program elements in GALL Report AMP XI.M33, "Selective Leaching." To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staff's audit addressed only the program elements described in the applicant's basis document.

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

"degraph," and "leach."

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

Relevant Documents Reviewed Document Title Revision I Date 1 88-P8D-AMP-Selective Leaching-GALL Program XI.M33-Selective Leaching Revision 1 XI M33 Byron Procedures

2. ER-8Y-700-401

! Guidance for Performing Selective Leaching Inspections (Level 2 Revision a

-Reference Use)

3. BY-SSBD-SLI, Draft 1 Selective Leaching Inspection Sample Basis Document Revision 0 Braidwood Procedures
4. ER-BR-700-401 Guidance for Performing Selective Leaching Inspections (Level 2 Revision a

-Reference Use)

5. BR-SSBD-SLI, Draft Selective Leaching Inspection Sample Basis Document Revision 0 Common Procedures
6. ER-M-700-401 L1cense Renewal Selective Leaching Program (Level 3-Revision 0 Information Only)

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.

The Selective Leaching program is a new program. The applicant did not cite any operating experience in the LRA for Byron and Braidwood; it identified only one instance of selective leaching that occurred on a potable water brass fitting on a supply line for one of the toilets in the New Training Building, which is not within the scope of license renewal.

During the audit, the staff performed an independent search of the applicant's operating experience database for Byron and Braidwood using the keywords cited earlier and did not find

I any relevant operating experience. The staff determined that the lack of relevant operating experience identified by the applicant and confirmed by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, when implemented by the applicant, will be sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the UFSAR 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.M33.

Based on the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 6.2.1.22, One-Time Inspection of ASME Code Class 1 Small-Bore Piping Summary of Information in the Application. The LRA states that AMP B.2.1.22, "One-Time Inspection of ASME Code Class 1 Small-Bore Piping," is an existing program that is consistent with the program elements in GALL Report AMP X1.M35, "One-Time Inspection of ASME Code Class 1 Small-Bore Piping." To verify this claim of consistency, the staff audited the LRA AMP.

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

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

"failure," "socket," "butt," thermal," "fatigue," and "leakage."

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

Relevant Documents Reviewed Document Title Revision I Date

  • 1 88-PBD-AMP-One-Time Inspection of ASME Code Class 1 Small-Bore Piping Revision 1, XLM35 Program Basis Document 05/1712013
2. AR 01166795 Periorm investigation per MRC on 02/07/11 03/04/2011
3. LER 455-2011-002 Licensee Event report 2011-002-00, "'Unit 1 Reactor Pressure 5/18/2011 Vessel Head Penetration Nozzle Weld Flaws Attributed to Primary Water Stress Corrosion Cracking**
4. AR 00177514 Unit 1 RPV Lower Head Condition, B1R12 Exam Results

' 9125/200~-

5. LER 456-2011-001 Through Wall Cracking on 1A Safety Injection Pump Discharge 04/2612011 line Due to Outside Diameter (Transgranular) Stress Corrosion Cracking Initiated at External Diameter of Pipe
6. LER-455-2009-001 Supplemental to "Reactor Coolant System Leakage 02110/2010 I Characterization Resulting in a Cond1tion Prohibited by Technical Specifications" Document Title Revision I Date
7. M-02619-98 System Materials Analysis Department Report on the Evaluation 04/08/1998 of a Safety Injection Line Failure at Byron Station
8. AR 01166795 01/25/2011 2CV8409 Piping (Boric Acid Accum., ln~estigate Source) g_ wo 01405325

, M2-2CV8409 Cut Out Weld and Replace Valve 02/24/2011

.~R o1zo9a4a

' 2CV048-3" (Further Actions Required Boric Acid Leakage 04/29/2011 l11 Investigation)

BRW-47115 Evaluation of a Socket Weld Leak in Line 2CV02G-2" at 06/21/2011 J

Braidwood Station 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 whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAis for the subjects discussed below.

During the audit, the staff noted that the LRA section does not provide the weld populations. It is not clear to the staff how the inspection sample would be selected.

The staff noted that the LRA should provide the population of in-scope small-bore piping welds for each weld type (i.e., butt welds and socket welds) at each unit.

During the audit of the "operating experience" program element, the staff determined that the operating experience provided by the applicant and identified by the staff's independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

The LRA states that there have not been any failures caused by sec or fatigue in its Class 1 small-bore piping. However, one of the operating experience cases provided in the LRA documents a socket weld failure at Byron Unit 1 in 1998. The LRA states that the failure was caused by a fabrication flaw. During its onsite audit, the staff noted that there is evidence indicating the failure was service induced Based on the information provided, the staff noted that the failure may have been caused by vibration fatigue.

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

Audit Results. Based on 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 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 the audit, the staff also found that additional information is required for Byron before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR LRA AMP 8.2.1.23, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The LRA states that AMP 8.2.1.23, "External Surfaces Monitoring of Mechanical Components," is a new program that will be 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.

At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staff's audit addressed only the program elements described in the applicant's basis document. 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 provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database for Byron and Braidwood using the keywords:

"corros," "loss of material," and "crack."

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

Relevant Documents Reviewed Document Title Revision I Date 1 BB-PBD-AMP-External Surfaces Monitoring of Mechanical Components Program Revision 2 XI.M36 Basis Document 2 ER-BY-700-402 External Surfaces Monitoring of Mechanical Components Prowam Revision 0

3. ER-BR-700-402 External Surfaces Monitoring of Mechanical Components Program Revision 0

~-

4. AR 00687024 Cleanup of rust particles resulted in a thru wall leak onto SX 10119/2007

~

AR 00828518 piping Surface corrosion present on Accumulator connection isolation 10/09/2008 valve

6. AR 00765821 Moderate Corrosion on SX Piping 04/21/2008
7. AR 00883889 light Surface Rust ldentirled on SX_ Piping 02/23/2009 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. For the "scope of program" program element sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

The "scope of program" program element of the LRA AMP states that cracking of stainless components exposed to an air environment containing halides is not a predicted aging effect for the material and environment combinations. The GALL Report

"50" AMP recommends visual inspections of external surfaces to manage cracking of stainless steel components exposed to an air environment containing halides. It is not clear to the staff that the LRA statements are consistent because SRP-LR Sections 3.2.2.2.6, 3.3.2.2.3 and 3.4.2.2.2 state that the GALL Report recommends further evaluation to manage cracking due to sec of stainless steel piping, piping components, piping elements, and tanks exposed to outdoor air environments containing sufficient halides (primarily chlorides) and in which condensation (including rain) or deliquescence is possible.

During the audit of the "operating experience" program element, the staff's independent database search for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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. M36. 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 the audit, the staff also verified that the operating experience at Byron and Braidwood 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 UFSAR supplement is consistent with the description provided in the SRP~LR.

LRA AMP 8.2. 1.24, Flux Thimble Tube Inspection Summary of Information in the Application. The LRA states that AMP B.2.24, "Flux Thimble Tube Inspection," is an existing program that is consistent with the program elements in the GALL Report AMP XI.M37, "Flux Thimble Tube Inspection." 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 provided by the applicant. 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 which were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staff's search of the applicant's operating experience database.

Relevant Documents Reviewed Document Title Revision/Date I 1 BwVS 210-3 Multifrequency Eddy Current Examination of Neutron Revision 3 I

Monitoring System (lncore Flux Thimble Tubes) 2 PMID 54635 Multifrequency Eddy Current Examination of lncore 10/05/2012 I

L..._.

Detector Flux Thimble (Un1t 2)

3. 1BVSR Xll-7 Unit 1 Non-Technical Specification Eddy Current Texting I

Revision 3 of lncore Th1mble Tubes 4_ 2BVSR Xll-7 Unit 2 Non-Technical Specification Eddy Current T extlng Revision 3 of lncore Thimble Tubes

5. PMID 172394 Non-Tech Spec Eddy Current Testing of lncore Thimble 04/08/2013 Tubes
6. BB-PBD-AMP Flux Thimble Tube Inspection Aging Management Revision 1 XLM37 Program 1-.

WCAP 12866 Bottom Mounted Instrumentation Flux Thimble Wear 01/01/1991

7.
8. AR00687278 Wear on U-1 lncore Thimble Tube number 44 at 10/20/2007 location R-8
9. AR00687434 Need to replace multiple lncore Thimbles during A1R14 10/21/2007
10. AR00690333 Initiate Common Cause-lncore Reliability and Limited 10/2712007 PMTS
11. AR00774272 A2R13 lncore Flux Thimble Eddy Current Inspection 05/11/2008 Results
12. AR01364821 A 1 R16 lncore Thimble Tube Eddy Current Inspection 05/10/2012 Scope Reduced
13. AR01435374 Potential Moisture in Unit 2 lncore thimbles 11/03/2012 --
14. AR01435431 A2R16 lncore Thimble Eddy Current Inspection Scope 11/03/2012
15. AR01439377 Potential for Thimble Tube Corrective Action in B2R17 11/13/2012 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's independent database search found that the operating experience provided by the applicant for Byron is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or the staff). However, the staff's independent database search of the operating experience for Braidwood indicated that the operating experience may not be bounded by known industry operating experience.

Specifically, the staff noted that there were instances when Braidwood Units 1 and 2 flux thimble tubes experienced unexpected and high wear rates during a single cycle. In addition, the staff noted that there had been instances of difficulties associated with the inspection of all flux thimble tubes during an outage (i.e. eddy current probe not traversing thimble tubes, presence of moisture in tubes, or outage schedule). In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAis for the subjects discussed below_

The applicant's operating experience discussion in the LRA did not fully address the unexpected high wear rates observed for Braidwood Units 1 and 2 nor the issues during eddy current testing which prevented examination of all flux thimble tubes. The staff is concerned about the sufficiency of the proposed AMP if these issues are not properly addressed.

The staff also audited the description of the LRA AMP provided in the UFSAR 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. M37.

Based on the audit, the staff also verified that the operating experience at Byron is bounded by the operating experience for which the GALL Report program was evaluated. The staff also identified that additional information is required for Braidwood Units 1 and 2 before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Oucting Components Summary of Information in the Application. The LRA states that AMP 8.2.1.25, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," is a new program that will be consistent with the program elements in GALL Report AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

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

"loss of material," *'foul," and "corros."

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

Relevant Documents Reviewed Document Title Revision I Date**~

1 ER BY-700-403 Inspection of Internal Surfaces in Miscellaneous Piping and Revision 0 Ducting Components Aging Management Program Implementing Document

2. ER-BR.J00-403 Inspection of Internal Surfaces in Miscellaneous Piping and Revis1on 0 Dueling Components Aging Management Program Implementing Document
3. 88-PBD-AMP-Inspection of Internal Surfaces in Miscellaneous Piping and Revision 1 XI.M38 Dueling Components Program Basis Document
4. AR 00158892 Excessive corrosion found on a check valve that prevented the 05/15/2003 valve disc from seating tightly 5 AR 00753030 Check valve internal condition determined to be unacceptable, 03/21/2008 due to severe corrosion found on internal parts 6 AR 00363287 Potential Trend of Raw Water Pipe Thinn1ng 08/15/2005
7. AR 00162517 Fouled Inlet and Outlet Piping to Start-up FW Pump Cooler 06/09/2003 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 whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAis for the subject discussed below.

The "detection of aging effects" program element of the GALL Report AMP states:

"[V)isual and mechanical inspections conducted under this program are opportunistic in nature; they are conducted whenever piping or ducting is opened for any reason."

The staff noted the possibility that opportunistic inspections may not be available for one or more material, environment, and aging effect combinations presented in the AMR line items where GALL Report AMP XI. M38 is referenced. With the exception of a few GALL Report AMR items where preventive actions alone are considered sufficient to manage aging effects, it is the staff's position that, to credit a GALL Report AMP for aging management, some assurance that a representative sample of all material, environment, and aging effect combinations will be inspected when necessary.

During the audit of the "operating experience" program element, the staff's independent database search found that operating experience for Byron and Braidwood provided by the applicant is bounded by industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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 element in GALL Report AMP XI.M38. 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 the audit, the staff also verified that the operating experience at Byron and Braidwood 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 UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.26, Lubricating Oil Analysis Summary of Information in the Application. The LRA states that AMP B.2.1.26, '*Lubricating Oil Analysis," is an existing program that is consistent with the program elements in GALL Report AMP XI.M39, "Lubricating Oil Analysis." To verify this claim of consistency, the staff audited the LRA AMP. 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 provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "Lube," "Sample," and "Loss of Material."

