ML14072A369

AMP Audit Enclosure (3)

ML14072A369
Person / Time
Site:	Byron, Braidwood
Issue date:	03/13/2014
From:	Division of License Renewal
To:	Exelon Generation Co
Robinson L, 415-4115
References
TAC MF1879, TAC MF1880, TAC MF1881, TAC MF1882
Download: ML14072A369 (97)

Text

ENCLOSURE 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, DLR 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, DLR 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 O. 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. Istar, Structural Engineer, DLR C. Doutt, Sr. Electrical Engineer, DLR D. Nguyen, Electrical Engineer, DLR R. Li, Electrical Engineer, DLR 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 applicants 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

10) 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 staffs safety evaluation report (SER).

NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), Revision 2, dated December 2010, provides staff guidance for reviewing 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 applicants 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 applicants AMPs were claimed to be consistent with the GALL Report and were audited against the related elements of the associated AMP described in the GALL Report, unless otherwise indicated in this audit report. Elements seven through nine (corrective actions, confirmation process, and administrative controls) were audited during the scoping and screening methodology audit conducted at Byron July 29 to August 2, 2013, and at Braidwood December 2 to December 4, 2013; the scoping 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 performing the audit, the staff examined the applicants LRA, program-bases documents, and related references; interviewed various applicant representatives; and conducted walkdowns of several plant areas. In total, 45 AMPs were reviewed and 69 breakout (discussion) sessions with applicant representatives were conducted. This report documents the staffs activities during the audit.

LRA AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Summary of Information in the Application. The LRA states that AMP B.2.1.1, ASME Section XI Inservice 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 XI Inservice Inspection, Subsections IWB, IWC, and IWD. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M1 Program Basis Document: ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD Revision 1, 5/1/2013

2. AR 01254938 ISI Program FASA 08/24/2011

3. AR 01231119 ISI Program FASA 06/29/2012

4. AR 01357298 UT Indication on Unit 1 CRDM Nozzle #69 04/23/2012

3. LER 455-2011-002 Licensee Event report 2011-002-00, Unit 1 Reactor Pressure Vessel Head Penetration Nozzle Weld Flaws Attributed to Primary Water Stress Corrosion Cracking 5/18/2011

4. AR 00177514 Unit 1 RPV Lower Head Condition, B1R12 Exam Results 9/25/2003

5. LER 456-2011-001 Through Wall Cracking on 1A Safety Injection Pump Discharge Line Due to Outside Diameter (Transgranular) Stress Corrosion Cracking Initiated at External Diameter of Pipe 04/26/2011

6. LER-455-2009-001 Supplemental to Reactor Coolant System Leakage Characterization Resulting in a Condition Prohibited by Technical Specifications 02/10/2010

7. M-02619-98 System Materials Analysis Department Report on the Evaluation of a Safety Injection Line Failure at Byron Station 04/08/1998

8. LS-AA-126-1001 FASA Self Assessment Report Revision 6

9. LTR Byron 2006-0009 Submittal of Analytical Evaluation of Pressurizer Seismic Restraint Lug Indications 01/11/2006 Document Title Revision / Date

10. EC374961 Evaluation for Indication on Shear Lugs Westinghouse NDE Report #A1R14-MT-0001 04/22/2009

11. LER454-2012-004 Unit 1 Reactor Pressure Vessel Head Control Rod Drive Mechanism Penetration Nozzle Weld Repair Surface Indication 11/12/2012

12. IR 01166795 Exelon Power Lab, Evaluation of a Socket Weld Leak in Line 2CV02G-2 at Braidwood Station 06/21/2011

13. AR 00601691 ASME XI UT Inspection Code Coverage Issues on RHR Hx Vessels 04/17/2007

14. AR 00979896 NRC Identified 2A RHx Weld Indication Not Dispositioned 10/15/2009

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

16. AR 01128840 ANI not Given Opportunity to Review Code Weld Package on Hx 10/21/2010

17. AR 01399058 2Q2012 - NRC Green NCV - A1R16 - ISI - UT Speed in Procedure 08/09/2012 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed 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 staffs 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 B.2.1.2, Water Chemistry Summary of Information in the Application. 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M2 Water Chemistry - GALL Program XI.M2 - Water Chemistry Revision 1

2. CY-AP-120-1000 Primary Strategic Water Chemistry Plan for Recirculating Steam Generator Plants Revision 010

3. CY-AP-120-100 Reactor Coolant System Chemistry Revision 018

4. CY-AP-120-2000 Secondary Strategic Water Chemistry Plan for Recirculating Steam Generator Plants Revision 012

5. CY-AP-120-200 Recirculating Steam Generator Chemistry Revision 009

6. CY-AP-120-170 Refueling Water Storage Tank/Borated Water Storage Tank Chemistry Revision 6

7.

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

8.

Review of Primary and Secondary Cycle Chemistry - Braidwood Unit 1, Fuel Cycle 16, by ChemStaff, November 28, 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, 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 staffs 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 B.2.1.3, Reactor Head Closure Stud Bolting Summary of Information in the Application. The LRA states that AMP B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/

Date

1. BwMP 3100-008 Braidwood Reactor Vessel Closure Head Installation Revision 34A

2. BwMP 3100-009 Braidwood Reactor Vessel Closure Head Removal Revision 21A

3. BMP 3118-1 Byron Reactor Vessel Closure Head Removal Revision 33

4. BMP 3118-7 Byron Reactor Vessel Closure Head Installation Revision 42

5. ER-AA-330 Conduct of Inservice Inspection Activities; Common Revision 09

6. ER-AA-330-001 Section XI Pressure Testing; Common Revision 10

7. ER-AA-330-002 Inservice Inspection of Section XI Welds and Components; Common Revision 10

8. ER-AA-330-009 ASME Section XI Repair/Replacement Program; Common Revision 06

9. BB-PBD-AMP-XI.M3 BBS Reactor Head Closure Stud Bolting Revision 01

10. AR 01061227 Byron Unit 2 Vessel Head Closure Bolt # 11 vs. TS Table 1.1-1 04/25/2010

11. AR 00105295 Overboring of Reactor Stud Hole # 35 Counterbore 04/25/2002

12. AR 01549725 PTLR Analysis Not Revised for Rx Head Stud Configuration Change 08/22/2013

13. CCE-91-275 Commonwealth 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

16. AR 01549725 License Renewal Personnel Misinterpret Site Procedures 12/04/2013

17.

Unit 2 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 staffs independent operating experience search of the applicants onsite database indicated that the applicants operating experience was not bounded by known industry operating experience.

Specifically, the applicants 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 2s 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 applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.

The applicants 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 applicants 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 applicants 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 B.2.1.4, Boric Acid Corrosion Summary of Information in the Application. The LRA states that AMP B.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 LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: boric, BAC, 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M10 Program Basis Document, Boric Acid Corrosion Revision 1

2. ER-AP-331 Boric Acid Corrosion Control (BACC) Program Revision 6

3. ER-AP-331-1001 Boric Acid Corrosion Control (BACC) Inspection Locations, Implementation and Inspection Guidelines Revision 6

4. ER-AP-331-1002 Boric Acid Corrosion Control Program Identification, Screening, and Evaluation Revision 7

5. ER-AP-331-1003 RCS Leakage Monitoring and Action Plan Revision 5

6. ER-AP-331-1005 Boric Acid Corrosion Control (BACC) Program Performance Indicators Revision 3

7. NA Byron - Boric Acid Corrosion 1st Quarter 2013 Program Health Report First Quarter, 2013

8. NA Braidwood - Boric Acid Corrosion 1st Quarter 2013 Program Health Report First Quarter, 2013

9. LS-AA-126-1001 Braidwood Station Boric Acid Corrosion Program Focused Area Self Assessment (FASA)

Revision 5

10. ER-AA-330-001 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 staffs review of the program basis document, BB-PBD-AMP-XI.M10, the staff noted that the applicants 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 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.M10.

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 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 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M11B Program Basis Document: Cracking of Nickel Alloy Components and Loss of Material Due of Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Revision 1, 5/6/2013 Document Title Revision / Date

2. BYRON 2007-0072 Licensee Event Report (LER) 455-2007-001-00, Reactor Pressure Vessel Head Control Rod Drive Mechanism Penetration Nozzle Weld Indication Due to an Initial Construction Weld Defect Allowing the Initiation of Primary Water Stress Corrosion Cracking 6/8/2007

3. BYRON 2008-0119 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 Reactor Pressure Vessel Heads at Pressurized Water Reactors 12/5/2008

4. Byron Ltr 2011-0082 Licensee Event Report 2011-002-00, Unit 1 Reactor Pressure Vessel Head Penetration Nozzle Weld Flaws Attributed to Primary Water Stress Corrosion Cracking 5/18/2011

5. Byron 2006-0134 Byron Station Unit 1, 60-Day Response to NRC Bulletin 2004-1, Inspection of Alloy 82/182/600 Materials Used on the Fabrication of Pressurized Penetrations and Steam Piping Connections at Pressurized Water Reactors 12/6/2006

6. BYRON 2010-0042 Byron Station Unit 2, 90-Day Inservice Inspection Report for Interval 3, Period 2 (B2R15) 8/3/2010

7. BYRON 2003-0114 Byron Station Unit 1, 60-Day Response to NRC Bulletin 2003-02, Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity 12/12/2003

8. AR 00615484 B2R13 - PT Indications Discovered at CRDM Penetration 68 4/10/2007

9. AR 01189229 B1R17 CRDM Inspection - Volumetric Ultrasonic Indication 3/18/2011

10. AR 01460556 LR UFSAR Table 3.2-1 Thermal Sleeve Safety Class Error 1/9/2013

11. AR 01190247 Loss of UT Data Above J-groove Weld on Penetrations 04 & 08 3/21/2011

12. AR 00623331 Need to Perform Thermal Sleeve UT 4/30/2007

13. AR 01460556 LR UFSAR Table 3.2-1 Thermal Sleeve Safety Class Error 1/9/2013

14.

Braidwood Nuclear Power Station Units 1 & 2, ISI Program Plan:

Third Ten-Year Inspection Interval Revision 6, 4/21/2012

15. BAP 1210-1T1 Byron Station Plant Review Report: Third Ten-Year ISI Program Plan Volume 1, Revision 6 Revision 11, 3/26/2011

16. AR 00177514 Unit 1 RPV Lower Head Condition, B1R12 Exam Results 9/25/2003

17.