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

Document

1. BB-PDB-AMP-X1.39
2. ASTM 06226-09
3. MA-AA-716-230
4. BOP-DG-300-1 5 AR 00438755 re:--AR 01341284
7. AR 01176623 8 AR 00863887
9. AR 00858617
10. AR 00138437 11 BOP-AF-300-1
12. BOP-AF-300-2
13. BOP-DG-300-1
14. BWOP-AF-300
15. BWOP-DG-300
16. BWOP-SX-301
17. MM-AA-716-230-1001 Relevant Documents Reviewed Title Revision I Date License Renewal Project, lubricating Oil Analysis Revision 1 Standard Practice of Lubricating Oil for Auxiliary Power Plant November, 2009 Equipment Predictive Maintenance Program Reviston 8 Sampling Diesel Generators Lubricating Oil Revision 7 Recommen~ations/Deficiencies From Lubrication Program

, January 4, 2006 Lost Oil Samples March 15,2012 Oil Lab Data Entry Error for Byron/Braidwood Oil Samples February 17,2011 2AF01 P~ Engine Oil Sample-Potential Lab Error January 7, 2009 Lubrication Sampling Processing Issues On 28 AF Diesel December 19,2008 Lost or Misplaced Oil Samples January 7, 2003 Byron Sampling the Motor Dnven Auxiliary Feedwater Pump Revision 4 Lubricating Oil Reservoirs Byron Sampling the Motor Driven Auxiliary Feedwater Diesel Revision 6 Lubricating Oil Byron Sampling the Standby Diesel Generator Lubricat1ng Oil Revision 7 Braidwood Sampling Auxiliary Feedwater Diesel Crankcase Revision 2 1 Bra1dwood Sampling the Standby Diesel Generator Lubricating Revision 3 Oil Braidwood Sampling the Essential Service Water Pump

  • ~ Revision 1 Lubncating 011 Reservoirs I Re""o" 13 011 AnalySIS Interpretation GU1del1nes 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's independent database search for Byron and Braidwood found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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 the audit, the staff also verified that the operating experience at Byron and Braidwood is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.27, Monitoring of Neutron-Absorbing Materials Other than Boraflex Summary of Information in the Application. The LRA states that AMP 8.2.1.27, "Monitoring of Neutron-Absorbing Materials Other than Boraflex," is an existing program that is consistent with the program elements in GALL Report AMP XI.M40, "Monitoring of Neutron-Absorbing Materials Other than Boraflex." To verify this claim of consistency, the staff audited the LRA AMP. 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 on site documentation provided by the applicant. In addition, the staff conducted walkdowns of the Braidwood spent fuel pool and the chemistry laboratory facilities. The staff also conducted an independent search of the applicant's operating experience database using the keywords:

"boral," "aluminum," "loss of material," and "degradation."

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

Relevant Documents Reviewed Document Title Revision I Date 1 N/A SFP Bora I Sample Coupon not Irradiated per OEM 2003 Specification

2. N/A SFP Water Chemistry Trend-Alum Concentration (Braidwood)

N/A

3. BVP 200-20 Spent Fuel Rack Boral Specimen Program Revision 9
4. AR01542347 Spent Fuel Pool Bora I Coupon Testing Results 2013 5 Hl-982094 Criticality Evaluation for the Byron/Braidwood Rack Installation Rev2-2000 Pro*ect 6 OBVSR FH-1 Unit 0 Spent Fuel Rack Boral Specimen Surveillance Revision 3
7. BwVP 500-86 lnservice Surveillance Program for Boral Neutron Absorbing Revision 4 Material
8. NET-213-01 Inspection and Testing of Boral Surveillance Coupon from Braidwood Station
9. NET-243-01 Inspection and Testing of Boral Surveillance Coupon from Braidwood Stat1on
10. NET 278-01 Inspection and Testing of Boral Surveillance Coupon from Byron Station 11 NET-266-01 Inspection and Testing of Boral Surveillance Coupons from Byron and Braidwood Stations
12. NET-207-01 Inspection and Testing of Boral Surveillance Coupon from the Bvron Stat1on
13. OBVSR FH-1 Unit 0 Spent Fuel Rack Boral Specimen Surveillance Revision 2
14. NET-236-01 Inspection and Testing of Boral Surveillance Coupon from the Bvron Station
15. AR01417888 NRC Concerns with SFP Racks Boral Coupon Tests 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.

In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAis for the subjects discussed below.

Both Byron and Braidwood have operating experience where the coupon tree holding the Bora I sample coupons was not surrounded by freshly discharged fuel in accordance with the original equipment manufacturer's recommendations.

In order to have an effective coupon monitoring program, the coupons should be the leading indicators of material degradation as compared to the neutron absorber material in the spent fuel storage racks. That is, the dose received and/or long-term exposure to the wet pool environment by the coupons should be bounding of the material in the racks. Allowing the coupons to lead the neutron absorber material in the racks provides reasonable assurance that the applicant will detect any material degradation in the coupons before the material in the spent fuel pool racks starts to degrade.

Additional information may be needed to explain how the coupon exposure (i.e., coupon tree location) will provide reasonable assurance that Boral degradation is identified prior to potential loss of neutron-absorbing capability of the material in the spent fuel racks. If the coupon exposure to the environment is not bounding of the material in the racks, additional information may be needed to explain how the aging effects of the Boral material will be managed for the unbounded racks.

The staff also audited the description of the LRA AMP provided in the UFSAR 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 M40.

Based on the audit, the staff also found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.28, Buried and Underground Piping Summary of Information in the Application. The LRA states that AMP 8.2.1.28, '"Buried and Underground Piping," is an existing program with enhancements and exceptions that is consistent with the program elements in GALL Report AMP XI.M41, "Buried and Underground Piping and Tanks," as modified by LR-lSG-2011-03, "Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program (AMP) XI.M41, 'Buried and Underground Piping and Tanks'." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. 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 which 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 provided by the applicant. The staff also conducted an independent search of the Byron and Braidwood operating experience database using keywords: "buried," "coat,"

"dug," "excavat," "holiday," "min wall," "through wall," "underground," and "wrap

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

Relevant Documents Reviewed Document I

Title I Revision I Date Documents Reviewed During Byron Audit Phase 1 88-PBD-AMP-Program Basis Document Buried and Underground Piping Revision 1 XLM41 2 F/L-2722 Section 2-111.5, Site Work, Backfill Specification Revision 2

3. Form 276-C Standard Specification for Protective Coatings for Buried Pipe 08/27/1971
4. ER-AA-5400 Buried Piping and Raw Water Corrosion Program (BPRWCP)

Revision 5 Guide

5. ER-AA-5400-1 002 Buried P1ping Examination Guide Revision 4
6. OBOSR FP-9 Unit Zero Fire Protection System Leakage j. Revision 1
7. OBwVS FP.2.1.T-1 Fire Protection Flow Test Revision 3 Documents Reviewed During Byron Audit Phase (continued)
8. 0BwOS-FP-A10 I Fire Protectio~ System Leakage Surveillance-Braidwood Revision 2
9. None Underground Pipe and Tank Inspection Plan-Byron Revision 1
10. None Buried P1pe Inspection ~ian-Braidwood Revision 1 I 11. NUC2011109.00 Condition Assessment Excavated Buried Pipe-Byron 09/27/2011
12. NUC2010111.00 Condition Assessment Excavated Buried P1pe-Bra1dwood 10/31/2010
13. IR 953598 Standing water in OSX138A Valve P1t Leading to Pipe Wall 08/20/2009 Corrosion - Byron
14. 2010-348 Ultrasonic Thickness Measurements, 0SX138A Valve Pit Piping-05/27/2010 Byron
15. 2012-415 Ultrasonic Thickness Measurements, OSX138A Valve Pit Piping-11/0712012 Byron
16. 2011-068 Ultrasonic Thickness Measurements, 0SXH2AA Valve Pit Piping-04/04/2011 Braidwood
17. 01456616-02 Apparent Cause Evaluation-Six Buried Fire Protection Pipe No date available Leaks-Braidwood 18 None Bio-GardT"' 258 Product Data Sheet, Th1n F11m Technology, Inc.,

No date available www. th inf1l mtech. net

19. PMRQ 00120596 FP System Leakage-Byron 04/22/2009

~0 PMRQ 00120642 Readings Taken on Cathodic Protection Rectifiers-Byron 05/04/2011

21. PMRQ 00141070 Cathodic Protection Site Survey-Byron 01/27/2010 E~RQ 00169300 Fire Protection System Leakage Surveillance - Braidwood 06/14/2011
23. PMRQ 00049757 U-0 Cathod1c Protection Sys Monthly Surve1llance-Braidwood 02/20/2009 24 PMRQ 00096509 Cathodic Protection S~rvey-Braidwood No date available
25. None Corpro 2011 Cathodic Protection System Resurvey Report for January 2012 Exelon Nuclear Byron Power Station
26. None Corpro 2012 Cathodic Protection System Resurvey Report for March 2012 Exelon Nuclear Byron Power Stat1on i
27. None Quarterly Health Report Buried P1ping and Raw Water Corrosion-2013 CP System Rectifier Availability Trending-Rollmg 12 Month Byron and Braid..yood Document Title Revision I Date I
28. 1001447.401 APEC Survey for Braidwood Nuclear Power Station 02/26/2013
29. S-546 Turbine Room Foundation Section 1-1 Revision G 30 PMRQ 55407 Essential Service Water OSX165A Pit Inspection, inclusive of the 07/3112012 2012,2010, and 2009 inspections-Braidwood 31 PMRQ 55408 Essential Service Water 0SX165B Pit Inspection, inclusive of the 07/31/2012 2012, 2010, and 2009 inspections-Braidwood
32. PMRQ 00100304 Essential Service Water 0SX138A Pit Inspection, inclusive of the, 07/08/2013 inclusive of 9 prior inspection results-Byron
33. PMRQ 00100305 Essential Service Water 0SX1388 Pit Inspection, inclusive of the, 05/30/2013 inclusive of 11 prior inspection results-Byr~n
34. AR 00635246 Potential Issues for Cathodic Protection~ Byron 0513012007
35. AR 00700422 Replace Buried Pipe Coating on OSX097AA-24, OA SX Riser 11116/2007 36 AR 00689316 Buried 24" SX Piping with Line Stop Inspected, Restore Coating 10/25/2007 f-37 AR 00730278 1 _Replace Buried Pipe Coating on OSX97AC-24, OC SX Riser 02/01/2008

'38. AR 00154572 OSX1618 Pipe NDE Failed the Minimum Wall Thickness 04118/2003 Examination Documents Reviewed During the Braidwood Audit Phase

39. 1001447.401 APEC Survey Braidwood Nuclear Power Station Revision 0 f-;;;-:

Cathodic Protection Survey for Underground ~tructures December 20~ Q_______

40. None
41. AR 00733843 Underground Leak on CD Pipe 02/08/2008
42. AR 00952693 0SX165B Valve Pit Piping Inspection Results 08/11/2009
43. AR 00977262 As-Found OSX99BB-12" Buried Pipe Assessment 10/09/2009
44. AR 01128731 As-Found Buried Pipe 2CD19A-20 Condition Assessment 10/08/2010
45. AR 01259165 Jockey Pump Cycling Excessively 09/03/2011 46 AR 01128730 As-Found B~ried Pipe 1CD19A-20 Condition As~essment 10/0812010
47. AR 01459125 As-Found Buried Pipe Condition Assessment for Excavation 2 01/05/2013 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 "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 revised by LR-ISG-2011-03). In addition. the staff found that, for the '*scope of program," "preventive actions," "detection of aging effects," and "acceptance criteria" program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAis for the subjects discussed below.

The Program Description of the LRA AMP states that the program manages the external surface aging effects for buried and underground piping. The GALL Report AMP "scope of program" program element recommends the same scope. However, LRA Table 3.3.2-22 states that carbon steel piping and piping components exposed to concrete, citing LRA Table 3.3-1, item 3.3.1-112 and plant-specific note 4, have no aging effect requiring management (AERM) and no recommended aging management program (AMP). Plant-specific note 4 states:

The Service Water system contains buried piping that is embedded in the reinforced concrete foundation of the Turbine Building Complex. The reinforced concrete foundation, which is founded on the underlying bedrock at the site, provides protection to the below-grade piping. This area, including any potential ground water exposure, is considered oxygen deficient and not conducive to active corrosion. Therefore, no aging affects are assumed for the carbon steel piping embedded in the reinforced concrete foundation of the Turbine Building Complex.

It is not clear to the staff that all the buried in-scope piping components have been correctly identified as being within the scope of the Buried and Underground Piping program. In addition, during the audit, the staff reviewed the foundation drawing and UFSAR Sections 2.4.12 and 2.4.13.3, which appear to show that the ground water table is very close to this piping. It is not clear to the staff that the ground water would be oxygen deficient; and therefore, stating that there is no AERM and no AMP needed may not be an appropriate statement.

Exception No. 1 states that original plant specifications did not require coatings to be installed for carbon steel piping embedded in reinforced concrete. The GALL Report AMP "preventive actions" and "detection of aging effects" program elements recommend that coatings and cathodic protection be provided for steel piping and that inspection locations be based on risk (i.e., susceptibility to degradation and consequence of failure). During the audit, the applicant stated that the in-scope make-up water piping from the river screen house is buried in concrete, not coated, and is provided with cathodic protection. The applicant also stated that it is not possible to verify the level of cathodic protection provided to this portion of the piping system. It is not clear to the staff how the risk level of this piping will be established for determining site inspection priorities given that the level of cathodic protection cannot be verified.

Enhancement No. 9 states that a -850 mV polarized potential criterion will be used during cathodic protection surveys unless the 100 mV polarization criterion can be demonstrated to be effective through the use of buried coupons, electrical resistance probes, or placement of reference cells in the immediate vicinity of the piping being measured. The GALL Report AMP "acceptance criteria" program element recommends,

"[w]hen the 100 mV criterion is utilized in lieu of the -850 mV CSE criterion for steel piping or where copper or aluminum components are protected, applicants must explain in the application why the effects of mixed potentials are minimal and why the most anodic metal in the system is adequately protected." Based on the information provided in the LRA, the staff lacks sufficient information related to the how coupons, electric resistance probes, or reference cells will be used During the audit of the "operating experience" program element, the staff's independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency oft he LRA AMP, the staff will consider issuing RAls for the subjects discussed below.

The "operating experience" program element cites an example where at Byron inspection personnel discovered 8-10 feet of water in an essential service water valve pit. The in-scope piping was immersed in water. The water was removed, ultrasonic thickness measurements of the piping were performed, and the piping was recoated with a protective coal tar coating and polymeric tape wrap. The inspection frequency for both essential service water valve pits at Byron was changed from every two years to every three months. The same Braidwood valve pits were inspected and they contained 4-18 inches of water. The lower half of the piping exhibited heavy general corrosion.

The piping was recoated with a protective Kevlar reinforced epoxy coating. The inspection interval is annual. The staff reviewed the results of the preventive maintenance activities associated with the essential service water valve pits which experienced water intrusion. The results are summarized as follows:

a.

Braidwood PMRQ 55407 07/31/2012- "[n]o leaks or other issues identified,"

12/06/2010- "[fjound only 2 inches of water in bottom of pit, 08/17/2009- "found 4 inches of water in vault"

b.

Braidwood PMRQ 55408: 07/31/2012- "[n]o leaks or other issues identified,"

12/13/2010- "[fjound only 4 inches of water in pit," 08/20/2009- "as found sat"-

no data available on water quantity.

c.

Byron PMRQ 00100304: 07/09/2013- "[a]s found 1200 gallons of water in the bottom of vault," 03/20/2013- "removed approx 14 inches of water from vault,"

01/14/2013- "[w]ater level was 10 inches from the bottom of the pit," 10/10/2012

-no data available on water quantity, 07/17/2012- "[p}umped out 4 inches of water," 04/11/2012-no data available on water quantity, 12/20/2011 - "[fjound about 20 inches of water in vault," 09/06/2011 -no data available on water, 06/23/2011 - "[s]tarted with 12 inches to 18 inches of water," 03/14/2011 - no data available on water quantity.

d.

Byron PMRQ 00100305 05/20/2013- "[fjound about 2 feet of water in vault,"

02/28/2013- "six inches of water," 11/26/2012 -"pit was dry," 08/28/2012 - no data available on water, 06/04/2012-no data available on water, 02/29/2012-

"[f)ound 6 to 8 inches of water," 12/01/2011 -"found 8 inches of water in pit,"

09/07/2011 -no data available on water, 06/01/2011 - "[fjinished pumping down vault approx. 1 0 inches," 03/03/2011 -"observed small amount of water,"

12/08/201 0 -"found about 6 foot of water in the vault."

e.

Based on the applicant's hand calculation, 1200 gallons results in the pit (11 feet by 11 feet) being filled to 15.6 inches, bottom of pipe is 18 inches).

Based on a review of the applicant's inspection results, it is not clear that the inspection interval at Byron is sufficient to prevent the in-scope piping from being periodically rewetted. Based on a review of plant-specific operating experience, it is evident that corrosion occurred on the underground piping; and therefore, it is not clear to the staff that the coating system is adequate for immersion, drying, and rewetting.

Based on a review of inspection reports and plant-specific operating experience, it appears that there have been several instances of potential damage to coatings during installation and inadequate initial preparation of coatings resulting in disbandment and minor corrosion. For example:

a.

NUC20111 09.00 (Byron) stated: "[w]ith regard to the as-found coating condition, localized coating damage appears to be largely the result of mechanical damage resulting from the original installation or excavation for inspection."

b.

In addition to the NUC report, the following Action Requests (AR) identified degraded coatings or loss of material for essential service water piping:

AR 00689316, AR 00700422, AR 00730278, and AR 00154572.

c.

NUC201 0111.00 (Braidwood) stated: "[i]n some locations, lack of overlap exposed the underlying coating or steel substrate. These exposed areas exhibited minor corrosion activity but no significant pitting."

Based on this plant-specific operating experience, the staff lacks sufficient information to understand the extent of condition of coating degradation and quality of the original coating installation. In conjunction with the plant-specific operating experience, the staff's review of cathodic protection survey reports for both Byron and Braidwood indicate that cathodic protection coverage has been improving, but in many locations less than 50 percent of the site is adequately protected. As a result of these observations, the staff cannot conclude that the as-found coating condition for buried piping is adequately bounded by the assumptions used to develop the GALL Report AMP (e.g., quantity of inspections, frequency of inspections).

The staff also audited the description of the LRA AMP provided in the UFSAR 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 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.M41. The staff also identified certain aspects of the "scope of program," "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 the audit, the staff also found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.29, ASME Section XI, Subsection IWE Summary of Information in the APplication. The LRA states that AMP 8.2.1.29, "ASME Section XI, Subsection IWE," is an existing program with enhancement that will be 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. 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 which 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 provided by the applicant. In addition, the staff conducted walkdowns of 100 percent of the vertical tendon galleries and a partial walkdown of one of three buttresses containing hoop tendon anchorages for the containment structures of Byron and Braidwood Units 1 and 2. The staff also conducted an independent search of the applicant's operating experience database using keywords: "containment," "IWE," "liner plate," "moisture barrier," and "liner plate corrosion."

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

Relevant Documents Reviewed Document Title Revision I Date 1 AR 0093228 Limited Liner Inspection Behind Unit 2 Containment Moisture

.: 11/1312009 Barrier

2. AR 00908703 Byron review of Braidwood Containment Liner Plate indication 4/17/2009 3 ER-AA-335-018 Visual Examination of ASME IWE Class MC and Metallic Liner of Rev. 8 IWL Class CC Components 4_ Calculation 5.2.6-Liner plate inspection criteria Rev. 6 BRW-98-1090

~:- AR 012254938 lSI Program-Focused Area Self-Assessment (FASA) 02/01/2011

6. AR 01254938 lSI Program-Focused Area Self-Assessment (FASA) 08/2412011
7. AR 965901965901Unit 1, identified degraded areas of moisture barrier 09116/2009 Unit2, degraded bolts used at the cover for a spare containment
8. AR 611767611767penetration 04/02/2007 The applicant provided pictures taken during the IWE inspections
9. Inspection Pictures showing the design and conditions of the containment liner plated leak case channel system
10. AR 00105204 (Braidwood Station-Unit 2) Results of Containment Liner Visual 0412412002 Inspections-Exelon Nuclear Condition Report j

I" AR 1433284 (Braidwood Station-Unit 2) NRC Containment Liner Examination 10130/2012 Observations 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 "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 provided by the applicant is bounded by known industry operating experience. In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAis for the subjects discussed below.

During audit walkdowns of the Byron main steam and tendon gallery tunnels, the staff observed white material deposits on the concrete walls and tendon gallery tunnel ceilings. indicative of water leakage or seepage through the containment concrete.

Through discussions with the applicant, the staff learned that the cracks through which the material appears to be leaching have existed since initial plant construction. The staff noted during its review that on the south side of Byron Unit 1 and north side of Unit 2, the below grade areas between the main steam tunnels and containment structures were in-filled with limestone during the original construction. According to plant operating experience, this area has allowed groundwater infiltration to the below-grade containment concrete. The staff noted that the groundwater at both Byron and Braidwood is considered to be an aggressive environment due to high chloride levels (i.e., >500 ppm). The staff may issue an RAI regarding the potential for moisture to travel through the concrete and be trapped against the containment liner plate and cause accelerated corrosion at the exterior surface of the liner.

The "operating experience" program element recommends that the ASME Section XI, Subsection IWE program consider operating experience regarding liner plate and containment shell corrosion. The applicant should demonstrate that it utilizes industry operating experience in development of the AMP. There is recent industry operating experience which has indicated that at some plants, the implementation of the IWE program has been ineffective in identifying moisture intrusion into the leak chase channel areas and potential leakage to the containment shell and liner seam welds.

Consistent with the GALL Report recommendation that the applicant consider industry operating experience related to the program, the staff may issue an RAI seeking information regarding applicability of this operating experience to Byron and Braidwood.

The staff noted both in the LRA and onsite audit that there is history of degradation at the moisture barrier areas at Braidwood Unit 1 and Unit 2, at the interface between the concrete floor slab and the containment liner. The staff reviewed on site documentation and interviewed applicant personnel regarding this issue and its applicability to the ASME Section XI, Subsection IWE AMP. The staff noted that the moisture barrier area is currently subject to augmented examinations per the ASME Code and that the requirements of IWE are being closely followed, including appropriate evaluations and corrective actions.

The staff also audited the description of the LRA AMP provided in the UFSAR 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 X!.S1, "ASME Section XI, Subsection IWE." The staff's evaluation of aspects of the program elements associated with enhancement which is not necessary for consistency will be addressed in the SER.

Based on this audit, the staff found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP*LR.

LRA AMP 6.2.1.30, ASME Section XI, Subsection IWL Summary of Information in the Application. The LRA states that AMP 8.2.1.30, "ASME Section XI. Subsection IWL," is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S2, "ASME Section XI, Subsection IWL."

To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. 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 provided by the applicant. In addition, the staff conducted walkdowns of the containment vertical tendon gallery tunnels, horizontal tendon buttresses, and the exterior of the containment structures at Byron and at Braidwood. The staff also conducted an independent search of the applicant's operating experience database using keywords: "tendon," "post tension," "prestress," "concrete," "containment," "rebar," "buttress," "leak," "spall,"' "delamination,"

"grease," "gallery," "anchorage" and "IWL."

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

Relevant Documents Reviewed

,D'-o~c~u~m~e~n~tc----,-------C~~~~~~~T~Itf-le~~~~~~~--------,.R>.e~v"ls~l~o~n'I'D'-a~re:-1 r.--~~==+/-~~~~~---.=~~:;;;oo===:---+==::c;-----1 1 BB-PBD-AMP-XI.S2 Byron and Braidwood Stations, Units 1 and 2 Program Basis Revision 1 Document ASME Section XI, Sub~ectiQ!l_I"W~L~------------1-n==c:cc------1

2.

Design Control Summary Revision 0, February 2, 1994 ro--=-o~"""~--h==-=~=~c=:=::::---

3. CC AA-309-1001 Selection of Tendons and Calculation of Predicted Ltft-Off Revision 6, May f-o--.nc===~----t-icF~or~c~e~s~fo~r~2SS~"=Y~e~'~r~IS~I'c-coc=-cc~==c-------*---------~2~0~1~1==~----1
4. AR 01247295 Unit1 Containment Dome Drainage System 08/0112011 Deficiencies/Concrete Damaae f-.o---=o~-=o--+'0~"!""~'"-!"'~~'c--~~~-~-+-o-c~=--
5. AR 00514372 111ocations Unit1 and 141ocations Unit 2 with signs of

' July 2006

6. AR 00518036
7. AR 00575066
8. AR 00575074 9 AR 00576027
10. AR 00576059 11 W07173B4 12 W000929084
13. W000929566
14. SPP VT 3C 1
15. 2006 IWL 01
16. ER-AA-330-005 117. ER-AA-330-006
18. BwVSR 5.5.6-2
19. Project No.

9135-53, Calc. No.

24.2.9 20 BY N1044-501 dearadation Tendon Grease Leakage Through Concrete, Unit1 08/08/2006 Containment Concrete Repair Required, Un1t 1 Containment ASME Section 01/03/2007 IX IWL Exams Concrete Repair Required, Unit2 Containment ASME Section 01/03/2007 IX IWL Exams Concrete Repair Required, Unit2 Containment ASME Section 01/06/2007 IX IWL Exams ASME Section XI Augmented Exams Required (Unit 2 Tendon 01/06/2007 Tunnel)

Visual Exam VT3C/1 C of Unit1 Concrete Containment Exterior 01/03/2006 U/1 ASME IWL VT-3 Concrete Exams Prep Areas for VT-1C 06/12/2006 Exams U/2 ASME IWL VT 3C Concrete Exams Prep Areas for VT -1 C 06/13/2006 Exams Visual Examination Data Attachment Form VT 3C 1.2 ReviSIOn 0 Exelon Braidwood Station Units 1 and 2 Engineering Evaluation Revision 0 ASME Section XI Class CC Structures Visual Examination of Section XI Class CC Concrete Revision 9 Containment Structures lnservtce Inspection and Testing of the Pre-Stressed Concrete Containment Post Tensioning S-ystems Contamment Tendon Grease Can Inspection Design Control Summary: Containment Post-Tensioning In-Service Inspection (lSI)

Revision 6 Revision 1 Revision 0 11/16/2009 Final Report for Exelon Byron Station Unit 1 and Unit 2 25 Year Containment Buildin-g Tendon Surveillance lo-.--.=c-=v=..-o--t-i':"':'S~~'S':".O':-'.'=s~"i2"iC'::cc=c::----t-o-c'""--- --

21 EC 0000353115 Document and Evaluate for Acceptability the Free Water 8/12/2005

22. Report 0500523 R-001
23. 2011-IWL-02 Presence in Tendons Found During the 201h-YR Tendon Surveillance /Bvron)
  • ASME Section XI IWL Evaluation of Byron Unit 2 Containment Post-Tensioning for Free Water Exelon Braidwood Station 25 Year Un bonded Post

' Tensioning System Surveillance Engineering Evaluation Report.