Exelon Powerlabs Evaluations of a Boat Sample from the

1. 68 CRDM Penetration on Byron Unit 2 5/23/2007

18. LTR-MRCDA-11-67 Justification of Wear Indication on Inside Surface of Byron Unit 1 CRDM Housings Revision 2, 4/18/2011

19. CCE-12-94 Transmittal of LTR-RIDA-12-94, Rev. 1 - Penetration 69 Thermal Sleeve Revision 1, 4/27/2012

20. AR 01357298 UT Indication on Unit 1 CRDM Penetration 69 4/23/2013

21. CR 1558555 A1R17 PT Indications in Embedded Flaw Repair of CRDM Penetration 69 9/14/2013

22. EC 395417 Technical Evaluation Disposition of Boric Acid Residues Identified on Reactor Head Components AR17 Mode 3 Exams and During Extent of Condition Examinations 9/09/2013 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 staffs 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 applicants program. The staff will consider issuing RAIs 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 applicants 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 applicants 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 applicants 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 applicants 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 applicants 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 B.2.1.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

Summary of Information in the Application. The LRA states that LRA AMP B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M12 Program Basis Document: Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Revision 1, 5/3/2013

2. Byron 2011-0103 Byron Station Unit 1 90-Day Inservice Inspection Report for Interval 3, Period 2 (B1R17) 7/21/2011

3. BAP 1210-1T1 Byron Station Plant Review Report: Byron Station 3rd Interval ISI Program Plan Vol. 3 ISI Selection Document, Rev. 0 Revision 10, 9/9/2006

4. BW110012 Braidwood Station Unit 1 Inservice Inspection Summary Report 2/4/2011

5. BW100010 Braidwood Station Unit 2 Inservice Inspection Summary Report 1/27/2010

6. CRDM-01-017 Cast Latch Housing 8/23/2001

7. AR 00152254 Crack Identified on 1A RH Pump Diffuser 04/03/2003 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 applicants 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 applicants 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 performed 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 applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.

LRA Section B.2.1.6 includes a section that discusses operating experience related to the applicants 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 applicants 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 applicants 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 B.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 applicants program basis document and the applicants response to applicant/licensee action items (A/LAI) to MRP-227-A, which included any supporting references and documents, inspection results from previous vessel internal inspections, and Exelons 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 applicants exception was to ensure its PWR Vessel Internals Program is consistent with Draft LR-ISG-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 applicants 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.16A Program Basis Document - GALL Program XI.M16A - PWR Internals Revision 1, 05/17/2013

2. AR00685151 Broken leaf found on guide tube assembly J13 0 degree 10/15/2007

3. AR00684704 A1R13 LL - Broken leafs found during split pin replacement 10/15/2007

4. EC000349590 Engineering Change - Replace Control Rod Drive Support Pins with Materials Resistant to Primary Water Stress Corrosion Cracking - Byron Unit 1/2

5. EC000349592 Engineering Change - Replace Control Rod Drive Support Pins with Materials Resistant to Primary Water Stress Corrosion Cracking - Byron Unit 1/2

6. EC0000360473 Alloy 600 U1 RX Vessel Control Rod Guide Tube Split Pin Replacements - Braidwood Unit 1

7. EC0000360474 Alloy 600 U1 RX Vessel Control Rod Guide Tube Split Pin Replacements - Braidwood Unit 2

8. Work Order 00617445 Visual Exam of the Reactor Pressure Vessel Interior Includes B-N-3 Examination Results - Byron Unit 1, R13

9. AR00310817 B1R13 Material Found at Bottom of Reactor Vessel 03/10/2005

10. Work Order 00856130 Visual Exam of the Reactor Pressure Vessel Interior Includes B-N-3 Examination Results - Byron Unit 2, R13

11. Examination Results - Braidwood Unit 1 B-N-3 Examination Results - A1R16 A1R16

12. Examination Results - Braidwood Unit 2 B-N-3 Examination Results - A2R16 A2R16

13. AR00770884 FME Event - A2R13 -Initial Foreign Object Search and Retrieval - Foreign Object Identified

14. AR01361865 Foreign Material Identified on Lower Core Plate 05/03/2012

15. EC0000370641 Lost parts evaluation for foreign object observed on reactor vessel lower internals support ledge - Braidwood Unit 2 05/12/2008

16. WCAP-13266 Baffle Former Bolt Program for the Westinghouse Owners Group - Phase 1: Plant Categorization March 1992 Document Title Revision / Date

17. LTR-RIAM-13-16, Rev.0 Final Reports for Braidwood Unit 1, Braidwood Unit 2, Byron Unit 1, and Byron Unit 2 for PWROG PA-MSC-0983 Cafeteria Tasks Deliverables 06/04/2013

18. LTR-RIAM-13-28 MRP-191 Failure Modes, Effects, and Criticality Analysis (FMECA) Impact Assessment as a Result of Alternate Materials for Byron Units 1 and 2 and Braidwood Units 1 and 2 05/10/2013

19. Email to Gary Becknell (Exelon) from Charles Meyer (Westinghouse)

RE: Byron and Braidwood RX Internal Questions June 20, 2012 -

3:33pm

20. Design Specification - 952630 Specific Design Specification - Nuclear Reactor Internals and Instrumentation Port Column Assembly Rev. 6, 11/15/1989

21. RE-CS-395 Conversion of Lower Core Support Cast Dome to a Flat Plate Design (flat forged plate)

January 26, 1971

22. Work Order 01267563 Visual Exam of the Reactor Pressure Vessel Interior Includes B-N-3 Examination Results - Byron Unit 1, R17

23. Work Order 01481167 Visual Exam of the Reactor Pressure Vessel Interior 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, Attachments and Interiors of Reactor Vessels Revision 17

27. AR01433842 Reactor Upper Internals Measurement Uncertainty October 31, 2012

28. AR01432409 FME: Core barrel foreign object from A2R13 removed/relocated October 28, 2012

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 applicants 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 staffs review of the program elements included the exception. In addition, the staff found that for the applicants responses to A/LAI 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 applicants responses to the A/LAI items are adequate, the staff will consider issuing RAIs for the subjects discussed below.

The applicants responses to A/LAI 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 performed for these two components is needed to assess the applicants responses.

The applicants response to A/LAI No. 3 states there are no vendor specific requirements to inspect the replacement control rod guide tube (CRGT) split pins; however, through the stations 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 applicants 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 III, 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 applicants 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 A/LAI 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 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. In addition, the staff noted that as part of implementing MRP-227-A, the applicant will provide 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 XI.M16A as amended by Draft LR-ISG-2011-04 and Final LR-ISG 2011-04. The staff also identified certain aspects of the applicants 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 B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database for the Byron and Braidwood Stations using the keywords related to flow-accelerated corrosion (FAC): 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date BB-PBD-AMP-XI.M17 Program Basis Document Flow-Accelerated Corrosion Revision 1 ER-AA-430 Conduct of Flow Accelerated Corrosion Activities Revision 5 ER-AA-430-1001 Guidelines for Flow Accelerated Corrosion Activities Revision 7 Document Title Revision / Date ER-AA-430-1002 Feedwater Heater Shell Inspection Revision 4 ER-AA-430-1004 Erosion in Piping and Components Guide Revision 0 NES-MS-03.1 Piping Minimum Wall Thickness Calculation Revision 5 IT-AA-101 Digital Technology Software Quality Assurance Procedure Revision 8 IT-AA-101-1001 DTSQA Classifications Revision 7 WO 01450663 FAC Activities Byron 1 Refuel 18 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 1SD01K Elbow 09/21/12 WO 01306880 FAC Activities Byron 1 Refuel 17 Summary Report 03/14/11 WO 01358402 FAC Activities Byron 2 Refuel 16 Summary Report 09/19/11 AR 01362960 Br1 Erosion Identified in Drain Pipe for Component Cooling Pump 1CCA6AC-3/4-inch 05/05/12 AR 00292875 Br FAC Program Documents Require Update 01/20/05 AR 00550067 A2R12 - 14, Visual Inspection of Steam Generator Steam Drum Region 10/27/06 AR 01199165 FAC Web-Based Database Missing Information 04/07/11 6200.106-01 CSI Technologies Report, Braidwood Unit 1, CHECWORKS SFA Update for Measurement Uncertainty Recapture Revision 0 6200.106-02 CSI Technologies Report, Braidwood Unit 2, CHECWORKS SFA Update for Measurement Uncertainty Recapture Revision 0 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, detection 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 SNM1DV006-1 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 1SD319 and notes impingement damage on the elbow. Although LRA Section B.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 B.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 DD, Screened, which do not require any validation or verification in accordance with Exelons 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 FAC 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 applicants implementing procedures.

During the audit of the operating experience program element, the staffs 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 B.2.1.9, Bolting Integrity Summary of Information in the Application. The LRA states that AMP B.2.1.9, Bolting Integrity, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M18, Bolting Integrity. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. The scope of this audit report includes enhancements necessary to make the LRA AMP consistent with the corresponding GALL Report AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M18 Program Basis Document, Bolting Integrity Revision 1

2. ER-AA-330-001 Section XI Pressure Testing Revision 10

3. ER-AA-330-002 Inservice 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 Bolted Connections Revision 4

6. BMP 3122-4 Essential Service Water Make-up Repair Revision 16

7. BwMP 3300-091 Lake Screen House Diver Related Inspections Revision 25

8. AR 01141591 2A DG Emergency Stopped Due to Oil Leak 11/17/2010

9. ER-AA-2003 System Performance Monitoring and Analysis Revision 9

10. PMID 00174169-01 0A WW PP 10 YR Rebuild NA

11. PMID 00174170-01 0B WW 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 (6B FP)

NA

15. PMID 00039099 0FP03PA-M Refurbishment NA

16. PMID 00039101 0FP03PB 6-Year Maintenance NA

17. PMID 00099262 Perform Inspection (3A FP)

NA

18. PMID 00099266 Perform Inspection (3B FP)

NA

19. PMID 00099267 Inspect or Replace Pump (6A FP)

NA

20. PMID 00099270 Inspect or Replace Pump (6B 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 (PMIDs 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 protection 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 staffs 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 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.M18. The staffs evaluation of the applicants 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 B.2.1.10, Steam Generators Summary of Information in the Application. The LRA states that AMP B.2.1.10, Steam Generators, is an existing program with enhancements and an exception that is consistent with the program elements in GALL Report AMP XI.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M19 Steam Generators Revision 1, 05/01/2013

2. ER-AP-420-001 Byron/Braidwood Unit 1: Steam Generator Eddy Current Activities Revision 10

3. ER-AP-420 Steam Generator Management Program Revision 11

4. CY-AP-120-340 Primary-to-Secondary Leak Program Revision 6 Document Title Revision / Date

5. CY-AP-120-1000 Primary Strategic Water Chemistry Plan for Recirculating Steam Generator Plants Revision 10

6. CY-AP-120-2000 Secondary Strategic Water Chemistry Plan for Recirculating Steam Generator Plants Revision 12 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 staffs evaluation of aspects of this program element associated with the exception will be addressed in the SER.