Revision 0 Revision 0 Evaluate Conditions that Did Not Meet Th~.Acceptance Criteria lo~-.-..,..-=.-.conc.,---~D~u"Crl~no~lh~e~2~D~"=ycce~7ar_}"~11E.~en~S~u~rv~e~ll21,=n~ce~>~

t*B"'"yrr~on"'c'c---------f--oc===o--------1

25. ATI 1324460 10 Byron Contatnment Tendons-Operating Experience 06125/2012
24. EC 350171 Revision 0 Document Title Revision I Date
26. wo 01249079-01 IWL, Visu~~EExa~~nation of Concrete (Class CC) CNMT 05/20/2011 Structures Byron
27. ER-AA-335-019

, Visual Examination of ASME IWL Class CC Containment Revision 0

  • Components 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 provided by the applicant is bounded by known industry operating experience. In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAis for the subjects discussed below.

The staff reviewed information related to a crack with grease leakage discovered in 2006 at Braidwood Unit 1 containment on the upper right corner of concrete that had been patched after the steam generator (SG) was replaced in 1998. The staff also performed a walkdown of the area of the crack and noted that a similar crack was also located on the upper left corner of the SG replacement concrete patch in Unit 1 containment. The applicant stated that a similar condition exists at the Byron Unit 1 containment where it was patched for SG replacement. The staff may request additional information regarding aging management of the containment concrete in that area for both Byron and Braidwood. The staff is also concerned that the amount of grease leakage through the cracks may result in an exposure of the prestressing tendon in that area to an aggressive environment which could result in corrosion of the tendon.

The staff reviewed operating experience at Braidwood regarding suspected areas of degradation in the concrete at the vertical tendon access gallery tunnel ceilings. The staff performed walkdowns at both Byron and Braidwood and observed buildup of minerals, white efflorescence, stalactites, surface corrosion on embedded plates, and surface cracks at the tunnel ceilings near some of the vertical tendon anchorage cans.

Due to the aggressive nature of the site groundwater and condition of the suspected areas of degradation observed, the staff is concerned that the conditions found on the tendon gallery tunnel ceiling may be indicative of chemical attack and/or leaching of the concrete. The staff may request additional information to determine whether the ASME Section XI, Subsection IWL program will be able to manage the effects of aging in this area for the period of extended operation.

The staff reviewed operating experience regarding degradation of concrete dome surfaces due to the degraded condition of the dome drainage system at Braidwood. The degradation of the concrete is localized near the drain penetrations on the containment dome and includes: loose surface of concrete near two of the drains, accumulation of calcium deposits or efflorescence on concrete surfaces near all the drains, accumulation of water, corrosion staining, and cracks extending from all six dome drain penetrations.

The staff is concerned that the water trapped at the top of the containment dome, as a result of the degraded drainage system, may be affecting the condition of the concrete near the drains. The staff may request additional information to determine whether the ASME Section XI, Subsection IWL program will be able to manage aging of the concrete in this area for the period of extended operation.

During a walkdown to observe the exterior surfaces of Braidwood Units 1 and 2 containments, the staff noted rust staining on the south face of the Unit 2 concrete containment. Based on its review of operating experience at Braidwood, the staff was not able to determine whether (1) the applicant has determined the cause of this condition, (2) the condition identified is a result of age-related degradation, and (3) whether the condition is considered an indication requiring evaluation in accordance with the ASME Section XI, Subsection IWL examinations. The staff may request additional information regarding the operating experience associated with this condition.

The staff also audited the description of the LRA AMP provided in the UFSAR 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.S2. 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 found that additional information may be required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.31, ASME Section XI, Subsection IWF Summary of Information in the Application. The LRA states that AMP XI.S3, "ASME Section XI, Subsection IWF," is an existing program with enhancements and exceptions that will be 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. This audit report does not consider the sufficiency of exceptions, which will be evaluated in the SER.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the auxiliary building at both Byron and Braidwood. The staff also conducted an independent search of the applicant's operating experience database using keywords: "support," "bolt,"

"hanger," "stress corrosion crack," "spring support," and "IWF."

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

Relevant Documents Reviewed Document Title

[ Revision I Date

1. 88-PBD AMP-XI.S3 Program Basis D-ocument, ASME Section XI, Subsection IWF j Revision 1 05/01/2013
2. ER-AA-330-003
lnservice Inspection of Section XI Component Supports Revision 7 08/07/2013
3. ER-AA 335-016 VT-3 Visual Examination of Component Supports, Attachments Revision 5 and Interiors of Reactor Vessels 07/29/2013

. 4 MA-MW-736 600 Torquemg and Tightening of Bolted Connections Revision 4 10/25/2012 5 BWD05.005 Braidwood Selection Document, Third Ten Year Inspection 12/21/2007 Interval

6. PMRQ 106745-06 Component Inspection/Replacement (Fuel transfer system)

I (B"on>

08/6/2009

7. PMRQ 175341-01 2FH01E FH SYS PM with Dry Transfer Canal 01/23/2013
8. AR 00757579, WR Variable Spring Support 1AF0604V (Adjust Load Setting) 04/01!2008 268149, wo 1121045
9. AR 00757349, WR Boric Acid Accumulation I Corrosion NSSS 1 RC01 BA SG 03/31/2008 2667977, wo 1121300

~upports

10. Byron 2010-0001 Byron Unit 1 90 day lSI Report for Interval 3, Period 1 (81 R16) 01/05/2010 11 A2R13 Braidwood Unit 2 lSI Summary Report for Interval 2, Period 3, Octage 2 (A2Ri3) 0811312008 ---
12. AR 00544850, WR ASME Support 2CV41016V (Recordable Indication No Load) 10/17/2006 222074. wo 0967028
13. wo 0808296 V1sual Exam VT 314 of Component Supports 11/15/2006
14. AR 00952591, WR 2AF~;~30X (Loose Pipe Clamp, Repair, Expand Inspection 08/12/2009 1142589, wo 1261700 Scope
15. AR 1369622
  • . A1R17: Apply Lubricant: SG Upper Lat9ral Shim Packs 05/23/2012
16. AR 01413704 1RC01BB ULR Belly Band Shim Packs Damaged 09/16/201~- -~
17. AR 01413706, Inspect 1A11 Ct1 D S/G Upper Restraint Shimpacks (Belly Band) 09/16/2012 01413707, 01413708 18_ AR 01416386, 1 RC01 BAJC/0 ULR Belly Band -Shim Packs Damaged 09/21/2012 01416405,01416411 19_ AR 01414309, A2R16 Examine SG Belly Barld Shim Assembly and Repair 09117/2012 01414313 20_ AR 01414334, A1R17 Examine SG Belly Band Shim Assembly and Repair 09/17/2012 01414336 21 AR 01429245, B2R17 Inspect 2AJB/C/D S/G Upper Lateral Shim packs (Belly 10/20/2012 01429246 Band)

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. Aspects of the "preventive actions" and "detection of aging effects" program elements of the LRA AMP associated with the exceptions were not evaluated during the audit. The aspects of these program elements that are not associated with the exceptions were evaluated and are described below.

During the audit, the staff verified that the "scope of program," "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 some aspects of the "preventive actions" and "detection of aging effects" program elements not associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staff's evaluation of aspects of these program elements associated with the exceptions will be addressed in the SER. In addition, the staff found that for the "preventive actions," "parameters monitored or inspected," and "detection of aging effects" program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAis for the subjects discussed below.

GALL Report AMP XI.S3 recommends that the ASME Section XI, Subsection IWF AMP augment the requirements of the existing ASME Section XI, Subsection IWF in service inspection program (required by 10 CFR 50.55a) to include aging management of high-strength structural bolting with actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa for cracking. The "preventive actions" program element recommends (1) using bolting material that has an actual measured yield strength less than 150 ksi and (2) for structural bolting consisting of ASTM A325, ASTM F1852, and/or ASTM A490 bolts, following the preventive actions for storage, lubricants, and SCC potential discussed in Section 2 of Research Council for Structural Connections (RCSC) publication, "Specification for Structural Joints Using ASTM A325 or A490 Bolts." The "parameters monitored or inspected" program element recommends that high-strength structural bolting susceptible to SCC be monitored for SCC. In addition, the "detection of aging effects" program element recommends that, for high-strength structural bolting in sizes greater than 1 inch nominal diameter, volumetric examination should be performed in addition to the VT-3 examination to detect cracking. The "preventive actions" program element of the LRA AMP states that high strength bolts susceptible to SCC are not used in IWF supports at Byron and Braidwood. However, in discussions with the applicant during its onsite audit, the staff noted that there may be high-strength bolts (i.e., ASTM A490) in sizes greater than 1" diameter and actual yield strength greater than 150 ksi that may be applicable to the IWF program. The staff needs more information to determine whether there are high-strength bolts susceptible to sec that were not previously identified by the applicant; and, if so, how the recommendations in the "preventive actions," "parameters monitored or inspected," and "detection of aging effects program elements are addressed to manage aging of these components.

The ASME Section XI, Subsection IWF AMP basis document states that molybdenum disulfide (MoS2) was used as lubricant for faying the surfaces of NSSS supports but not used as a thread lubricant. The preventive actions" program element of the GALL Report AMP states that the use of MoS2 as a lubricant is a potential contributor to SCC, especially when applied to high strength bolting. Although MoS2 has not been used as a lubricant for bolt threads, bolt installation procedures applying to IWF bolting do not specifically prohibit the lubricant from use. The staff needs more information to understand whether the use of MoS2 will be prohibited for structural bolting.

The staff notes that for the enhancement to the "preventive actions" program element, which enhances the program to provide guidance for proper specification of high strength bolting material and lubricant to prevent or mitigate degradation and failure of structural bolting, the program basis document states the following.

The applicable preventive action recommendations addressed within EPRI NP-5769, NP-5067 for the proper selection of bolting material, lubricants, and installation torque and tension to prevent and minimize loss of bolting preload and cracking of high strength bolting are addressed in existing station design and maintenance procedures. These procedures are also consistent with EPRI TR-104213 and NUREG-1339.

During the audit of the "operating experience" program element, the staff's independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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," "monitoring and trending," 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 exceptions will be addressed in the SER. The staff also identified certain aspects of "preventive actions," "parameters monitored or inspected,"

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 the audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 6.2.1.32, 10 CFR Part 50, Appendix J Summary of Information in the Application. The LRA states that AMP 8.2.1.32,

10 CFR Part 50, Appendix J," is an existing program that is consistent with the program elements in GALL Report AMP XI.S4, "10 CFR Part 50, Appendix J." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.

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

"containment isolation valve," "penetration," "leak rate," and "containment leak."

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

Relevant Documents Reviewed Document Title Revision/Date 1 BB-PBD-AMP XI.S4 Byron and Braidwood Stations License Renewal Project Aging Revision 1 Management Program Basis Document

2. Calculation

, To provide justification for the use of dry air density at standard Revision 1 EC367380 conditions when calculating the allowable leakage rate based on test pressure near the Design Basis Acc1dent pressure.

I This revisi_on is a result of an ACIT from IR #139~?20

3. Applicant Letter to Request for amendment to technical specification 5.5.16
  • April4, 2007 NRC "containment leakage rate testing ~rogram."
4. NRC Letter to Byron Station Unit Numbers. 1 and 23 Issuance of February 12, Applicant amendments, RE: Request for amendment to technical 2008 specification 5.5.16, "containment leakage rate testing

! p.roQram

Document Title Revision/Date

5. NRC Letter to Safety evaluation of containment leak chase channels
Byron, May 17. 1996*-

Applicant Unit Nos. 1 and 2, Braidwood, Unit Nos_ 1 and 2. The NRC staff agrees with the licensee, that for Byron and Braidwood plants. there is no need to vent the containment liner weld leak-chase channels durinq a CILRT.. "

6.-wo 96077555 ILRT Byron, Unit 2 11/02/1999

7. wo 98059067 ILRT Byron, Unit 1 10/05/2012
8. UFSAR ILRT Unit1, Page 6.2-86, Test Pressure of 42.77 psig Revision 9
9. Technical Section 83.6 "Containment Systems," page 83.6.4-1 and 2, Revision 18

~ecification ILRT pressure for Unit 1*

~-2.8 psig and Unit' 38.4 psig

10. CFR 50. Appendix 1* Quarter, 2013 2012 2013 J Program Health znd Quarter, 2012 Reports 3'd Quarter, 2012 41h Quarter, 2012
11. Letter from Byron Station Units 1 and 2 April19, 1983 Common Wealth Braidwood Station Units 1 and 2 Edison to Mr. Harold R.

Containment Leak Rate Testing Denton NRC Docket Nos. 50-454, 50-455 50-456, and 50-457

12. Letter from Byron Station Units 1 and 2 July 7, 1983 Common Wealth Braidwood Station Units 1 and 2 Edison to Mr. Harold R. ' Containment Leak Rate Testing Denton NRC Docket Nos_ 50-454, 50-455 50-456, and 50-457
13. ER-AA 380 Primary Containment Leakage Testing Program Revision 9
14. AR 00623361 AppendiX J F ASA 07/02/2009
15. ER-AA-335-018 Revision 5 ASME IWE (Class MC) Containment Visual Examination Record
16. AR 01282363 FASA Rec #1: Revise ER-AA-380 05/3012013
17. AR 01012562 FASA Report Passport Assignment Fill in FASA Report &

06/30/2010 Approval Tem(:llate Per LS-AA-126-1 001

18. BwVP 200-25 Braidwood Containment Leakage Rate Testing Program Revision 11
19. wo 01277596 Summation of Type B & C Tests for Acceptance Criteria 02/25/2011 20 wo 01337609 Summation of Type B & C LLRT Tests for Acceptance Criteria 10/07/2011 21 Byron & Braidwood Stations NA 10 CFR Part 50, Appendix J Exemptions 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 LRAAMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit, the staff made the following observations:

For each of the exempted components from the 10 CFR Part 50, Appendix J Program, the applicant has already identified the components in the LRA Table 2's as requiring aging management and proposed various AMPs to demonstrate that the effects of aging will be adequately managed.

For the "cumulative maximum leakage test results" as stated in the "operating experience" program element for Byron, the applicant reported that the results from 2012 were 125.647 standard cubic feet per hour (SCFH), or 14% of the total allowable technical specification limit of 899.03 SCFH, for Unit 1, and 122 889 SCFH, or 14.8% of the total allowable technical specification limit of 829.99 SCFH, for Unit 2. For the "cumulative maximum leakage test results" as stated in the "operating experience" program element for Braidwood Station, the applicant reported that the results from 2012 were 57.7 standard cubic feet per hour (SCFH), or 10.7% of the total allowable technical specification limit of 540.48 SCFH, for Unit 1, and 44.1 SCFH, or 8.8% of the total allowable technical specification limit of 499.12 SCFH, for Unit 2. Byron and Braidwood Technical Specifications, Section 5.5.16, indicate that the total allowable leakage rate acceptance criteria are <0.60 La for the Type 8 and C tests, and <.75 La for Type A containment integrated leak rate tests (CILRTs), where La is 899.03 SCFH and 829.99 for Units 1 and 2, respectively. The applicant acknowledged the discrepancy between the total allowable technical specification limit described in the LRA and that in Technical Specifications 5.5.16, and the applicant initiated an action to make the correction to the program basis document During the audit of the "operating experience" program element, the staff's independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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.S4, "10 CFR Part 50, Appendix J."

Based on the audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR LRA AMP 6.2.1.33, Masonry Walls Summary of Information in the Application. The LRA states that AMP 8.2.1.33, "Masonry Walls," is an existing program with enhancements that will be 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. 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 which 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 provided by the applicant The staff noted that the Masonry Walls LRA AMP is contained within and implemented through the Structures Monitoring LRA AMP; therefore, the staff also verified that each of the ten elements of GALL Report AMP XI.S5 have been incorporated into the applicant's Structures Monitoring LRA AMP. In addition, the staff conducted walkdowns of masonry walls in Byron's turbine building and Braidwood's auxiliary building, turbine building, and lake screen structure. The staff also conducted an independent search of the applicant's operating experience database using keywords: "masonry," "block,"

"CMU," crack" and "grout."

. 72.

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

Relevant Documents Reviewed Document Title Revision I Date 1

1 BB-PBO-AMP XLS5 Program Basis Document Masonry Walls Revision 1

2. ER-AA-450 Structures Monitoring Revision 3

~-ER-BY-450-1001 Byron Structures Monitonng Instructions Revision 1

4. ER BR-450-1001 Braidwood Structures Monitoring Instructions Revision 0
5. AMP Results Book Byron and Braidwood Stations NA License Renewal Project Masonry Walls Program 8.2.1.33
6. AR 00436111 Cracks identified in Turbine Building Masonry Wall 12/21/2005
7. AR 00299062 Localized Cracks on Masonry Walls 1 o21o8/2oo5
8. AR 00367289

, Masonry Walls of the Swilchyard Relay House Need Repairs 1 oa12st2oos 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 provided by the applicant is bounded by known industry operating experience.

The staff also audited the description of the LRA AMP provided in the UFSAR 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.S5.

Based on the audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 6.2.1.34, Structures Monitoring Summary of Information in the Application. The LRA states that AMP 8.2.1.34, "Structures Monitoring," is an existing program with enhancements that will be 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 which 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 provided by the applicant. Because the Masonry Walls LRA AMP is contained in and implemented through the Structures Monitoring LRA AMP, the staff verified that each of the ten elements of GALL Report AMP XI. 85, "Masonry Walls," have been incorporated into the applicant's Structures Monitoring LRA AMP. In addition, the staff conducted walkdowns of Byron's auxiliary building, turbine building, essential service water cooling tower, Unit 2 natural draft cooling tower cold water basin and flume, and containment tendon tunnels, and of Braidwood's auxiliary building, turbine building, lake screen structures, and containment tendon tunnels. The staff also conducted an independent search of the applicant's operating experience database using keywords: "crack," "spall," "leach," "corrosion," "leakage," "rust," and "loss of material."

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

Relevant Documents Reviewed I

Document Title Revision f Date 1 BB-PBD-AMP-XI.S6 Program Basis Document~ Structures Monitoring Revision 1

~R-AA-450 Structures Monitoring Revision 1

~~-BY-450, NEW Byron Structures Monitoring Program DRAFT

4. ER-BR-450, NEW Braidwood Structures Monitonng Program DRAFT

~00112804 River Screen House Concerns 08115/2002

6. AR 01263972 Long Term Plan to Survey the Rock River 0911612011 7_ MA-MW-736-6000 Torqueing and Tightening of Bolted Connections Revision 4
8. PES-S-003 In-Storage Maintenance of Nuclear Material Revision 8
9. PS-S-010 Fasteners Revision 0
10. AR 01285797 Byron SFP lntegritylleak Detection Issue 04/0212012 11 AR 01287713 License Renewal Exposure Issue~ SFP Leak Detection 11/0812011
12. AR 01008728 DEF Tag Discrepancies and Material Condition of Aux Bldg.

03/05/2010 Wall

13. AR 01360802 Concrete Surfaces Soaked with Oil on Condenser Piers, TB 05/3112012
14. AR 01124323 Structural Degradation of the North Wall of Cable Vaull1 E 04/15/2011 -

15 AR 00739247 Increased Degradation 2SI8811 B Piping to Containment Pen.

0312212008

16. AR 00613160 White Residue and RusUSpalled Concrete Along L Wall 05/0412007
17. AR 01165648 Potential Degradation of SIR Structure (U/1 Tendon Tunnel) 11/25/2011
18. AR 01250903 Safety Issue & More than Cosmetic Damage Aux. Bldg.

' 09/16/2011 Concrete

~_R 01360819 Standing Water and Potential Groundwater Intrusion, TB, 369 05/3112012 --

20. AR 01402603 Concrete Degradation Worse (Auxiliary Bldg. Exterior) 01/3112013 21 WJE No.

Byron Generating Station Inspection of Unit 2 Natural Draft 11/0512010 2010.0758.0 Cool inn Tower (B2R15)

22. Condition Byron Generating Stat1on 1/31/2013 Assessment Summary Condition Assessment Summary Unit1 and Unit2 Natural Draft Coolina Towers
23. Ltr from Sargent Tendon Tunnel Cracks and Evaluations 10/28/1978 and Lundy to J

Commonwealth Edison 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 notes that for the enhancement to the "preventive actions" program element to provide guidance for proper specification of high strength bolting material and lubricant to prevent or mitigate degradation and failure of structural bolting, the program basis document states the following:

[T]he applicable preventive action recommendations addressed within EPRI NP-5769, NP-5067 for the proper selection of bolting material, lubricants and installation torque and tension to prevent and minimize loss of bolting preload and cracking of high strength bolting are addressed in existing station design and maintenance procedures. These procedures are also consistent with EPRI TR-104213 and NUREG-1339.

During the audit of the "operating experience" program element, the staff's independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAis for the subject discussed below.

During a walkdown of Byron's main steam and tendon gallery tunnels, the staff observed white material deposits on the concrete walls. A review of operating experience revealed similar cond1lions in the auxiliary feedwater tunnel at Byron. Through discussions with the applicant, the staff learned that the cracks through which the material appears to be leaching have existed since initial construction of the plant. The staff has the following concerns: (1) some of the material may be leaching from the concrete and (2) the water migrating through the concrete may be aggressive.

The staff also audited the description of the LRA AMP provided in UFSAR 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.S6. The staff's evaluation of aspects of the program elements associated with enhancements which are not necessary for consistency will be addressed in the SER.

Based on the audit, the staff also found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.35, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Summary of Information in the Application. The LRA states that AMP 8.2.1.35, URG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants," is an existing program with enhancements that will be 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 which 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 provided by the applicant The staff noted that although not indicated in the LRA, this AMP is implemented through the Structures Monitoring Program. In addition, the staff conducted walkdowns of Byron's river screen house and essential service water cooling towers, and Braidwood's lake screen structures. The staff also conducted an independent search of the applicant's operating experience database using keywords: "erosion," "corrosion," "crack,"

"spall," "leakage," "settlement" and "rust."

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

Relevant Documents Reviewed Document Title Revision I Date 1 BB PBD-AMP-XI.S7 Program Basis Document Revision 1 RG 1 127, Inspection of Water-Control Structures Associated with Nuclear Power Plants 2 PMID0013968210 Structures Monitoring Walkdown Notes 12/3012010 Essential Service Water Cooling Tower Including Cold Water Basin, Plenum, Valve Enclosures, and Electrical Rooms

3. ER-BY-450, New Byron Structures Monitoring Program Revision 1
4. WJE Report
Byron Generating Stat1on Inspection of Essential Service 01/11/2013
  • Water Coolint=~ Tower Final Report
5. AR 00070276 Damage at Freshwater Holding Pond Overflow 04/14!2003
6. AR 00184318 Spillway Project in leakage from the FWHP to coffer dam 12/01/2003

'7 AR 00241721 Place Stone Along Sand Surfaces at FWHP Spillway 11/11/2011

.~

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.

The staff also audited the description of the LRA AMP provided in the UFSAR 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.S7. The staff's evaluation of aspects of the program elements associated with enhancements which are not necessary for consistency will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.36, Protective Coating Monitoring and Maintenance Program Summary of Information in the Application. The LRA states that AMP 8.2.1.36, "Protective Coating Monitoring and Maintenance Program," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.S8, "Protective Coating Monitoring and Maintenance." 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 on site documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "service Ieveii," "coating," and "containment."

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

Relevant Documents Reviewed

~Document Title Revision I Date

! 1. 88-PBD-AMP-XI.SS Protective Coating Momtoring and Maintenance Program Revision 1, 05/01/2013 2

Byron IR 0761313 B 1 R 15 Coating Inspection Does Not Meet Acceptance Criteria

3. Byron IR 845114 Degraded Levell Top Coating on Containment Concrete Walls
4. Byron IR 845084 Degraded Levell Top Coating on Containment Floors
5. Byron IR 845151 Degraded Levell Coating on Electncal Panel at 8 RCP
6. Byron IR #246926 Pipe Supports Coating Required by B1R10 Still Not Installed
7. Byron lR #175317 Levell Coating Applied Incorrectly on Storage Boxes in Containment 8 Braidwood IR Containment Coating A1R16 Exam Results
  1. 1365407

~BRW-05 0059-GSI-191 Post-LOCA Debns Generation Calculation

, M/BYROS-041

~10. BRW 11-0027 DBA Qualification of Service Levell Coatings for Use Inside Revision 0, SIBYR 10-146 Containment 05/10/2011 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 ofthe "operating experience" program element, the staff's independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience.

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

Based on the audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP*LR.

LRA AMP 8.2.1.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA states that AMP, "Insulation Material for Electrical Cable and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," is a new program that will be consistent with the program elements in GALL Report AMP XI.E1, "Insulation Material for Electrical Cable and Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements." To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staff's audit addressed only the program elements described in the applicant's basis document.

Audit Activities. During its audit, the staff interviewed the applicant's staff and reviewed onsite Byron and Braidwood documentation provided by the applicant. In addition, the staff conducted walkdowns including the switchyards at Byron and Braidwood. The staff also conducted an independent search of the applicant's operating experience database using the keywords:

"crack," "jacket," and "cable."

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

Relevant Documents Reviewed Document Title Revision I Date

1. BBS-PBD-AMP-Program Bas1s Document-Insulation Material for electrical Revision 1, XI.E1 Cable and Connections Not Subject to 10 CFR 50.49 05/0112013 Environmental Qualification Requirements
2. ELEC 1 Electrical Commodities Aging Management Review Report Revision 1, 03/01f2Q.13
3. MA-AA-723-500 Inspection Of Non EO Cables And Connections For Managing Revision 6, Adverse Localized Environments
4. ER-AA-3003 Cable Condition Monitoring Program Revision 3.