During the audit of the operating experience program element, the staffs 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 staffs 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 B.2.1.11, Open-Cycle Cooling Water System Summary of Information in the Application. The LRA states that AMP B.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 applicants staff and reviewed onsite 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / 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-340-1001 GL 89-13 Program Implementation Instructional Guide Revision 9

4. ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide Revision 5

5. ER-AA-340-2000 Balance-of-Plant Heat Exchanger Inspection, Testing, and Maintenance Guide Revision 6

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

8. BVP 800-30 Essential Service Water Fouling Monitoring Program (GL 89-13 Program Basis Document)

Revision 14

9. BAP 560-3 Byron Cooling Water Chemistry Monitoring Program Revision 10

10. 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 05/21/11

13. AR00950907 Inadequate Follow-Up for Failed DG Hx Coatings 08/07/09

14. WO00999972-01 Examination of 1SXA9A-6 01/31/2008

15. WO01282977-01 Examination of 1SXB7A-8 01/25/2010

16. WO1103391 Examination of 0SX97AC-24 04/21/2010

17. WO01346601 Examination of 2SXA9A-6 09/25/2011

18. Drawing M-946 Chemical Feed System Quill Design and Installation Details Essential Service Water (SX) Units 1 and 2 Revision C 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 applicants 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 III (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 Exelons 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 staffs 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 B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: corros, erosi, crack, pit, microbiologic, MIC, 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M21A 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 Component Cooling Second Quarter, 2013

5. NA System Health Report, Braidwood Common Unit, Unit 1, and Unit 2 Component Cooling Second Quarter, 2013

6. NA Closed Treated Water Systems Program Summary, Bryon and Braidwood, Units 1 and 2 NA

7. BB-AMRBD-MEAE Materials, Environments, and Aging Effects - Aging Management Review Basis Document Revision 2

8. AR 01243542 Erosion found on the 0WO02CA west end condenser water box 7/25/2011

9. WO 01365423 0CC01A Eddy Current Testing and Inspection 2/6/2012

10. Drawing 4618D97 Byron Units 1 and 2 Component Cooling Water Heat Exc. Inlet and Outlet Tube Plate Assembly (Clad) 3/5/2007

11. Drawing 878C789 Braidwood Units 1 and 2 Heat Exchanger Tube Plate Complete 6/18/1974 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 applicants 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-AA-120-400, Closed Cooling Water Chemistry, and confirmed that the applicants 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 MIC 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 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.

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 B.2.1.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. The LRA states that AMP B.2.1.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M23, Inspection of Overhead Heavy 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Aging Management Program Basis Document Revision 1

2. MA-AA-716-021 Rigging and Lifting Program Inspection Procedure Revision 21

3. MA-AA-716-022 Control of Heavy Loads Program Revision 11

4. AR 00144059 Fuel handling crane problems were discovered during yearly crane inspection.

Leakage on the south bridge motor oil seals North bridge motor cover missing hold down bolts and was broken off 02/07/2003

5. AR 00199448 Condition report on problems found during crane inspection found during yearly turbine building crane inspection 01/26/2004

6. 0BMSR HC-3 Fueling Handling Building Overhead Traveling Bridge Crane Monthly/Yearly Inspection Revision 10

7. AR 00180292 Loose bolting on main steel girder rail connecting plate. This mechanical connection could cause a concern if the bolting becomes dislodged and falls into the reactor cavity.

10/09/2003

8. AR 00651354 NRC Concern with Bypassing FHB Crane Interlocks 07/18/2007

9. AR 00662034 Fuel Building Crane Trolley Rubbing Rail at Rail Joint/Tie 08/18/2007

10. AR 01116777 Trolley Gear Box Bound and Degraded Gear Teeth 09/23/2010 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.

During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

During the audit of the operating experience program element, the staffs 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 B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M24 Compressed Air Monitoring - GALL Program XI.M33 -

Compressed Air Monitoring Revision 1 Byron Action Request Report (ARs)

2. AR 00531203 Instrument air line associated w/FW reg valves fretting 09/15/2006

3. AR 00660181 Small instrument air leak upstream of 2MS004D-I/A 08/14/2007

4. AR 00719605 Loss of station air and instrument air 01/08/2008

5. AR 00883117 NRC IDed def tag in field that should have been removed 02/20/2009

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 IB U-2 instrument air system components/piping 04/15/2013 Document Title Revision / Date

9. AR 01532845 Significant I/A leak near 2CD210A 07/06/2013 Braidwood Action Request Reports (ARs)

10. 00121753 IA dewpoint measurement out of spec - high 09/05/2002

11. 00359833 IA Leak Upstream of Valve 08/04/2005

12. 00426295 Conflict Between UFSAR and BWVS Acceptance Criteria 11/21/2005

13. 00585962 Elbow on Air Line Degraded 01/31/2007

14. 00678074 Instrument Air Leak Near 1B SI Accumulator 10/01/2007

15. 00766438 I/A Leak Upstream of Isolation Valve for 2LC-H0101 04/23/2008

16. 00821267 Water in Station Air Penetration 09/23/2008

17. 00935919 Acceptance Criteria per BWVS 800-2 Not Met on IA Sampling 06/26/2009

18. 01005631 Copper Tubing Leaking Air 12/15/2009

19. 01196316 Degradation of Instrument Air Tubing Within 1CV01FA Vault 04/01/2011

20. 01212894 2ES032A Instrument Air Supply Leak 05/06/2011

21. 01522808 Instrument Air Sampling Acceptance Criteria Not Met 06/08/2013

22. 01530460 IA Dewpoint Sampling Re-Test from 6/7 - Results 06/28/2013 Byron Procedures

23. 0BOSR IA-2 Unit Zero Quarterly Instrument Air Testing Revision 0

24. 0BOSR IA-3 Unit Zero Instrument Air Dryer Testing Revision 0

25. 1BOSR IA-3 Unit One Instrument Air Dryer Testing Revision 1

26. 2BOSR IA-3 Unit Two Instrument Air Dryer Testing Revision 0

27. 1BOSR IA-R1 Instrument Air Surveillance For Refuel Outages Revision 3

28. 2BOSR IA-R1 Instrument Air Surveillance For Refuel Outages Revision 2

29. 0BOSR IA-W1 Instrument Air Dryer Weekly Surveillance Revision 5 Braidwood Procedures

30. BwVS 800-2 Instrument Air Sampling Requirements Revision 7

31. 0BwOS IA-W1 Instrument Air Dryer Weekly Surveillance Revision 11

32. BwMS 3150-004 Unit 0 Instrument Air Dryer Filter Changeout Surveillance Revision 2E1

33. BwMS 3150-005 Unit 2 Instrument Air Dryer Filter Changeout Surveillance Revision 1E1

34. BwMS 3150-006 Unit 1 Instrument Air Dryer Filter Changeout Surveillance Revision 4

35. BwMP 3305-057 Disassembly/Reassembly of Anderson Greenwood Wafer Check Valves (Type CV1B)

Common Procedures

36. ER-AA-700-405, Draft Compressed Air Monitoring Aging Management Program Revision 0A

37. MA-AA-733-1001, Draft Guidance for Check Valve General Visual Inspection Revision 7 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 staffs evaluation of aspects of this program element associated with the exception will be addressed in the SER.

During the audit of the operating experience program element, the 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 staffs 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 B.2.1.15, Fire Protection Summary of Information in the Application. The LRA states that AMP B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: carbon dioxide, CO2, 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M26 Fire Protection - GALL Program XI.M26 - Fire Protection Revision 1 Byron Action Request Reports (ARs)

2. 00168282 RSH CO2 tank level trending down 07/19/2003

3. 00264702 10 Ton CO2 Tank Trend Shows Slow Loss of Level 10/18/2004

4. 00365171 RSH CO2 Tank Level Less Than TRM Minimum 08/21/2005

5. 00442526 Turbine Bldg CO2 Tank Losing Inventory 01/16/2006 Document Title Revision / 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 of Degraded Fire Barriers 09/07/2007

10. 01020924 Missing Fireproofing on Structural Steel 01/25/2010

11. 01055128 ODSD461 Door Fails Semi-Annual Inspection 04/10/2010

12. 01126376 Degraded Fire Proofing 10/14/2010

13. 01289049 Fireproofing on Column Outside 1B AF Pump Room Degraded 11/10/2010

14. 01145445 River Screen House CO2 Tank Level Trending Down at 1% Daily 11/28/2010 Braidwood Action Request Reports (ARs)

15. 00250423 Fireproofing Needs Repair on Beam 09/07/2004

16. 00357743 Deficient DO Piping Fire Wrap in 2B D/G Room 07/28/2005

17. 00357752 Deficient DO Piping Fire Wrap in 1B D/G Room 07/28/2005

18. 00571309 Small Halon Leaks @ 4 UCSR Halon Bottles 12/19/2006

19. 00696549 NOS Adverse Finding: Inoperable and Degraded Fire Barriers 11/08/2007

20. 00760718 Upper Cable Spreading Rm Degraded Seal E0383301 04/08/2008

21. 00774899 PBI# 11243 Degr. Struct Steel Fireproofing - U1 Cable Tunnel 05/13/2008

22. 00776231 PBI #11251 Fireproofing is Breached Exposing Web of Beam 05/15/2008

23. 00780238 Caulk Missing from Thermafiber in Fire/Vent Barrier 05/28/2008

24. 01033161 CO2 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 Revision 5

27. 0BVSR 10.g.8-1 Fire Rated Assemblies Visual Inspection Revision 11

28. 0BVSR 10.g.6-1 Fire Barrier Penetration Visual Inspection 18 Month Surveillance Revision 10

29. 0BMSR 3.10.g.4 Fire Door Semi-Annual Inspection Revision 14

30. 0BMSR 3.10.g.7 TRM Fire Damper 18-Month Visual Inspection Revision 14

31. 0BMSR 3.10.e.2 Upper Cable Spreading Room Halon 1301 Fire Protection System Semi-Annual Inspection Revision 9

32. MA-BY-EM FP001-001 Upper Cable Spreading Room Halon System Actuation Surveillance Revision 11

33. MA-BY-EM FP003 Diesel Generator and Day Tank Room Low Pressure CO2 System Detection Test Revision 8

34. MA-BY-EM FP004 Unit 1(2)B Diesel Driven Aux. Feedwater Pump Room & Day Tank Room Low Pressure CO2 System Actuation Revision 8

35. MA-BY-EM FP009 Low Pressure CO2 System Air Actuation Revision 6

36. 0BOSR 10.d.2-1 CO2 Tank Level and Pressure Weekly Surveillance Revision 2 Braidwood Procedures

37. BwAP 1110-1 Fire Protection Program System Requirements Revision 31

38. BwMS FP.7.1.E-1 Fire Rated Assemblies Visual Inspection Revision 5

39. MA-BR-EM 00008 Fire Barrier Penetration Visual Inspection Revision 4

40. BwMS 3350-002 Semi-Annual Inspection of Fire Protection Program Required Fire Doors Revision 8

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 Document Title Revision / Date

43. MA-BR-EM FP003 Diesel Generator and Day Tank Room Low Pressure CO2 System Air Actuation Test Revision 17

44. MA-BR-EM FP004 1(2)B Diesel Driven Aux. Feedwater Pump Room & Day Tank Room Low Pressure CO2 System Air Actuation Test Revision 9

45. MA-BR-EM FP006 Upper Cable Spreading Room Low Pressure CO2 System Air Actuation Test Revision 10 Common Procedures

46. CC-AA-211 Fire Protection Program Revision 4

47. OP-AA-201-001 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 following 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/CO2 fire suppression system.