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's independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR 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.E1.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP~LR.

LRA AMP B.2.1.38,1nsulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Summary of Information in the Application. The LRA states that AMP 8.1.2.38, "Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification (EO) Requirements Used in Instrumentation Circuits," is a new program that will be 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

{EQ) Requirements Used in Instrumentation Circuits." To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staff's audit addressed only the program elements described in the applicant's basis document. 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 on site Byron and Braidwood documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords:

"reduced insulation resistance," "instrumentation circuit," and "insulation aging."

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

Document L___

Relevant Documents Reviewed Title

] Revision I Date ]

I Document Title Revision I Date I 1 BBS-PBO-AMP-Insulation Matenal for Electrical Cables and Connections Not Revision 1 XI.E2 Subject to 10 CFR 50.49 Environmental Qualification Req-uirements Used in Instrumentation Circuits

2. AR 00996543 TB-09 8 Nl System Ex-Core Detector Tape Enhancement 11/2012009 3 AR 00485241 1 RT AR024 Detectors Has a Steady Output, Not Normal 05101/2006
4. BISR 3.8.3-200 Surveillance Calibration of Fuel Building fuel Handling Monitor Revision 7
5. BIP 2500-119 Calibration of General Atomics Radiation Monitoring Revision 7 Assemblies and RD-8 Ionization Chamber Detector

~

During the audit of program elements one through six, 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. For the "scope of program" and "detection of aging effects" program elements sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAis for the subjects discussed below.

The "scope of program" program element of the LRA AMP states that the in-scope cables and connections that are used in instrumentation circuits with sensitive, high voltage, low level current signals which are not part of the EQ Program are within the scope of this program. The applicant further stated that portions of the radiation monitoring system are within the scope of the program for both Byron and Braidwood.

In addition, for Braidwood only, the applicant stated that portions of the reactor protection system (source range/intermediate range neutron monitors (SR/IR)) are also in-scope. For Byron, the SR and IR neutron monitors are not within the scope of the program because they are managed by the EO of Electric Components program. The GALL Report AMP recommends that this AMP applies to electrical cables and connections (cable system) used in circuits with sensitive, high voltage, low-level current signals, such as radiation monitoring and nuclear instrumentation, that are subject to aging management review and installed in adverse localized environments caused by temperature, radiation, or moisture. It is not clear to the staff that these statements are consistent because the applicant did not identify power range neutron monitoring circuits as within the scope of this AMP for both Byron and Braidwood or explain why these circuits are not within scope.

The "detection of aging effects" program element of LRA AMP 8.2.1.38 states that cable system testing will be credited as an alternative approach to the review of surveillance or calibration results and will be performed using a proven, industry accepted cable system test for detecting deterioration of the insulation system.

The GALL Report AMP recommends that cable testing be conducted when the calibration or surveillance program does not include the cabling system in the testing circuit. A proven cable system test for detecting deterioration of the insulation system (such as insulation resistance tests, time domain reflectometry tests, or other testing judged to be effective in determining cable system insulation as justified in the application) is performed.

The GALL Report AMP recommends cable system testing when the calibration or surveillance program does not include the cable system. The applicant's LRA AMP could allow reviewing of calibration results even though the cable system is not included in the calibration or surveillance program. The applicant's LRA AMP states that a proven, industry accepted, cable system test for detecting deterioration for the insulation will be performed. However, the applicant does not identify the type of test that can be used. In the absence of these testing techniques, the staff cannot determine the consistency of the "detection of aging effects" program element to the GALL Report.

During the audit of the "operating experience" program element. the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff}.

The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing RAis for the subject discussed below.

SRP Table 3 0-1, "FSAR Supplement for Aging Management of Applicable Systems under GALL Report AMP XLE2," 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.2.1.38 states that a proven cable test is performed in cases where cables are not included as part of the calibration or surveillance program testing circuit 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 UFSAR supplement. In the absence of these testing techniques, the UFSAR supplement is inconsistent with GALL Report AMP XI.E2 and SRP Table 3 0-1 guidance.

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 elements in GALL Report AMP XI. E2. 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 verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report AMP was evaluated. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR supplement.

LRA AMP B.2.1.39,1naccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA states that AMP 8.2.1.39, "Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," is a new program that will be 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. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staff's audit addressed only the program elements described in the applicant's basis document. 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 on site documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "cable submergence,"

"insulation degradation," and "standing water."

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

Relevant Documents Reviewed Document Title I Revision I Date 1 BBS-PBO-AMP Inaccessible Power Cable Not Subject to 10 CFR 50 49

Revision 1 XI.E3.

Environmental Qualtfication Requirements

2. AR 01550777 Safety-Related Cable Vault 082 Follow-Up Inspection 8/26/2013
3. AR 01254093 2011 Safety-Related Manhole 082 Inspection 08/22/2011
4. AR's 1073696, Yearly Manhole Inspection for Manhole 1M 5/26/2010 1108590,1204963
5. ER AA 3003 Cable Condition Monitoring Program Revision 3
6. AR00154057 Potential Adverse Condition with Underground Cables 04/15/2003 7 AR00839912 Electrical Cable Vaults Investigate Long Term Solution 11/03/2008
8. AR00968522 Deteriorating Condttion of Cable Vaults 10/22/2009 -*-
9. AR01086710 Water Found In Cable Vaults 06/30/2010
10. AR01098179 Water Found In Cable Vaults 08/04/2010
11. AR01145884 Water Found In Cable Vaults 11/29/2010
12. AR01180099 Untimely Action For Submerged Cable 02/07/2011
13. AR01199716 Monitoring Results of Water in Manholes 04/08/2011 I 14. AR01552615 Cable Vaults Not Being Pumped 08/30/2013
15. AR01513443 Submerged Cables in Cable Vaults 05/13/2013
16. AR01210266 Increasing Water Levels In Cable Vaults 05/01/2011 During the audit of program elements one through six, the staff verified that the "scope of program," "parameters monitored or inspected," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the "preventive actions," "detection of aging effects," and "monitoring and trending" program elements sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAis for the subjects discussed below.

The "preventive actions" program element of the LRA AMP states if water is found during inspection, water is drained and other corrective actions are taken, as appropriate. The GALL Report AMP recommends that if water is found during inspections (i.e., cable exposed to significant moisture), corrective actions are taken to keep the cable dry and to assess cable degradation. The applicant's program does not specifically require testing to assess the condition of cables when these cables have been exposed to significant moisture.

The "detection of aging effects" program element of the LRA AMP states that the condition of cable insulation is assessed with reasonable confidence using one of the following techniques: Dielectric Loss (Dissipation Factor or 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 pertormed. The GALL Report AMP recommends that the applicant can assesses the condition of the cable insulation with reasonable confidence using the above techniques. The GALL Report AMP further recommends that 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. It is not clear to the staff that these statements are consistent because the applicant only chose one of the testing techniques whereas the GALL Report AMP recommends one or more testing techniques. One technique may not be adequate to detect cable insulation degradation. For example, EPRI has stated that three practical tests are currently available for shielded extruded polymer medium-voltage cable:

partial discharge, tan i5, and power frequency or very low frequency (VLF) withstand.

Depending on the nature of the cable design and the cable or accessory (termination or splice) concern, one or more of these tests would be recommended and others would be unsuitable.

The "monitoring and trending" program element of the LRA AMP states that test results that can be trended provide additional information on the rate of cable degradation. The GALL Report AMP recommends that trending actions are included as part of this AMP, although the ability to trend results is dependent on the specific type of test or inspection chosen. Results that are trended provide additional information on the rate of cable insulation degradation. It is not clear to the staff that these statements are consistent because trending actions should be considered for testing as well as inspection. The applicant's LRA AMP only includes trending actions for testing.

During the audit of the "operating experience" program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). However, the staff determined that additional information is necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP. Therefore, the staff will consider issuing RAis for the subjects discussed below.

GALL Report AMP X1.E3 states that periodic actions are taken to prevent inaccessible cables from being exposed to significant moisture. Examples of periodic actions are inspecting for water collection in manholes and conduits and then draining water as needed. The inspection should include direct observation that cables are not wetted or submerged, cables/splices 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, and action requests (ARs), the staff identified unresolved cases of water in the manholes 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 staff is concerned that the applicant's manhole inspections, preventative maintenance, and corrective actions may be inadequate to prevent in-scope inaccessible power cables from being subjected to significant moisture.

The staff could not determine based on the operating experience if the applicant's LRA AMP 8.2.1.39 will ensure that in-scope inaccessible power cables will continue to perform their intended function during the period of extended operation.

The staff also audited the description of the LRA AMP provided in the UFSAR 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 "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.E3. The staff also identified certain aspects of the "preventive actions," "detection of aging effects," and "monitoring and trending" program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on the audit, the staff found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.40, Metal Enclosed Bus Summarv of Information 1n the Application The LRA states that AMP 8.2. 1.40, "Metal Enclosed Bus," is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.E4, "Metal Enclosed Bus." To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staff's audit addressed only the program elements described in the applicant's basis document. 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 which 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 on site documentation provided by the applicant. In addition, the staff conducted walkdowns of metal enclosed bus outside the auxiliary building The staff also conducted an independent search of the applicant's operating experience database using keywords: "metal enclosed bus," "loose connections," and "water intrusion."

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

Relevant Documents Reviewed L_ _ Document Title I Revision f Date I Document Title Revision I Date 188 PBD-AMP-XLE4 Aging Management Program Basis Document Metal Revision 1 Enclosed Bus T-MA BY-725-515 Preventive Maintenance of Non-Segregated Bus Duct Revision 9

3. C37.23 IEEE Standard for Metal Enclosed Bus 04/26/2004 4 SER 5-09 6.9 kV Non-segregated Bus Failure and Complicated Scram 11/04/2009
5. AR00754582 OE Example #2 U2 Loss of Power (SAT 242-2) 3/25/2008
6. AR01068883 OE Example #2 Loose Link Connections in Bus Work 5/13/2010 2AP02E 7 AR01552783 Non-Seg Bus Duct Maintenance Program Deficiencies 08/30/2013
8. AR01552496 LR-Metal Enclosed Bus Main! Proc Not Aligned W/EPRI Doc 08/30/2013 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 staffs review of existing implementation document MA-BY-725-515, Revision 9, the staff noted that in Section 4.4.8.2, the applicant required a torque check for bus insulation bolts.

Torque check is not recommended per industry guidance. EPRI TR-104213, "Bolted Joint Maintenance & Application Guide," Section 8.2 states, "inspect bolted joints for evidence of overheating, signs of burning or discoloration, and indication of loose bolts. The bolts should not be retorqued unless the joint requires service or the bolts are clearly loose. Verifying the torque is not recommended." The option for checking tightness of the bus insulator bolts is not in alignment with the EPRI guidance. In response to the staff concern, the applicant created AR 01552489 to document the basis for the current practice or revise the procedure to align with the EPRI guidance. The staff gave this AR to the resident inspector for followup.

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

The staff also audited the description of the LRA AMP provided in the UFSAR 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.E4. The staff's evaluation of aspects of the program elements associated with enhancements which are not necessary for consistency will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.41, Fuse Holders (Byron Only)

Summary of Information in the Application. The LRA states that AMP 8.2.1.41, "Fuse Holders (Byron Only)," is a new program that will be consistent with the program elements in GALL Report AMP XI.E5, "Fuse Holders." The applicant also stated that no fuse holders at Braidwood are required to be managed by this AMP because there are no in-scope fuse holders located outside of active devices susceptible to aging effects at Braidwood. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staff's audit addressed only the program elements described in the applicant's basis document. 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 provided by the applicant The staff also conducted an independent search of the applicant's operating experience database using the keywords: "fuse holder," "corrosion,"

and "loose connections."

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

Relevant Documents Reviewed Document Title Revision I Date

1. BBS-PBD-XI.E5 Byron and Braidwood Station, Fuse Holders (Byron Only)

Revision 0 Aging Management Program Basis Document

2. MA-AA-716 230-Thermography Program Guide Revision 4 1003
3. CC AA-206 Fuse Control Revision 7 4_ NUREG-1760 Aging Assessment of Safety Related Fuses Used in Low-and 05/2002 Medium-Voltage Applications in Nuclear Power Plants 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," and "monitoring and trending" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the "acceptance criteria" program element sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAis for the subject discussed below.

The "acceptance criteria" program element of the LRA AMP states the thermography program establishes acceptance criteria for thermography testing. When thermography is not practical, other acceptance tests are implemented, such as connection resistance measurement. Acceptance criteria are set in accordance with good practice.

The GALL Report AMP recommends the acceptance criteria for each test are defined by the specific type of test performed and the specific type of fuse holder tested. The temperature of the metallic clamp of the fuse holder needs to be below the maximum allowed temperature for the application when thermography is used; otherwise, a low resistance value appropriate for the application when resistance measurement is used.

"Acceptance criteria set in accordance with good practice" is unclear. An acceptance criterion consistent with the GALL Report needs to be established in order for the applicant to take corrective action. Acceptance criteria ensure that the intended function of the fuse holders can be maintained consistent with the current license basis.

During the audit of the "operating experience" program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR 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," and "monitoring and trending" program element(s) of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.ES_ The staff also identified certain aspects of the "acceptance criteria" program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.

Based on the audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.2.1.42, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA states that AMP 8.2.1.42, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," is a new program that will be consistent with the program elements in GALL Report AMP XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicant"s basis document. 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 on site documentation provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using the keywords: "cable connections," "loose connections," and "high resistance."

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

Relevant Documents Reviewed Document Title I Revision I Dat~

Document Title Revision I Date

1. BB.PBD-AMP-XI.E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Revision 1 Environmental Qualification Requirements
2. IR #963012 U2 Pressunzer Group "0" Breakers Found Trip 09/09/2009
3. IR#239039 Weekly Thermography Identified Warm Connection 4-1 0712612004 Contactor
4. MA-AA-716-230-Thermography Program Guide ReviSIOn 4 1003
5. AR01322539 Continued Elevated Temp OSYBT7 8 BUS 7 B Disconnect 02/03/2012
6. AR00374808 Elevated Temperature of A Phase Disconnect OSYBT1-3-A 09/1912005
7. AR00325716 Elevated Temp Seen on BT 4-7-7 Bushing Connection 04/18/2005
8. AR00263709 Line Loss Caused Elevated Disconnect Temperature 10/14/2004 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 element(s) of the GALL Report AMP. For the "detection of aging effects" program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.

The "detection of aging effects" program element of the AMP Basis Document states the technical basis for the sample size is documented per station procedures. The AMP basis document also states that representative sample size is twenty percent of the population with a maximum sample of 25 connections. The GALL Report AMP states that twenty percent of the population with a maximum sample of 25 constitutes a representative sample size. The staff is concerned that the applicant could choose a sample size/method that is different from the GALL Report recommendation without an evaluation by the staff. Gall Report AMP XI.E6 states that if the representative sample size selected by the applicant is not consistent with the GALL Report a technical justification of the methodology and sample size used for selecting components for one-time test should be included as part of the AMP site documentation.

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

The staff also audited the description of the LRA AMP provided in the UFSAR 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.E6. 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 at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.3.1.1, Fatigue Monitoring Summary of Information in the Application. The LRA states that AMP 8.3.1.1, "Fatigue Monitoring," is an existing program with enhancements that is consistent with the program elements in GALL Report AMP X.M1, "Fatigue Monitoring." To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP; however, it does not consider the sufficiency of enhancements which 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 provided by the applicant. The staff also conducted an independent search of the applicant's operating experience database using keywords: "fatigue," "cycle,'" and "cracking."

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

Relevant Documents Reviewed Document I

Title Revision I Date 1 BB-PBD-AMP-X.M1 ; Byron & Braidwood Stations License Renewal Project-Aging Revision 1 Management Program Basis Document-Fatigue Monitoring Pr~o-ram GALL Program X.M1 2 BVP 900-3 Documentation of Operating PlanUComponent Cyclic or Revision 9a Transient Events

,3 BwVP 850-7 Operational Transient Cycle Counting Revision 5 4 ER-AA-470 Fatigue and Transient Monitoring Program Revision 5

~TR-PAFM-12-92 Westinghouse Letter Report-Byron and Braidwood Stations, Revision 0,

~-AR 00982528 Units 1 and 2 Cvcle Countina Procedure Review 5/1612013 Action ~lequest-Resolution of FatiguePro Related Issue (RIS 10/21/2009 2008-30

7. ATI 01308932,01 Level 3 OPEX Evaluation RIS 2011 14 1/24/2012
8. T&RM LR-AA-1208 Time-Limited Aging Analysis (TLAA) Identification, Evaluation, Revision 1,

~-

and Disnosition.

5/30/2013 9 CC-AA-1 02 Design Input and Configuration Change Impact Screening Revision 23 -*-

~Q. CN-PAFM-12-18 Westinghou-se-Byron Station. Units 1 and 2. Transient Revision 2, Counting and 60 Year Projections 2/1/2013 11 CN-PAFM-12-19 Westinghouse-Braidwood Station, Units 1 and 2: Transient Revision 2,

. Counting and 60-Year Projections

! 2/1/2013 12 AR 00762699 Acti~~ Request-PZR Heatup Rate Possibly Exceeded (TRM 4/13/2008 3.4.C

13. LER 2012-001-00 1 Umt 2 Loss of Normal Offsite Power and Reactor Trip and Unit 3/3012012 1 Loss of Normal Offsite Power Due to Failure of System Auxiliaru Transformer Inverted Insulators
14. AR 00536774 Action Request-Potential Issues in Historical Cycle Counting 9/27/2006 Database Document Title Revision I Date
15. AT11230600-01 Significance Level3 OPEX Evaluation-OE 33310- Normal 8/4/2011 Letdown Flow Operation at the ;;~~ximu~~low Rate is Outside the Fatigue Desi9n Basis Limits Callawa
16. AR 01215079 Assignment Request Byron Station Review of OE 33310 6/13/2011
17. WCAP 17699-P Environmental Fatigue Evaluation for Byron and Braidwood I Revision 0, i

Stations, Units 1 and?

02/2013 The staff conducted its audit of LRA program elements one through seven based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the "detection of aging effects," "monitoring and trending,"

and "corrective actions" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the "scope of program," "preventive actions," "parameters monitored or inspected," and "acceptance criteria" program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing an RAI for the subjects discussed below.

The "scope of program," "preventive actions," uparameters monitored or inspected," and "acceptance criteria" program elements of the LRA AMP provide an enhancement to

"[m]onitor and track additional plant transients that are significant contributors to component fatigue usage." The GALL AMP recommends the program monitor all plant design transients that cause cyclic strains, which are significant contributors to the fatigue usage factor. It is not clear what actions will be done to include additional transients that contribute significantly to fatigue usage and ensure the transients that have occurred will be accurately accounted for.

LRA Section 8.3.1.1 states the Fatigue Monitoring Program will be used to monitor the transients for ASME Section Ill fatigue analyses. It is unclear to the staff whether analyses other than ASME Section Ill fatigue analyses are within the scope of the program.

The "scope of program," "preventive actions," "parameters monitored or inspected," and "acceptance criteria" program elements of the LRA AMP provide an enhancement to

"[e]valuate the effects of the reactor coolant system water environment on the reactor vessel internal components with existing fatigue CUF analyses to satisfy the evaluation requirements of ASME Code, Section Ill, Subsection NG-2160 and NG 3121." The staff noted that this is in response to Applicant/Licensee Action Item 8 of MRP-227 -A. The staff needs further clarification as to what actions will be done to evaluate the effects of the reactor coolant system water environment on the applicable reactor vessel internals.

This issue will be evaluated under the staff's review of LRA AMP 8.2.1.7, "PWR Vessel Internals."

During the audit of the "operating experience" program element, the staff determined that the operating experience provided by the applicant and identified by the staff's independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). The applicant addressed generic communication (i.e., RIS 2008-30 and RIS 2011-14) and its impact on its plants. The applicant determined that the analysis methodology described in RIS 2008-30 was not used, and therefore, the RIS was not applicable. The applicant reviewed the concerns discussed in RIS 2011-14. The applicant determined that when conservatism is removed during fatigue calculations performed by computer software, adequate justification is fully documented in the analysis. Therefore, the applicant concluded that the applicable concerns in RIS 2011-14 have been addressed. The staff also determined that the operating experience provided by the applicant and identified by the staff's independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the UFSAR 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 "detection of aging effects" and "monitoring and trending" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP X.M1. The staff's evaluation of aspects of the program elements associated with enhancements which are not necessary for consistency will be addressed in the SER. The staff also identified certain aspects of the "scope of program," "preventive actions," parameters monitored or inspected," 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 the 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 8.3.1.2, Concrete Containment Tendon Prestress Summary of Information in the Application. The LRA states that AMP B.3.1.2, "Concrete Containment Tendon Prestress," is an existing program with an enhancement that will be consistent with the program elements in GALL Report AMP X.S1, "Concrete Containment Tendon Prestress." To verify this claim of consistency, the staff audited the LRA AMP. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP; however, it does not consider the sufficiency of enhancements, which 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 on site documentation provided by the applicant. In addition, the staff conducted walkdowns that included the Byron and Braidwood stations' concrete containment structures exterior surfaces, vertical tendon galleries, and a representative sample of the containment buttresses containing horizontal hoop tendon anchorages. The staff also reviewed a number of pictures of end anchorages for dome, hoop, and vertical tendons and conducted an independent search of the applicant's operating experience database using such relevant keywords as: "IWL," "tendon,"

and "prestress."

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

Relevant Documents Reviewed Document Title I Revision/Date

1. Tendon Procedure, 70 Tendon Procedure 70 by Napoleon Steel Construction, j 0412811982 Inc.
2. Drawing S-884 Containment Building Ten don Location Plans &
  • Rev:sion H Sections, Byron Unit 1 & 2

' 3_ Tend on Report Evaluation of Tendon H4CB for Reduced Number of i 11/18/2011 I 5.2.2-BRW11-0141-S Wires Steam Generator Replacement Containment Opening

! 4. 23161-C-208 (BRW Unit1)

Tendon Details i 05/14/1996 5 23161-C-608 (BYR Unit1)

Steam Generator Replacement Containment Opening 1 03/25/1998 Tendon Details

6. 23161-C-209 (BRW Unit 1)

Steam Generator Replacement Containment Concrete

05/18/1998 Removal & Tendon Sheathino Details 7 23161-C-609 (BYR Unit1)

Steam Generator Replacement Containment Concrete 03/25/1998 Removal & Tendon S_heathing Details

8. 23161-C-210 (BRW Unit1)

Steam Generator Replacement Containment Openrng 05/18/1998 ReinforcinQ Details

9. 23161-C-610 (BYR Unit1)

Steam Generator Replacement Containment Opening 03/25/1998 Reinforcina Deta11s

10. 23161-C-211 (BRW Unil1)

Steam Generator Replacement Containment Opening I 05/18/1998 Liner Plate Details 11 23161-C-611 (BYR Unit 1)

Steam Generator Replacement Containment Opening 03/25/1998 Liner Plate Deta1ls

12. BB-AMP-PBD-X.S1 Concrete Contamment Tendon Prestress Program Rev_ 1 Basis Document 4/2_~/2013
13. ER-AA-330-006 lSI and Testing of the Prestressed Concrete Rev. 6 Conta1nment Post Tensioning System
14. 5.2.2-BYR12-093 (Unit 1)

Regression Analysis to Predict Post-Tensioning Forces Rev. 0 for Byron Unit 1 Containment Tendons in Support of 1/10/2013 License Renewal Regression Analysis to Predict Post Tensioning Forces Rev. 0

15. 5.2.2-BYR12-094 (Unit 2) for Byron Unit 2 Containment Tendons in Support of 1/10/2013 License Renewal Regression Analysis to Predict Post-Tensioning Forces
16. 5.2.5-BRW-12-0144-S (Un1t 1)

Rev. 0 for Braidwood Unit 1 Containment Tendons in Support 112112013 of License Renewal Regression Analysis to Predict Post Tensioning Forces Rev. 0

17. 5.2.5-BRW-12-0145-S (Unit2) for Braidwood Unit2 Containment Tendons in Support 1121/2013 of License Renewal Final Report For Exelon Byron Station U1 and U2 25 Rev_ A
18. BY-N1044-501 Year Containment Building and Tendon Surveillance-11/16/2009 PSC Contairlment Tendons-Predicted Lower Limit Forces Rev. 0
19. 5.2.2-BYR12-131 (Unit1)

During Period of Extended Operation - Byron Unit 1 1/10/2013

20. 5.2.2-BYR09-17 Calculation of Tendon Predicted Lift-Off Forces for the Rev_ 0 25 1~year lSI-Byron Unit 2 0412712009
21. 5.2.2-BRW-10-0154-S Selection of Tendons and Calculation of Lift Off Forces Rev_ 0 for 251h Year ISI-BRW Units 1 and 2 05/23/2011 Exelon Braidwood Station Unit 1 and 2 ASME Section
22. wo 728405 XI Class CC Structures 20'h Year Unbonded Post 01/12/2007 Tensioning System Surveillance Engineering Evaluation Report
23. AR 00477411 Ineffective wire discovered (BRW U2-Cont. Tendon 04/10/2006 V225) 201h vear Post-Tensioning Surveillance
24. AR 00499108 Tendon 01-02 (BRW U1-Low Yield Strength Observed 06/12/2006 Duri~g Wire Testl
25. AR 00781251 U-2 Containment Buttress F-EF Flooded, Tendon Cans 0513012008 Submecged (BYR)
26. AR 00240041 Gre~~e Leakage at Various U-1 Verttcal Tendons (BYR) 07/29/2004 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 "scope of program," "preventive actions," "parameters monitored," "detection of aging effects," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

For the "monitoring and trending," program element, sufficient information was not available to determine whether it is consistent with the corresponding program elements of the GALL Report AMP. To obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing the following RAI for the subject discussed below.