In BB-PBD-AMP-XI.M26, 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 CO2 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 CO2 system be demonstrated operable by verifying correct valve position every 92 days, by verifying CO2 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 B.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 applicants 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Documents Reviewed During the Byron Audit

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

2. AR 00594075 Common Cause Analysis of Piping Leaks in the Fire Protection System - Byron [associated with LS-AA-125-1003, Revision 10]

02/21/2007

3. AR 01520239 Through Wall Leak on 0FP07B 06/01/2013

4. AR 01199519 UT Identified Pipe Thickness Below 87.5 percent of Tnom 04/08/2011

5. PMRQ 00160166 Sample FP Water for Biological Growth - Braidwood 04/16/2012

6. AR 00850094 OBWVS FP.7.1.T-1 Flawed Methodology and Acceptance Criteria [Fire Protection System Flow Test - Braidwood]

11/26/2008

7. 0BOSR FP-Q2 Quarterly Sprinkler System Visual Inspection and Main Drain Test Surveillance Revision 12

8. 0BwOS FP.3.2.Q-1 Auxiliary Building Sprinkler Systems Inspectors Test Surveillance Revision 14

9. 0BwOS FP FP-AFT3 Charcoal Absorber Filter 0VC02FA Manual Deluge System Nozzles Air Flow Test Revision 3

10. 1BMSR 3.10.c.12-1 Unit 1 A-Train Diesel Fuel Oil Storage Tank Room Foam Spray Headers and Deluge Nozzles Air Flow Test Revision 0

11. 1BOSR FP-BA1 Unit One System Aux Transformer Deluge System Flush Revision 5

12. Draft New Procedure 50 Year Sample Testing of Fire Water System Sprinkler Heads Revision A

13. 0BOSR 10.c.3-1 Annual Sprinkler and Deluge System Visual Inspection and Main Drain Test Surveillance, Review included results of August 31, 2012, Test Results WO 01471059 Revision 6

14. 2006-653 UT Report for 0FPC2BA-6, associated with AR 00571074 12/19/2006

15. 2011-249 UT Report for 0FP13A-10, associated with AR 01199519 04/08/2011

16. 2005-345 UT Report for 0FP609, associated with AR 00350620 07/06/2005

17. 2007-104 Ultrasonic Thickness Testing Report for 0FP07B-12, associated with AR 00637331 03/20/2007

18. AR 01088598 Fire Protection Sprinkler Alarm Not Clearing - Byron 07/07/2010

19. AR 01482910 Tubing for 0PI-FP8039B Found Clogged - Byron 03/04/2013

20. AR 00798599 0FP222G Valve Blockage-Byron 07/21/2008 Documents Reviewed During the Braidwood Audit

21. PMID 169300 Braidwood Fire protection System Decay Test [The staff also reviewed the results of the tests conducted on 02/29/2012, 08/14/2011, 08/14/2010, and 08/15/2009]

02/27/2013

22. PMID 120596 Byron Fire protection System Decay Test [The staff also reviewed the results of the tests conducted on 07/11/2011, 07/13/201, and 07/14/2009]

07/09/2012

23. AR 00093761 Failed Deluge Nozzle Air Flow Test 0VA05FD 02/02/2002

24. AR 00236875 Unit 1 DOST [Diesel Oil Storage Tank] Room Foam Sprinkler Header and Deluge Nozzle Air Flow Test 07/17/2004

25. AR 01441681 Fire Protection Leak South East of Service Building Annex 11/17/2012

26. AR 00717568 0B Fire Protection Jockey Pump Casting Rusted Through Allowing Bypass Flow 01/02/2008

27. 00717951 Large Amount of FP System OOS [Out of Service] or Degraded 01/03/2008

28. 00130749 Deluge SAT [System Auxiliary Transformer] Testing Failures 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 staffs 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 applicants 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 staffs 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 applicants 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 B.2.1.17, Aboveground Metallic Tanks Summary of Information in the Application. The LRA states that AMP B.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 applicants 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 staffs audit addressed only the program elements described in the applicants 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Documents Reviewed During Byron Audit

1. BB-PBD-AMP-XI.M29 Program Basis Document Aboveground Metallic Tanks Revision 1

2. 101537-2-1 Spec # L-2878 General Elevation [CST] - Byron Revision 1

3. 101537-2-14 Spec # L-2878 General Elevation [CST] - Byron Revision 1

4. 5-4012 General Plan [CST] - Byron Revision 4

5. AR 01407570 Unit 2 CST Metal Flashing has Dropped 1-1/2 inch at Top - Byron 08/31/2012

6. AR 01407574 Unit 1 CST Metal Flashing Needs Inspection and Re-caulking -

Byron 08/31/2012

7. AR 01184976 Reapply sealant to Unit 1 CST - Byron 03/08/2011 Document Title Revision / Date

8. AR 01529489 5-Year Inspection of Unit 1 CST - Byron [including annotation that, [t]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.]

06/27/2013

9. AR 0646380 Water Seepage at Bottom of Unit 1 CST - Braidwood 07/02/2007

10. AR 00684137 Unit 2 CST Water Leakage Observed at Base 10/12/2007

11. AR 00667495 Water at Base at Unit 2 CST [including annotation that insulation had dropped] - Byron 09/04/2007

12. LS-AA-125-1003 Apparent Cause - Six Buried Fire Protection Leaks have Occurred at Braidwood Station Since September 2011 No date available Documents Reviewed During Braidwood Audit

13. 09.099H1350.001 &

002 Letter Tank Industry Consultants to Exelon, Summary Report on Weld Inspection of Primary Water Tanks 0PW02TA and 0PW02TB at Exelon Braidwood Station 06/01/2009

14. ED-BRW-97-0050 Internal memo, Cracks Observed in Primary Water Storage Tanks (oPW02TA and TB 01/16/1997

15. AR 00646380 Water Seepage at Bottom of Unit 1 Condensate Storage Tank 07/02/2007

16. AR 00667495 Water at Base of Unit 2 Condensate Storage Tank 08/27/2007

17. AR 00767002 Unit 2 Condensate Storage Tank Possible Indication in Wall Above Water Line 04/24/2008

18. AR 01525252 Condensate Storage Tank has Several Areas Where Rain Can Penetrate Top Ring 06/11/2013 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 staffs evaluation of aspects of these program elements associated with the exception will be addressed in the SER. In addition, the staff found that for the scope of program, 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 visually 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, Byrons 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 disbonded, 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 XI.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 all of the following criteria:

i.

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

are designed to near-atmospheric internal pressures iii.

sit on concrete iv.

are exposed internally to water

b.

Periodic inspections of the tanks bottom surface should be conducted (i.e., each 10-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 10 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 staffs 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 applicants 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 applicants corrective action database, an indication exists in the tank wall above the water line of the Braidwood Unit 2 CST. The applicants 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 RAIs.

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 staffs 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 applicants 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 B.2.1.18, Fuel Oil Chemistry Summary of Information in the Application. The LRA states that AMP B.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 applicants 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. ASTM D975 Standard Specification for Diesel Fuel Oils 98B Braidwood 06B Byron

2. ASTM D4057 Standard Practice for Manual Sampling of Petroleum and Petroleum Products D4057-95

3. Technical Specification 3.8.3 Diesel Fuel Oil (Byron)

Amendments 106 and 171

4. Technical Specification 3.8.3 Diesel Fuel Oil (Braidwood)

Amendments 98 and 165

5. GALL Report Generic Aging Lessons Learned Revision 2

6. LRA License Renewal Application Revision 1

7. Technical Requirement Manual, appendix M Diesel Fuel Testing program (Byron)

Revision 52

8. Technical Requirement Manual, appendix M Diesel Fuel Testing program (Braidwood)

Revision 48 Document Title Revision / Date

9. Program Basis Document Fuel Oil Chemistry Revision 1 BYRON

10. Action Request NRC Identified Small Zero Shift of DP Indication 03/18/2007

11. Action Request Industrial Safety D/G Fuel Oil Tank Sampling 06/29/2008

12. Action Request Corrosion on Diesel Fuel Offload Valve 10/30/2008

13. Action Request Small Fuel Oil Leak 0B Diesel Driven Fire Pump 01/08/2010

14. Action Request 0B Fire Protection Oil Storage Tank Needs Cleaned 10/02/2010

15. Action Request Process Hole that May Bypass TS Surveillance 02/21/2011 BRAIDWOOD

16. AR 00081421 Elevated particulate in tank 11/02/2001

17. AR 00112838 High Particulate found in monthly 0D0O5t fuel oil sample 12/07/2001

18. AR 00117114 Diesel Driven Fire pump Fuel Oil Storage Tank high Particulate 07/26/2002

19. AR 00277549 Elevated Particulate in 0DO05t 06/24/2005

20. AR 00666772 Inconsistent Diesel Fuel Sample for the 1DO02TA Tank 08/31/2007

21. AR 00834613 Excessive Biodiesel Rejects Diesel Fuel Delivery 12/23/2008

22. AR 00876981 Elevated Particulate in 2DO02TB Fuel Oil Sample 02/05/2009

23. BWOSR 3.8.3.2-1 Braidwood Sampling Methodology Rev. 4

24. 1BOSR 8.3.3-1 Byron Sampling Methodology Rev. 1

25. BB-PBD-AMP-XI.M30 Table of Tank Inspection Frequencies pg. 43 to 45 Rev. 1 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 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, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.30. The staffs 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 B.2.1.19, Reactor Vessel Surveillance Summary of Information in the Application. The LRA states that AMP B.2.1.19, 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent database search of the applicants 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 applicants operating experience database.

Relevant Documents Reviewed Document Title Revision /

Date

1. BB-PBD-AMP-XI.M31 Program Basis Document: Reactor Vessel Surveillance Revision 1, 5/3/2013

2. AR 00684551 Postpone RPV Specimen Removal To A1R14 10/14/2007

3. AR 00734399 Postpone Unit 2 RPV Specimen Removal To A2R14 2/11/2008

4. ER-AA-370 Reactor Coolant Pressure Boundary (RCPB) Integrity Revision 8

5. WCAP-17250-NP Ex-Vessel Neutron Dosimetry Program for Byron Unit 1 Cycle 16 Revision 0, September 2010

6. WCAP-17194-NP Ex-Vessel Neutron Dosimetry Program for Braidwood Unit 1 Cycle 14 Revision 0, March 2010

7.

Byron Unit 1 Pressure and Temperature Limits Report (PTLR)

December 2006

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 Recapture (MUR) Power Uprate 6/23/2011

12. RS-11-169 Additional Information Supporting Request for License Amendment Regarding Measurement Uncertainty Recapture Power Uprate 11/1/2011

13. WCAP-15316 Analysis of Capsule W from Commonwealth Edison Company Braidwood Unit 1 Reactor Vessel Radiation Surveillance Program Revision 1, December 1999

14. WCAP-15369 Analysis of Capsule W from Commonwealth Edison Company Braidwood Unit 2 Reactor Vessel Radiation Surveillance Program Revision 1, March 2000

15. WCAP-15123 Analysis of Capsule W from Commonwealth Edison Company Byron Unit 1 Reactor Vessel Radiation Surveillance Program Revision 1, January 1999 Document Title Revision /

Date

16. WCAP-15176 Analysis of Capsule X from Commonwealth Edison Company Byron Unit 2 Reactor Vessel Radiation Surveillance Program March 1999 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 staffs 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 staffs 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 B.2.1.20, One-Time Inspection Summary of Information in the Application. The LRA states that AMP B.2.1.20, One-Time Inspection, is a new program that will be consistent with the program elements in GALL Report AMP XI.32, One-Time Inspection. To verify this claim of consistency, the staff audited the LRA AMP.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. ASME Boiler and Pressure Vessel Code Section XI, Division 1 Rules for In-service Inspection of Nuclear Power Plant Components July 1, 2003

2. EPRI Report TR-1016609 Material Reliability Program: Inspection Standards for PWR Internal July 2009

3. EPRI Report TR-1022931 Nondestructive Evaluation: Update on License Renewal One-Time Inspection and Best NDE practices November 2011

4. ER-AA-335-004 Ultrasonic (UT) Measurement of Material Thickness and Interfering Conditions Revision 6

5. ER-AA-335-038 Examination of Non-Magnetic Heat Exchanger Revision 3

6. ER-AA-700-302 One-Time Inspection Program Draft Revision 0a

7. ER-AA-700-301 One-Time Inspection Program Draft Revision 0a

8. BY-SSBD-OTI BYRON - One-Time Inspection Sample Basis Document Draft Revision 0

9. BB-PBD-AMP-XI.M32 BYRON and BRAIDWOOD - Program Basis Document Revision 1 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 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.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 B.2.1.21, Selective Leaching Summary of Information in the Application. The LRA states that AMP B.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 staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M33 Selective Leaching - GALL Program XI.M33 - Selective Leaching Revision 1 Byron Procedures

2. ER-BY-700-401 Guidance for Performing Selective Leaching Inspections (Level 2

- Reference Use)

Revision a

3. BY-SSBD-SLI, Draft Selective Leaching Inspection Sample Basis Document Revision 0 Braidwood Procedures

4. ER-BR-700-401 Guidance for Performing Selective Leaching Inspections (Level 2

- Reference Use)

Revision a

5. BR-SSBD-SLI, Draft Selective Leaching Inspection Sample Basis Document Revision 0 Common Procedures

6. ER-AA-700-401 License Renewal Selective Leaching Program (Level 3 -

Information Only)

Revision 0 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program 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 applicants operating experience database for Byron and Braidwood using the keywords cited earlier and did not find any relevant operating experience. The staff determined that the lack of relevant operating experience identified by the applicant and confirmed by the 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 B.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 XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping. To verify this claim of consistency, the staff audited the LRA AMP.

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

Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M35 One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program Basis Document Revision 1, 05/17/2013

2. AR 01166795 Perform 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 Vessel Head Penetration Nozzle Weld Flaws Attributed to Primary Water Stress Corrosion Cracking 5/18/2011

4. AR 00177514 Unit 1 RPV Lower Head Condition, B1R12 Exam Results 9/25/2003

5. LER 456-2011-001 Through Wall Cracking on 1A Safety Injection Pump Discharge line Due to Outside Diameter (Transgranular) Stress Corrosion Cracking Initiated at External Diameter of Pipe 04/26/2011

6. LER-455-2009-001 Supplemental to Reactor Coolant System Leakage Characterization Resulting in a Condition Prohibited by Technical Specifications 02/10/2010 Document Title Revision / Date

7. M-02619-98 System Materials Analysis Department Report on the Evaluation of a Safety Injection Line Failure at Byron Station 04/08/1998

8. AR 01166795 2CV8409 Piping (Boric Acid Accum., Investigate Source) 01/25/2011

9. WO 01405325 M2-2CV8409 Cut Out Weld and Replace Valve 02/24/2011

10. AR 01209848 2CV04B-3 (Further Actions Required Boric Acid Leakage Investigation) 04/29/2011

11. BRW-47115 Evaluation of a Socket Weld Leak in Line 2CV02G-2 at Braidwood Station 06/21/2011 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 staffs independent database search is not sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging. In order to obtain the information necessary to determine whether the applicants 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 SCC 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 applicants 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 B.2.1.23, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The LRA states that AMP B.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 staffs audit addressed only the program elements described in the applicants 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.M36 External Surfaces Monitoring of Mechanical Components Program Basis Document Revision 2

2. ER-BY-700-402 External Surfaces Monitoring of Mechanical Components Program 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 piping 10/19/2007

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

6. AR 00765821 Moderate Corrosion on SX Piping 04/21/2008

7. AR 00883889 Light Surface Rust Identified 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 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 SCC 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 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 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 B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: thimble tube, thimble tube wear, wear rate, and capped tube.

The table below lists the documents 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 applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. BwVS 210-3 Multifrequency Eddy Current Examination of Neutron Monitoring System (Incore Flux Thimble Tubes)

Revision 3

2. PMID 54635 Multifrequency Eddy Current Examination of Incore Detector Flux Thimble (Unit 2) 10/05/2012

3. 1BVSR XII-7 Unit 1 Non-Technical Specification Eddy Current Texting of Incore Thimble Tubes Revision 3

4. 2BVSR XII-7 Unit 2 Non-Technical Specification Eddy Current Texting of Incore Thimble Tubes Revision 3

5. PMID 172394 Non-Tech Spec Eddy Current Testing of Incore Thimble Tubes 04/08/2013

6. BB-PBD-AMP XI.M37 Flux Thimble Tube Inspection Aging Management Program Revision 1

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

8. AR00687278 Wear on U-1 Incore Thimble Tube number 44 at location R-8 10/20/2007

9. AR00687434 Need to replace multiple Incore Thimbles during A1R14 10/21/2007

10. AR00690333 Initiate Common Cause-Incore Reliability and Limited PMTS 10/27/2007

11. AR00774272 A2R13 Incore Flux Thimble Eddy Current Inspection Results 05/11/2008

12. AR01364821 A1R16 Incore Thimble Tube Eddy Current Inspection Scope Reduced 05/10/2012

13. AR01435374 Potential Moisture in Unit 2 Incore thimbles 11/03/2012

14. AR01435431 A2R16 Incore 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 staffs 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 staffs 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 applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.

The applicants 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 applicants 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 B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The LRA states that AMP B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

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

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

3. BB-PBD-AMP-XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program Basis Document Revision 1

4. AR 00158892 Excessive corrosion found on a check valve that prevented the valve disc from seating tightly 05/15/2003

5. AR 00753030 Check valve internal condition determined to be unacceptable, due to severe corrosion found on internal parts 03/21/2008

6. AR 00363287 Potential Trend of Raw Water Pipe Thinning 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 staffs 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 staffs 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 B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PDB-AMP-XI.39 License Renewal Project, Lubricating Oil Analysis Revision 1

2. ASTM D6226-09 Standard Practice of Lubricating Oil for Auxiliary Power Plant Equipment November, 2009

3. MA-AA-716-230 Predictive Maintenance Program Revision 8

4. BOP-DG-300-1 Sampling Diesel Generators Lubricating Oil Revision 7

5. AR 00438755 Recommendations/Deficiencies From Lubrication Program January 4, 2006

6. AR 01341284 Lost Oil Samples March 15, 2012

7. AR 01176623 Oil Lab Data Entry Error for Byron/Braidwood Oil Samples February 17, 2011

8. AR 00863887 2AF01PB Engine Oil Sample-Potential Lab Error January 7, 2009

9. AR 00858617 Lubrication Sampling Processing Issues On 2B AF Diesel December 19, 2008

10. AR 00138437 Lost or Misplaced Oil Samples January 7, 2003

11. BOP-AF-300-1 Byron Sampling the Motor Driven Auxiliary Feedwater Pump Lubricating Oil Reservoirs Revision 4

12. BOP-AF-300-2 Byron Sampling the Motor Driven Auxiliary Feedwater Diesel Lubricating Oil Revision 6

13. BOP-DG-300-1 Byron Sampling the Standby Diesel Generator Lubricating Oil Revision 7

14. BWOP-AF-300 Braidwood Sampling Auxiliary Feedwater Diesel Crankcase Revision 2

15. BWOP-DG-300 Braidwood Sampling the Standby Diesel Generator Lubricating Oil Revision 3

16. BWOP-SX-301 Braidwood Sampling the Essential Service Water Pump Lubricating Oil Reservoirs Revision 1

17. MM-AA-716-230-1001 Oil Analysis Interpretation Guidelines Revision 13 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 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.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 B.2.1.27, Monitoring of Neutron-Absorbing Materials Other than Boraflex Summary of Information in the Application. The LRA states that AMP B.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 applicants staff and reviewed onsite 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. N/A SFP Boral Sample Coupon not Irradiated per OEM Specification 2003

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 Boral Coupon Testing Results 2013

5. HI-982094 Criticality Evaluation for the Byron/Braidwood Rack Installation Project Rev2-2000

6. 0BVSR FH-1 Unit 0 Spent Fuel Rack Boral Specimen Surveillance Revision 3

7. BwVP 500-86 Inservice Surveillance Program for Boral Neutron Absorbing Material Revision 4

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 Station

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 Byron Station

13. 0BVSR 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 Byron 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 applicants 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 Boral sample coupons was not surrounded by freshly discharged fuel in accordance with the original equipment manufacturers 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 applicants 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 B.2.1.28, Buried and Underground Piping Summary of Information in the Application. The LRA states that AMP B.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-ISG-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 applicants 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 applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Documents Reviewed During Byron Audit Phase

1. BB-PBD-AMP-XI.M41 Program Basis Document Buried and Underground Piping Revision 1

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)

Guide Revision 5

5. ER-AA-5400-1002 Buried Piping Examination Guide Revision 4

6. OBOSR FP-9 Unit Zero Fire Protection System Leakage 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 Fire Protection System Leakage Surveillance - Braidwood Revision 2

9. None Underground Pipe and Tank Inspection Plan - Byron Revision 1

10. None Buried Pipe Inspection Plan - Braidwood Revision 1

11. NUC2011109.00 Condition Assessment Excavated Buried Pipe - Byron 09/27/2011

12. NUC2010111.00 Condition Assessment Excavated Buried Pipe - Braidwood 10/31/2010

13. IR 953598 Standing water in 0SX138A Valve Pit Leading to Pipe Wall Corrosion - Byron 08/20/2009

14. 2010-348 Ultrasonic Thickness Measurements, 0SX138A Valve Pit Piping -

Byron 05/27/2010

15. 2012-415 Ultrasonic Thickness Measurements, 0SX138A Valve Pit Piping -

Byron 11/07/2012

16. 2011-068 Ultrasonic Thickness Measurements, 0SXH2AA Valve Pit Piping -

Braidwood 04/04/2011

17. 01456616-02 Apparent Cause Evaluation - Six Buried Fire Protection Pipe Leaks - Braidwood No date available