For the "monitoring and trending" program element the staff noted a discrepancy between the GALL Report AMP recommended approach for calculating trend lines based on the regression analysis of actual individual measured forces and the LRA AMP approach, which states that the analysis evaluates force trends by group (dome, hoop, vertical) and shows that group mean forces will not fall below applicable minimum required values (MRVs) prior to the end of the period of extended operation_ The staff may issue an RAI requesting the applicant to clarify if the regression analyses followed actual individual measured forces or mean group forces.

During the audit of the "operating experience" program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience. In order to obtain the information necessary to determine whether the applicant's operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

For the "operating experience" program element, the staff noted a discrepancy between the LRA program description, the reported operating experience, and plant procedure ER-M-330-006. The program description states that prestress tendon forces (TF) are measured every five years while ER-M-330-006 indicates that measurements occur at alternating ten year intervals. Operating Experience as reported in the LRA states that in 2009 and 2011, Byron and Braidwood, respectively, performed the 251h year interval ASME Section XI, Subsection IWL, examinations of the concrete containment tendons.

These examinations included testing to assess the loss of prestressing forces in select containment tendons consistent with IWL requirements. It is not clear whether Byron and Braidwood follow the modified lSI intervals consistent with IWL-2421 and procedure ER-M-330-006, to perform measurement of TF at alternating time frames for each unit (e.g., one unit fully examined per IWL-2500 on year 20 while the other on year 25), or if it examines, tests, and measures TF for both units at each site, every five years.

The staff also audited the description of the LRA AMP provided in the UFSAR 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," and "acceptance criteria" program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP X.S1. The staff also identified certain aspects of the program description and "monitoring and trending" program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined. The staff's evaluation of aspects of the program element associated with enhancements, which are not necessary for consistency, will be addressed in the SER.

Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicant's operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA AMP 8.3.1.3, Environmental Qualification (EQ) of Electric Components Summary of Information in the Application. The LRA states that AMP 8.3.1.3, "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.

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

environmental qualification."

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

Relevant Documents Reviewed Document Title I

Revision I Date I 1 BBS-PBD-AMP-Program Basis Document Environmental Qualification (EQ)

Revision 1, I

X.E1 of Electric Components 05101/2013 I

2 NES-G-14.02 Calculation No. BRW-01-0153-EfBYR01-068 Revision 2, 03/09/2001

3. AR01288474 Potential Green NCV Classification of EO Zones From HELB 11/09/2011
4. ER-AA-1100 Byron EQ Program: 3' Quarter 2008 2" Quarter 2013 N/A
5. ER-AA-1100 Braidwood Environmental Qualification (EQ) of Electric N/A Comooner~ts
6. LS-AA-126-1 001 FASA Self-Assessment Report Template: 2011 Byron Revision 6 Enwonmental Qualification
7. LS-AA-126-1 001 FASA Self-Assessment Report Template: 2012 Byron Revision 6 Environmental Qualification B EQ-BB-004 Byron/Braidwood Stations Equipment Qualification Binder Revision 8 Conax Resistance Tem~erature Detector
9. ER-AA-1100 Implementing and Management Engineering Program Revision 10 To~ AR01288474 HELB Modification Analysis N/A 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 LRAAMP 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 provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).

The staff also audited the description of the LRA AMP provided in the UFSAR 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 X.E1.

Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. ln addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.

LRA 4.7.3, Mechanical Environmental Qualification Time-Limited Aging Analysis Summary of Information in the Application. LRA Section 4.7.3, Mechanical Environmental Qualification," states that, "{q]ualified lives and replacement intervals are established for safety-related mechanical components located in harsh environments based on aging concerns."

Audit Activities. In order to obtain sufficient information to evaluate this plant-specific time-limited aging analysis (TlAA), during its audit, the staff interviewed the applicant's staff and reviewed onsite documentation provided by the applicant.

The table below lists the documents that were reviewed by the staff and were found to be relevant to the TLAA These documents were provided by the applicant Relevant Documents Reviewed

--Document I

Title Revision I Date 1.-- Not available Equipment Qualification Des1gn Program-Mechanical Revision 6 2 CC AA-203 Equipment Qualification Program Revision 8

3. EQOP MECH Pumps and Valves Volume 1 Revision 6 4.Eb-BB 052 Jamesbury Butterfly Isolation Valves and GH Bettis Actuators Revision 8
5. EO BB-044 Ingersoll Rand Containment Spray Pumps Revision 3
6. EQ-BB 047 Borg Warner Valves Revision 5
7. EO-BB 046 Masoneilan Control Isolation Valves Revision 5
8. EQ BB-051 Borg-Warner Main Feed Isolation Valves Revision 4
9. EQ-BB 043 Anchor Darling Main Steam Isolation Valves Revision 6

~Eo BB-045 W K-M Main Steam Power Operated Relief Valves Revision 2

11. EQ-BB 056 Borg Warner Main Steam Power Operated Relief Valve Revision 7 Hydraulic O~erator
12. EO-BB-010 Anchor Darling Gate Isolation Valves Revision 5
13. EO-BB-024
14. EQ BB-042 Anderson Greenwood Check Valves Revis1on 5
15. EQ BB-025 Borg Warner Ma1n Feed Isolation Valve Hydraulic Operators Revision 7C Document Title Revision J Date
16. EQ-BB-050 Tufline/Xomox Valves Revision 4
17. EQ BB-048 TRW Mission Check Valves Revision 2
18. EO-BB-049 TRW Mission Valves Revision 3

~-EZ409-4 Radiation Exposure Evaluation of Elastomeric Valve Seat Rev1sion A Materials

20. EQ ER-06 98-002 EQ Evaluation Request for PORVs 1 (2) TSV-RY455A and 1(2) 02122/1999

~

OEQ ER-00 97-FSV-RY456 EQ Evaluation to Address the Transient Changesflncreases in 08/01/1997 002 Sprav pH followinq a LOCA

22. EODP-MECH Tab EQDP-Mechanical Analysis of Phenolic Spacer Disc CV 01/13/2006 G58 Pumos 1/2 CV01 PA and PB
23. EODP-MECH Tab ITI Letter to Exelon-M1 EPDM Di-aphragm Operating 08/18!2008 G61 Env~lo~e Testing Summa!}'
24. 02-4854-RPT-1 Qualification of Valve Actuators for Nuclear Power Plants in 08/0411978 Accordance with SwRI Test Plan 02-4854-SP-1, Volume II-Wear Aqinq and Radiation Aqinq For documents 3 through 18, the generic title begins with, "Byron/Braidwood Station Equipment Qualification Binder." The staff reviewed Tab E, "Installation, Maintenance, and Surveillance Schedule," from these documents.

During the AMP audit the staff confirmed that each component or subcomponent in the plant-specific Equipment Qualification Design Program-Mechanical has specific replacement frequencies (i.e., qualified lives) as listed in individual mechanical component environmental qualification binders. Examples of the qualified lives are as follows as stated in the associated component environmental qualification binders.

(a)

Equipment Type Ill Check Valve with Soft Seat, EQDP-MECH, states, "[r]eplace the soft seat every 6 years (per vendor recommendation in Tab C. Ref. 2.8.7), unless justified otherwise based on new information or engineering evaluation of operating experience."

(b)

Equipment Type Safety-Related Large Pumps, EQDP-MECH, states that the qualified life is 60 years subject to replacement of items such as silicone rubber 0-ring of oil filter housing at or before 40 years and viton gaskets are replaced at or before 42.4 years.

(c)

Equipment Type Safety-Related Air Operated Valves, EQDP-MECH, states that the qualified life is 60 years subject to replacement of Dacron/Silicone Rubber diaphragm with a qualified life of 8.022 years.

(d)

Masoneilan Control Isolation Valves, EQ-88-046, states, that the qual1f1ed life of the valves is 60 years while the qualified life of the Model 77 -N-4 regulator, associated with the valve, is 6.47 years.

(e)

Jamesbury Water Sphere 8000 Series Butterfly Valves and GH Bettis Actuators, EQ-BB-052, states that the valves and actuators have associated lives of 60 years and 40.5 years respectively.

(f)

Phenolic Spacer Disc CV Pumps 1/2 CV01 PA and PB, EQDP-MECH, Tab G58, states that the pumps have a life of 12,956 years based on radiation and temperature data.

(g)

Borg-Warner Main Steam Power-Operated Relief Valve, EQ-88-056, states that the valves have a life of 46 years subject to replacing the viton Parker 0-ring at 15 years.

The staff reviewed the supporting documentation used to establish the qualified life for several of the components (see documents 19 through 24, above) and verified that the replacement frequencies were based on IEEE 323-1974 qualification tests or published material aging data.

The staff notes that LRA Section 4.7.3 states, The results of qualification tests or other published material aging data have been documented in individual mechanical component Environmental Qualification Binders. Since some of the variables analyzed are based upon 40-year assumptions, these qualifications have been identified as TLAAs that require evaluation for the period of extended operation.

During the AMP audit, the staff verified that approximately two-thirds of the components within the scope of this TLAA have been analyzed for the impact of a 60-year life. The staff noted an example of this during its review of EQDP-MECH where all the components cited in this binder had been re-evaluated for a 60 year life. Replacement frequencies varied, resulting in qualified lives ranging from less than 40 years to much more than 60 years. The plant-specific program requires that a component or subcomponent be replaced when it has reached the end of its qualified life. During the AMP audit, the applicant stated that the re-analysis of an aging evaluation for mechanical components to extend the qualification of components is performed on a routine basis. The applicant stated that the remaining one-third of components within the program will either be replaced at the end of their qualified lives or the applicant will perform evaluations to determine if the qualified life can be extended. The staff also reviewed the Equipment Qualification Program and verified that this procedure requires that the station environmental qualification engineer conducts the review of all changes to the Environmental Qualification Binders.

During its review of Tab E. "Installation, Maintenance, and Surveillance Schedule," in each of the Byron/Braidwood Station Equipment Qualification Binders, the staff noted that for most of the binders the document stated that there were either no surveillance requirements, or the following surveillances were required:

Use of the ASME Code Section XI Subsection IWP, lnservice Testing of Pumps in Nuclear Power Plants Program Use of the ASME Code Section XI, lnservice Inspection Program The above programs are required to be implemented by 10 CFR Part 50 and therefore, no specific aging management activities are required beyond the inspections implemented by the two AS ME-based programs.

The staff considered the need for additional information regarding the following subject. Five of the binders stated unique requirements beyond those stated above as follows:

Binders EQ-BB-044 and EQ-BB-045 state that inspections of exposed parts should be conducted every fuel load outage. The binders also stated that, "[a)ny indication of aging related degradation must be investigated, and necessary maintenance and replacement requirements shall be added. Arrangements shall be made to replace the affected component immediately." The staff noted that the scope of binders EQ-BB-044 and EQ-BB-045 include the containment spray pumps and main steam power operated relief valves.

Binder EO-BB-051 states that visual inspections should be conducted for packing and gasket leaks. The staff noted that the scope of binder EQ-BB-051 includes the main feed isolation valves.

Binder EQ-BB-056 states that during maintenance activities the operator assembly should be checked for oil leakage. The staff noted that the scope of binder EQ-BB-056 includes the main steam power-operated relief valve hydraulic operator.

Binder EQ-BB-025 states that every quarter visual inspections of area of the coupling for oil leaks should be conducted, the leak monitoring hole should be inspected for hydraulic fluid and pneumatic leakage, the hydraulic oil should be sampled quarterly, and every refueling outage the hydraulic fluid should be replaced and analyzed. The staff noted that the scope of binder EQ-BB-025 includes the main feed isolation valve hydraulic operators.

The staff noted that while the containment spray pumps are within scope, LRA Table 3.2.2-2 states that there are no aging effects requiring management and no AMP is recommended. The staff also noted that components such as the main steam power-operated relief valve and main feed isolation valve hydraulic operators are not included in the system AMR tables. The staff noted that the above EO binders include active components and the surveillance schedules are associated with subcomponents that would typically be identified as consumable items such as 0-rings and gaskets. The staff also noted that the consumable items all have specified replacement frequencies. SRP-LR Table 2.1-3, "Specific Staff Guidance on Screening," states, in part, that some categories of consumables. "are usually short-lived and periodically replaced, and can normally be excluded from an AMR on that basis." However, TLAA 4. 7.3 specifically addresses these components and subcomponents.

It appears to the staff that the surveillance (condition monitoring) activities described in the EO binders are required to be performed to ensure that the subcomponents will meet the qualified lives described in general in TLAA Section 4. 7.3. It is not clear to the staff that the above surveillance (condition monitoring) requirements, as described in the EO binders, have been incorporated into aging management programs.

Audit Results. Based on this audit, the staff verified that (a) each component in the plant-specific Equipment Qualification Design Program-Mechanical has specific replacement frequencies, (b) component and subcomponent replacement frequencies are based on IEEE 323-1974 qualification tests or published material aging data, and (c) components and subcomponents are replaced at the end of their qualified lives or the applicant performs an evaluation to determine if the qualified life can be extended.

Based on this audit the staff also found that additional information is required before a determination can be made that surveillance requirements described in the Byron/Braidwood Station Equipment Qualification Binders are included in an aging management program.

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