18. None Bio-Gard' 258 Product Data Sheet, Thin Film Technology, Inc.,

www.thinfilmtech.net No date available

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

20. PMRQ 00120642 Readings Taken on Cathodic Protection Rectifiers - Byron 05/04/2011

21. PMRQ 00141070 Cathodic Protection Site Survey - Byron 01/27/2010

22. PMRQ 00169300 Fire Protection System Leakage Surveillance - Braidwood 06/14/2011

23. PMRQ 00049757 U-0 Cathodic Protection Sys Monthly Surveillance - Braidwood 02/20/2009

24. PMRQ 00096509 Cathodic Protection Survey - Braidwood No date available

25. None Corpro 2011 Cathodic Protection System Resurvey Report for Exelon Nuclear Byron Power Station January 2012

26. None Corpro 2012 Cathodic Protection System Resurvey Report for Exelon Nuclear Byron Power Station March 2012

27. None Quarterly Health Report Buried Piping and Raw Water Corrosion -

CP System Rectifier Availability Trending - Rolling 12 Month Byron and Braidwood 2013 Document Title Revision / Date

28. 1001447.401 APEC Survey for Braidwood Nuclear Power Station 02/26/2013

29. S-546 Turbine Room Foundation Section I - I Revision G

30. PMRQ 55407 Essential Service Water 0SX165A Pit Inspection, inclusive of the 2012, 2010, and 2009 inspections - Braidwood 07/31/2012

31. PMRQ 55408 Essential Service Water 0SX165B Pit Inspection, inclusive of the 2012, 2010, and 2009 inspections - Braidwood 07/31/2012

32. PMRQ 00100304 Essential Service Water 0SX138A Pit Inspection, inclusive of the, inclusive of 9 prior inspection results - Byron 07/08/2013

33. PMRQ 00100305 Essential Service Water 0SX138B Pit Inspection, inclusive of the, inclusive of 11 prior inspection results - Byron 05/30/2013

34. AR 00635246 Potential Issues for Cathodic Protection - Byron 05/30/2007

35. AR 00700422 Replace Buried Pipe Coating on 0SX097AA-24, OA SX Riser 11/16/2007

36. AR 00689316 Buried 24 SX Piping with Line Stop Inspected, Restore Coating 10/25/2007

37. AR 00730278 Replace Buried Pipe Coating on 0SX97AC-24, OC SX Riser 02/01/2008

38. AR 00154572 0SX1618 Pipe NDE Failed the Minimum Wall Thickness Examination 04/18/2003 Documents Reviewed During the Braidwood Audit Phase

39. 1001447.401 APEC Survey Braidwood Nuclear Power Station Revision 0

40. None Cathodic Protection Survey for Underground Structures December 2010

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 0SX99BB-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 Buried Pipe 1CD19A-20 Condition Assessment 10/08/2010

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 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 applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs 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 - [f]ound 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 - [f]ound 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 - [f]ound 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 - [f]ound 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 - [f]inished pumping down vault approx. 10 inches, 03/03/2011 - observed small amount of water, 12/08/2010 - found about 6 foot of water in the vault.

e.

Based on the applicants 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 applicants 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 disbondment and minor corrosion. For example:

a.

NUC2011109.00 (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.

NUC2010111.00 (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 staffs 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 applicants 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 B.2.1.29, ASME Section XI, Subsection IWE Summary of Information in the Application. The LRA states that AMP B.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 applicants 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. AR 0093228 Limited Liner Inspection Behind Unit 2 Containment Moisture Barrier 11/13/2009

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 IWL Class CC Components Rev. 8

4. Calculation 5.2.6-BRW-98-1090 Liner plate inspection criteria Rev. 6

5. AR 012254938 ISI Program - Focused Area Self-Assessment (FASA) 02/01/2011

6. AR 01254938 ISI Program - Focused Area Self-Assessment (FASA) 08/24/2011

7. AR 965901965901Unit 1, identified degraded areas of moisture barrier 09/16/2009

8. AR 611767611767Unit 2, degraded bolts used at the cover for a spare containment penetration 04/02/2007

9. Inspection Pictures The applicant provided pictures taken during the IWE inspections 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 Inspections - Exelon Nuclear Condition Report 04/24/2002

11. AR 1433284 (Braidwood Station - Unit 2) NRC Containment Liner Examination Observations 10/30/2012 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed 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 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 applicants 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 onsite 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 XI.S1, ASME Section XI, Subsection IWE. The staffs 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 applicants 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 B.2.1.30, ASME Section XI, Subsection IWL Summary of Information in the Application. The LRA states that AMP B.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 applicants 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.S2 Byron and Braidwood Stations, Units 1 and 2 Program Basis Document ASME Section XI, Subsection IWL Revision 1

2.

Design Control Summary Revision 0, February 2, 1994

3. CC-AA-309-1001 Selection of Tendons and Calculation of Predicted Lift-Off Forces for 25th Year ISI Revision 6, May 2011

4. AR 01247295 Unit 1 Containment Dome Drainage System Deficiencies/Concrete Damage 08/01/2011

5. AR 00514372 11 locations Unit 1 and 14 locations Unit 2 with signs of degradation July 2006

6. AR 00518036 Tendon Grease Leakage Through Concrete, Unit 1 Containment 08/08/2006

7. AR 00575066 Concrete Repair Required, Unit 1 Containment ASME Section IX IWL Exams 01/03/2007

8. AR 00575074 Concrete Repair Required, Unit 2 Containment ASME Section IX IWL Exams 01/03/2007

9. AR 00576027 Concrete Repair Required, Unit 2 Containment ASME Section IX IWL Exams 01/06/2007

10. AR 00576059 ASME Section XI Augmented Exams Required (Unit 2 Tendon Tunnel) 01/06/2007

11. WO717384 Visual Exam VT3C/1C of Unit 1 Concrete Containment Exterior 01/03/2006

12. WO00929084 U/1 ASME IWL VT-3 Concrete Exams Prep Areas for VT-1C Exams 06/12/2006

13. WO00929566 U/2 ASME IWL VT-3C Concrete Exams Prep Areas for VT-1C Exams 06/13/2006

14. SPP VT-3C-1 Visual Examination Data Attachment Form VT-3C-1.2 Revision 0

15. 2006-IWL-01 Exelon Braidwood Station Units 1 and 2 Engineering Evaluation ASME Section XI Class CC Structures Revision 0

16. ER-AA-330-005 Visual Examination of Section XI Class CC Concrete Containment Structures Revision 9

17. ER-AA-330-006 Inservice Inspection and Testing of the Pre-Stressed Concrete Containment Post Tensioning Systems Revision 6

18. BwVSR 5.5.6-2 Containment Tendon Grease Can Inspection Revision 1

19. Project No.

9135-53, Calc. No.

24.2.9 Design Control Summary: Containment Post-Tensioning In-Service Inspection (ISI)

Revision 0

20. BY-N1044-501 Final Report for Exelon Byron Station Unit 1 and Unit 2 25th Year Containment Building Tendon Surveillance 11/16/2009

21. EC 0000353115 Document and Evaluate for Acceptability the Free Water Presence in Tendons Found During the 20th-YR Tendon Surveillance (Byron) 8/12/2005

22. Report 05Q0523-R-001 ASME Section XI IWL Evaluation of Byron Unit 2 Containment Post-Tensioning for Free Water Revision 0

23. 2011-IWL-02 Exelon Braidwood Station 25th Year Un-bonded Post Tensioning System Surveillance Engineering Evaluation Report.

Revision 0

24. EC 350171 Evaluate Conditions that Did Not Meet The Acceptance Criteria During the 20th Year Tendon Surveillance (Byron)

Revision 0

25. ATI 1324460-10 Byron Containment Tendons-Operating Experience 06/25/2012 Document Title Revision / Date

26. WO 01249079-01 IWL, Visual Examination of Concrete (Class CC) CNMT Structures (Byron) 05/20/2011

27. ER-AA-335-019 Visual Examination of ASME IWL Class CC Containment Components Revision 0 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 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 applicants 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 staffs 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 applicants 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 B.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 applicants 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.S3 Program Basis Document, ASME Section XI, Subsection IWF Revision 1, 05/01/2013

2. ER-AA-330-003 Inservice Inspection of Section XI Component Supports Revision 7 08/07/2013

3. ER-AA-335-016 VT-3 Visual Examination of Component Supports, Attachments and Interiors of Reactor Vessels Revision 5 07/29/2013

4. MA-MW-736-600 Torqueing and Tightening of Bolted Connections Revision 4 10/25/2012

5. BWD05.D05 Braidwood Selection Document, Third Ten Year Inspection Interval 12/21/2007

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

(Byron) 08/6/2009

7. PMRQ 175341-01 2FH01E FH SYS PM with Dry Transfer Canal 01/23/2013

8. AR 00757579, WR 268149, WO 1121045 Variable Spring Support 1AF0604V (Adjust Load Setting) 04/01/2008

9. AR 00757349, WR 2667977, WO 1121300 Boric Acid Accumulation / Corrosion NSSS 1RC01BA SG Supports 03/31/2008

10. Byron 2010-0001 Byron Unit 1 90-day ISI Report for Interval 3, Period 1 (B1R16) 01/05/2010

11. A2R13 Braidwood Unit 2 ISI Summary Report for Interval 2, Period 3, Outage 2 (A2R13) 08/13/2008

12. AR 00544850, WR 222074, WO 0967028 ASME Support 2CV41016V (Recordable Indication - No Load) 10/17/2006

13. WO 0808296 Visual Exam VT 3 /4 of Component Supports 11/15/2006

14. AR 00952591, WR 1142589, WO 1261700 2AF07030X (Loose Pipe Clamp, Repair, Expand Inspection Scope) 08/12/2009

15. AR 1369622 A1R17: Apply Lubricant: SG Upper Lateral Shim Packs 05/23/2012

16. AR 01413704 1RC01BB-ULR Belly Band Shim Packs Damaged 09/16/2012

17. AR 01413706, 01413707, 01413708 Inspect 1A/1C/1D S/G Upper Restraint Shimpacks (Belly Band) 09/16/2012

18. AR 01416386, 01416405, 01416411 1RC01BA/C/D-ULR Belly Band Shim Packs Damaged 09/21/2012

19. AR 01414309, 01414313 A2R16 Examine SG Belly Band Shim Assembly and Repair 09/17/2012

20. AR 01414334, 01414336 A1R17 Examine SG Belly Band Shim Assembly and Repair 09/17/2012

21. AR 01429245, 01429246 B2R17 Inspect 2A/B/C/D S/G Upper Lateral Shimpacks (Belly Band) 10/20/2012 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements. 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 staffs 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 inservice 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 SCC 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 staffs 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 staffs 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 B.2.1.32, 10 CFR Part 50, Appendix J Summary of Information in the Application. The LRA states that AMP B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. BB-PBD-AMP-XI.S4 Byron and Braidwood Stations License Renewal Project Aging Management Program Basis Document Revision 1

2. Calculation EC367380 To provide justification for the use of dry air density at standard conditions when calculating the allowable leakage rate based on test pressure near the Design Basis Accident pressure.

This revision is a result of an ACIT from IR #1396720.

Revision 1

3. Applicant Letter to NRC Request for amendment to technical specification 5.5.16 containment leakage rate testing program.

April 4, 2007

4. NRC Letter to Applicant Byron Station Unit Numbers, 1 and 23 - Issuance of amendments, RE: Request for amendment to technical specification 5.5.16, containment leakage rate testing program.

February 12, 2008 Document Title Revision/Date

5. NRC Letter to Applicant Safety evaluation of containment leak chase channels - Byron, 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 during a CILRT...

May 17, 1990

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

7. WO 98059067 ILRT Byron, Unit 1 10/05/2012

8. UFSAR ILRT Unit 1, Page 6.2-86, Test Pressure of 42.77 psig Revision 9

9. Technical Specification Section B3.6 Containment Systems, page B3.6.4-1 and 2, ILRT pressure for Unit 1: 42.8 psig and Unit: 38.4 psig Revision 18

10. CFR 50, Appendix J Program Health Reports 1st Quarter, 2013 2nd Quarter, 2012 3rd Quarter, 2012 4th Quarter, 2012 2012-2013

11. Letter from Common Wealth Edison to Mr. Harold R.

Denton Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Containment Leak Rate Testing NRC Docket Nos. 50-454, 50-455 50-456, and 50-457 April 19, 1983

12. Letter from Common Wealth Edison to Mr. Harold R.

Denton Byron Station Units 1 and 2 Braidwood Station Units 1 and 2 Containment Leak Rate Testing NRC Docket Nos. 50-454, 50-455 50-456, and 50-457 July 7, 1983

13. ER-AA-380 Primary Containment Leakage Testing Program Revision 9

14. AR 00623361 Appendix J FASA 07/02/2009

15. ER-AA-335-018 ASME IWE (Class MC) Containment Visual Examination Record Revision 5

16. AR 01282363 FASA Rec #1: Revise ER-AA-380 05/30/2013

17. AR 01012562 FASA Report Passport Assignment Fill in FASA Report &

Approval Template Per LS-AA-126-1001 06/30/2010

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 10 CFR Part 50, Appendix J Exemptions NA 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 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 2s 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 B 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 staffs 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 B.2.1.33, Masonry Walls Summary of Information in the Application. The LRA states that AMP B.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 applicants 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 applicants Structures Monitoring LRA AMP. In addition, the staff conducted walkdowns of masonry walls in Byrons turbine building and Braidwoods auxiliary building, turbine building, and lake screen structure. The staff also conducted an independent search of the applicants operating experience database using keywords: masonry, block, CMU, crack and grout.

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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed 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 staffs 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 B.2.1.34, Structures Monitoring Summary of Information in the Application. The LRA states that AMP B.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 Document Title Revision / Date

1. BB-PBD-AMP-XI.S5 Program Basis Document - Masonry Walls Revision 1

2. ER-AA-450 Structures Monitoring Revision 3

3. ER-BY-450-1001 Byron Structures Monitoring Instructions Revision 1

4. ER-BR-450-1001 Braidwood Structures Monitoring Instructions Revision 0

5. AMP Results Book Byron and Braidwood Stations License Renewal Project Masonry Walls Program B.2.1.33 NA

6. AR 00436111 Cracks identified in Turbine Building Masonry Wall 12/21/2005

7. AR 00299062 Localized Cracks on Masonry Walls 02/08/2005

8. AR 00367289 Masonry Walls of the Switchyard Relay House Need Repairs 08/26/2005 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 applicants 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.S5, Masonry Walls, have been incorporated into the applicants Structures Monitoring LRA AMP. In addition, the staff conducted walkdowns of Byrons 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 Braidwoods auxiliary building, turbine building, lake screen structures, and containment tendon tunnels. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.S6 Program Basis Document - Structures Monitoring Revision 1

2. ER-AA-450 Structures Monitoring Revision 1

3. ER-BY-450, NEW Byron Structures Monitoring Program DRAFT

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

5. AR 00112804 River Screen House Concerns 08/15/2002

6. AR 01263972 Long Term Plan to Survey the Rock River 09/16/2011

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 Integrity/Leak Detection Issue 04/02/2012

11. AR 01287713 License Renewal Exposure Issue - SFP Leak Detection 11/08/2011

12. AR 01008728 DEF Tag Discrepancies and Material Condition of Aux Bldg.

Wall 03/05/2010

13. AR 01360802 Concrete Surfaces Soaked with Oil on Condenser Piers, TB 05/31/2012

14. AR 01124323 Structural Degradation of the North Wall of Cable Vault 1E 04/15/2011

15. AR 00739247 Increased Degradation 2SI8811B Piping to Containment Pen.

03/22/2008

16. AR 00613160 White Residue and Rust/Spalled Concrete Along L Wall 05/04/2007

17. AR 01165648 Potential Degradation of S/R Structure (U/1 Tendon Tunnel) 11/25/2011

18. AR 01250903 Safety Issue & More than Cosmetic Damage Aux. Bldg.

Concrete 09/16/2011

19. AR 01360819 Standing Water and Potential Groundwater Intrusion, TB, 369 05/31/2012

20. AR 01402603 Concrete Degradation Worse (Auxiliary Bldg. Exterior) 01/31/2013

21. WJE No.

2010.0758.0 Byron Generating Station Inspection of Unit 2 Natural Draft Cooling Tower (B2R15) 11/05/2010

22. Condition Assessment Summary Byron Generating Station Condition Assessment Summary Unit 1 and Unit 2 Natural Draft Cooling Towers 1/31/2013

23. Ltr from Sargent and Lundy to Commonwealth Edison Tendon Tunnel Cracks and Evaluations 10/28/1978 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 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 applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subject discussed below.

During a walkdown of Byrons main steam and tendon gallery tunnels, the staff observed white material deposits on the concrete walls. A review of operating experience revealed similar conditions 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 staffs evaluation of aspects of the program elements associated with enhancements which are not necessary for consistency will be addressed in the SER.

Based on the audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants 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 B.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 B.2.1.35, RG 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 applicants 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 Byrons river screen house and essential service water cooling towers, and Braidwoods lake screen structures. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.S7 Program Basis Document RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Revision 1

2. PMID 0013968210 Structures Monitoring Walkdown Notes Essential Service Water Cooling Tower Including Cold Water Basin, Plenum, Valve Enclosures, and Electrical Rooms 12/30/2010

3. ER-BY-450, New Byron Structures Monitoring Program Revision 1

4. WJE Report Byron Generating Station - Inspection of Essential Service Water Cooling Tower Final Report 01/11/2013

5. AR 00070276 Damage at Freshwater Holding Pond Overflow 04/14/2003

6. AR 00184318 Spillway Project - inleakage 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 staffs evaluation of aspects of the program elements associated with enhancements which are not necessary for consistency will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience 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.2.1.36, Protective Coating Monitoring and Maintenance Program Summary of Information in the Application. The LRA states that AMP B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: service level I, 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-XI.S8 Protective Coating Monitoring and Maintenance Program Revision 1, 05/01/2013

2. Byron IR 0761313 B1R15 Coating Inspection Does Not Meet Acceptance Criteria

3. Byron IR 845114 Degraded Level I Top Coating on Containment Concrete Walls

4. Byron IR 845084 Degraded Level I Top Coating on Containment Floors

5. Byron IR 845151 Degraded Level I Coating on Electrical Panel at B RCP

6. Byron IR #246926 Pipe Supports Coating Required by B1R10 Still Not Installed

7. Byron IR #175317 Level I Coating Applied Incorrectly on Storage Boxes in Containment

8. Braidwood IR

1. 1365407 Containment Coating A1R16 Exam Results

9. BRW-05-0059-M/BYR05-041 GSI-191 Post-LOCA Debris Generation Calculation

10. BRW-11-0027-S/BYR10-146 DBA Qualification of Service Level I Coatings for Use Inside Containment Revision 0, 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 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.

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.S8.

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 B.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 staffs audit addressed only the program elements described in the applicants basis document.

Audit Activities. During its audit, the staff interviewed the applicants 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BBS-PBD-AMP-XI.E1 Program Basis Document - Insulation Material for electrical Cable and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 1, 05/01/2013

2. ELEC 1 Electrical Commodities Aging Management Review Report Revision 1, 03/01/2013

3. MA-AA-723-500 Inspection Of Non EQ Cables And Connections For Managing Adverse Localized Environments Revision 6,

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 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, 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, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Summary of Information in the Application. The LRA states that AMP B.1.2.38, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification (EQ) 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 staffs audit addressed only the program elements described in the applicants 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 applicants staff and reviewed onsite Byron and Braidwood documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Document Title Revision / Date

1. BBS-PBD-AMP-XI.E2 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Revision 1

2. AR 00996543 TB-09-8 NI System Ex-Core Detector Tape Enhancement 11/20/2009

3. AR 00485241 1RT-AR024 Detectors Has a Steady Output, Not Normal 05/01/2006

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 Assemblies and RD-8 Ionization Chamber Detector Revision 7 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 EQ 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 B.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 applicants LRA AMP could allow reviewing of calibration results even though the cable system is not included in the calibration or surveillance program. The applicants 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 XI.E2, states that in cases where cables are not part of a calibration or surveillance program, a proven test (such as insulation resistance tests, time domain reflectometry tests, or other test judged to be effective as justified in the application) for detecting deterioration of insulation system are performed. LRA Section A.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, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA states that AMP B.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 staffs audit addressed only the program elements described in the applicants 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BBS-PBD-AMP-XI.E3.

Inaccessible Power Cable Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 1

2. AR 01550777 Safety-Related Cable Vault 0B2 Follow-Up Inspection 8/26/2013

3. AR 01254093 2011 Safety-Related Manhole 0B2 Inspection 08/22/2011

4. ARs 1073696, 1108590, 1204963 Yearly Manhole Inspection for Manhole 1M 5/26/2010

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 Condition 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

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 applicants 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 performed. 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, 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 applicants 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 applicants operating experience supports the sufficiency of the LRA AMP. Therefore, the staff will consider issuing RAIs for the subjects discussed below.

GALL Report AMP XI.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 applicants 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 cables insulation system. The staff is concerned that the applicants 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 applicants LRA AMP B.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 applicants 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 B.2.1.40, Metal Enclosed Bus Summary of Information in the Application. The LRA states that AMP B.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 staffs audit addressed only the program elements described in the applicants 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 applicants staff and reviewed onsite 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 applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Document Title Revision / Date

1. BB-PBD-AMP-XI.E4 Aging Management Program Basis Document - Metal Enclosed Bus Revision 1

2. 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 -

2AP02E 5/13/2010

7. AR01552783 Non-Seg Bus Duct Maintenance Program Deficiencies 08/30/2013

8. AR01552496 LR-Metal Enclosed Bus Maint 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 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, 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 staffs evaluation of aspects of the program elements associated with enhancements which are not necessary for consistency will be addressed in the SER.

Based on this audit, the staff also verified that the operating experience 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.2.1.41, Fuse Holders (Byron Only)

Summary of Information in the Application. The LRA states that AMP B.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 staffs audit addressed only the program elements described in the applicants 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

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

Aging Management Program Basis Document Revision 0

2. MA-AA-716-230-1003 Thermography Program Guide Revision 4

3. CC-AA-206 Fuse Control Revision 7

4. NUREG-1760 Aging Assessment of Safety-Related Fuses Used in Low-and Medium-Voltage Applications in Nuclear Power Plants 05/2002 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.E5. 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 B.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 B.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 applicants 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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date Document Title Revision / Date

1. BB.PBD-AMP-XI.E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 1

2. IR #963012 U2 Pressurizer Group D Breakers Found Trip 09/09/2009

3. IR#239039 Weekly Thermography Identified Warm Connection 4-1 Contactor 07/26/2004

4. MA-AA-716-230-1003 Thermography Program Guide Revision 4

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 09/19/2005

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 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, 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 B.3.1.1, Fatigue Monitoring Summary of Information in the Application. The LRA states that AMP B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BB-PBD-AMP-X.M1 Byron & Braidwood Stations License Renewal Project - Aging Management Program Basis Document - Fatigue Monitoring Program - GALL Program X.M1 Revision 1

2. BVP 900-3 Documentation of Operating Plant/Component Cyclic or Transient Events Revision 9a

3. BwVP 850-7 Operational Transient Cycle Counting Revision 5

4. ER-AA-470 Fatigue and Transient Monitoring Program Revision 5

5. LTR-PAFM-12-92 Westinghouse Letter Report - Byron and Braidwood Stations, Units 1 and 2 Cycle Counting Procedure Review Revision 0, 5/16/2013

6. AR 00982528 Action Request - Resolution of FatiguePro Related Issue (RIS 2008-30) 10/21/2009

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, and Disposition Revision 1, 5/30/2013

9. CC-AA-102 Design Input and Configuration Change Impact Screening Revision 23

10. CN-PAFM-12-18 Westinghouse - Byron Station, Units 1 and 2: Transient Counting and 60-Year Projections Revision 2, 2/1/2013

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

12. AR 00762699 Action Request - PZR Heatup Rate Possibly Exceeded (TRM 3.4.C) 4/13/2008

13. LER 2012-001-00 Unit 2 Loss of Normal Offsite Power and Reactor Trip and Unit 1 Loss of Normal Offsite Power Due to Failure of System Auxiliary Transformer Inverted Insulators 3/30/2012

14. AR 00536774 Action Request - Potential Issues in Historical Cycle Counting Database 9/27/2006 Document Title Revision / Date

15. ATI 1230600-01 Significance Level 3 OPEX Evaluation - OE 33310 - Normal Letdown Flow Operation at the Maximum Flow Rate is Outside the Fatigue Design Basis Limits (Callaway) 8/4/2011

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 Stations, Units 1 and 2 Revision 0, 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, parameters 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 B.3.1.1 states the Fatigue Monitoring Program will be used to monitor the transients for ASME Section III fatigue analyses. It is unclear to the staff whether analyses other than ASME Section III 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 III, 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 staffs review of LRA AMP B.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 staffs independent database search is bounded by industry operating experience (i.e., no previously unknown aging effects were identified by the applicant or the staff). 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 staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.

The staff also audited the description of the LRA AMP provided in the 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 staffs 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 B.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 applicants staff and reviewed onsite 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 applicants 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 applicants operating experience database.

Relevant Documents Reviewed Document Title Revision/Date

1. Tendon Procedure, 7D Tendon Procedure 7D by Napoleon Steel Construction, Inc.

04/28/1982

2. Drawing S-884 Containment Building Tendon Location Plans &

Sections, Byron Unit 1 & 2 Revision H

3. Tendon Report 5.2.2-BRW11-0141-S Evaluation of Tendon H4CB for Reduced Number of Wires 11/18/2011

4. 23161-C-208 (BRW Unit 1)

Steam Generator Replacement Containment Opening Tendon Details 05/14/1996

5. 23161-C-608 (BYR Unit 1)

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

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

Steam Generator Replacement Containment Concrete Removal & Tendon Sheathing Details 05/18/1998

7. 23161-C-609 (BYR Unit 1)

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

8. 23161-C-210 (BRW Unit 1)

Steam Generator Replacement Containment Opening Reinforcing Details 05/18/1998

9. 23161-C-610 (BYR Unit 1)

Steam Generator Replacement Containment Opening Reinforcing Details 03/25/1998

10. 23161-C-211 (BRW Unit 1)

Steam Generator Replacement Containment Opening Liner Plate Details 05/18/1998

11. 23161-C-611 (BYR Unit 1)

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

12. BB-AMP-PBD-X.S1 Concrete Containment Tendon Prestress Program Basis Document Rev. 1 4/25/2013

13. ER-AA-330-006 ISI and Testing of the Prestressed Concrete Containment Post Tensioning System Rev. 6

14. 5.2.2-BYR12-093 (Unit 1)

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

15. 5.2.2-BYR12-094 (Unit 2)

Regression Analysis to Predict Post-Tensioning Forces for Byron Unit 2 Containment Tendons in Support of License Renewal Rev. 0 1/10/2013

16. 5.2.5-BRW-12-0144-S (Unit 1)

Regression Analysis to Predict Post-Tensioning Forces for Braidwood Unit 1 Containment Tendons in Support of License Renewal Rev. 0 1/21/2013

17. 5.2.5-BRW-12-0145-S (Unit 2)

Regression Analysis to Predict Post-Tensioning Forces for Braidwood Unit 2 Containment Tendons in Support of License Renewal Rev. 0 1/21/2013

18. BY-N1044-501 Final Report For Exelon Byron Station U1 and U2 25th Year Containment Building and Tendon Surveillance -

PSC Rev. A 11/16/2009

19. 5.2.2-BYR12-131 (Unit1)

Containment Tendons-Predicted Lower Limit Forces During Period of Extended Operation - Byron Unit 1 Rev. 0 1/10/2013

20. 5.2.2-BYR09-17 Calculation of Tendon Predicted Lift-Off Forces for the 25th year ISI-Byron Unit 2 Rev. 0 04/27/2009

21. 5.2.2-BRW-10-0154-S Selection of Tendons and Calculation of Lift-Off Forces for 25th Year ISI-BRW Units 1 and 2 Rev. 0 05/23/2011

22. WO 728405 Exelon Braidwood Station Unit 1 and 2 ASME Section XI Class CC Structures 20th Year Unbonded Post Tensioning System Surveillance Engineering Evaluation Report 01/12/2007

23. AR 00477411 Ineffective wire discovered (BRW U2 - Cont. Tendon V225) 20th year Post-Tensioning Surveillance 04/10/2006

24. AR 00499108 Tendon D1-02 (BRW U1 - Low Yield Strength Observed During Wire Test) 06/12/2006

25. AR 00781251 U-2 Containment Buttress F-EF Flooded, Tendon Cans Submerged (BYR) 05/30/2008

26. AR 00240041 Grease Leakage at Various U-1 Vertical 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 applicants 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-AA-330-006. The program description states that prestress tendon forces (TF) are measured every five years while ER-AA-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 25th 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 ISI intervals consistent with IWL-2421 and procedure ER-AA-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 staffs 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 applicants 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 B.3.1.3, Environmental Qualification (EQ) of Electric Components Summary of Information in the Application. The LRA states that AMP B.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 applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants 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 staffs search of the applicants operating experience database.

Relevant Documents Reviewed Document Title Revision / Date

1. BBS-PBD-AMP-X.E1 Program Basis Document - Environmental Qualification (EQ) of Electric Components Revision 1, 05/01/2013

2. NES-G-14.02 Calculation No. BRW-01-0153-E/BYR01-068 Revision 2, 03/09/2001

3. AR01288474 Potential Green NCV - Classification of EQ Zones From HELB 11/09/2011

4. ER-AA-1100 Byron EQ Program: 3rd Quarter 2008 - 2nd Quarter 2013 N/A

5. ER-AA-1100 Braidwood Environmental Qualification (EQ) of Electric Components N/A

6. LS-AA-126-1001 FASA Self-Assessment Report Template: 2011 Byron Environmental Qualification Revision 6

7. LS-AA-126-1001 FASA Self-Assessment Report Template: 2012 Byron Environmental Qualification Revision 6

8. EQ-BB-004 Byron/Braidwood Stations Equipment Qualification Binder Conax Resistance Temperature Detector Revision 8

9. ER-AA-1100 Implementing and Management Engineering Program Revision 10

10. ARO1288474 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 LRA AMP are consistent with the corresponding elements of the GALL Report AMP.

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, 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. In 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 applicants 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 Title Revision / Date

1. Not available Equipment Qualification Design Program - Mechanical Revision 6

2. CC-AA-203 Equipment Qualification Program Revision 8

3. EQDP-MECH Pumps and Valves Volume 1 Revision 6

4. EQ-BB-052 Jamesbury Butterfly Isolation Valves and GH Bettis Actuators Revision 8

5. EQ-BB-044 Ingersoll Rand Containment Spray Pumps Revision 3

6. EQ-BB-047 Borg Warner Valves Revision 5

7. EQ-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

10. EQ-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 Hydraulic Operator Revision 7

12. EQ-BB-010 Anchor Darling Gate Isolation Valves Revision 5

13. EQ-BB-024 Anchor Darling Main Steam Isolation Valve Hydraulic Operators Revision 9E

14. EQ-BB-042 Anderson Greenwood Check Valves Revision 5

15. EQ-BB-025 Borg Warner Main Feed Isolation Valve Hydraulic Operators Revision 7C Document Title Revision / Date

16. EQ-BB-050 Tufline/Xomox Valves Revision 4

17. EQ-BB-048 TRW-Mission Check Valves Revision 2

18. EQ-BB-049 TRW Mission Valves Revision 3

19. EZ409-4 Radiation Exposure Evaluation of Elastomeric Valve Seat Materials Revision A

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

FSV-RY456 02/22/1999

21. 0EQ ER-00 002 EQ Evaluation to Address the Transient Changes/Increases in Spray pH following a LOCA 08/01/1997

22. EQDP-MECH Tab G58 EQDP-Mechanical Analysis of Phenolic Spacer Disc CV Pumps 1/2 CV01PA and PB 01/13/2006

23. EQDP-MECH Tab G61 ITT Letter to Exelon - M1 EPDM Diaphragm Operating Envelope Testing Summary 08/18/2008

24. 02-4854-RPT-1 Qualification of Valve Actuators for Nuclear Power Plants in Accordance with SwRI Test Plan 02-4854-SP-1, Volume II -

Wear Aging and Radiation Aging 08/04/1978 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 III 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 O-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-BB-046, states, that the qualified 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 CV01PA 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-BB-056, states that the valves have a life of 46 years subject to replacing the viton Parker O-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, Inservice Testing of Pumps in Nuclear Power Plants Program Use of the ASME Code Section XI, Inservice 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 ASME-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 EQ-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 EQ binders include active components and the surveillance schedules are associated with subcomponents that would typically be identified as consumable items such as O-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 EQ 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 EQ 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.