IR 05000306/2014010

IR 05000306/2014010; on 07/14/14 - 08/1/14; Prairie Island Nuclear Generating Plant, Unit 2; Post-Approval Site Inspection for License Renewal

ML14258B212
Person / Time
Site:	Prairie Island
Issue date:	09/12/2014
From:	Ann Marie Stone NRC/RGN-III/DRS/EB2
To:	Davidson K Northern States Power Co
Thomas Bilik
References
IR 2014010
Download: ML14258B212 (36)

Text

UNITED STATES ber 12, 2014

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 2 NRC POST-APPROVAL LICENSE RENEWAL INSPECTION REPORT 05000306/2014010

Dear Mr. Davidson:

On August 1, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed a Post-Approval Site Inspection for License Renewal at your Prairie Island Nuclear Generating Plant, Unit 2. The enclosed report documents the results of this inspection, which have been discussed on August 1, 2014, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, performed walkdowns, and interviewed personnel.

Based on the sample selected for review, there were no findings of significance identified during this inspection. The team concluded commitments were properly identified, implemented, and completed.

Based on the sample selected for review and in consultation with the Division of License Renewal in the Office of Nuclear Reactor Regulation, the NRC concludes that the licensee has completed the necessary commitments for operation into the period of extended operation.

In accordance with Title 10, Code of Federal Regulations (CFR), Section 2.390 of the NRC's

"Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Branch Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-306 License No. DPR-60

Enclosure:

Inspection Report 05000306/2014010 w/Attachment: Supplemental Information

REGION III==

Docket No: 05000306 License No: DPR-60 Report No: 05000282/2014010 Licensee: Northern States Power Company, Minnesota Facility: Prairie Island Nuclear Generating Plant, Unit 2 Location: Welch, MN Dates: July 14, 2014 - August 1, 2014 Inspectors: T. Bilik, Senior Reactor Engineer (Lead)

V. Meghani, Reactor Engineer G. ODwyer, Reactor Engineer A. Shaikh, Reactor Engineer S. Sheldon, Senior Reactor Engineer L. Smith, Observer Approved by: Ann Marie Stone, Branch Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000306/2014010; 07/14/14 - 08/1/14; Prairie Island Nuclear Generating

Plant, Unit 2; Post-Approval Site Inspection for License Renewal.

The report covers a team inspection conducted by region-based engineering inspectors. The inspectors concluded that commitments, license conditions, and regulatory requirements associated with the issuance of the renewed operating license are being met. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process Revision 5, dated February 2014.

NRC-Identified

and Self-Revealed Findings No findings were identified.

Licensee-Identified Violations

No violations were identified.

REPORT DETAILS

4OA5 Other Activities

.1 Post-Approval Site Inspection for License Renewal (Phase II) - Inspection Procedure

71003

a. Inspection Scope

(1) Review of Newly Identified Structures, Systems, and Components The inspectors discussed the identification of newly identified Structures, Systems, and Components (SSCs) under the purview of 10 CFR 54.37(b), with the licensees license renewal staff. The licensee performed a review of engineering changes and the site component database to identify SSCs, which had not previously been screened for license renewal applicability. In their letter dated November 20, 2012 (ML12335A135), pursuant with 10 CR 54.37(b), the licensee stated 592 SSCs were found to be subject to aging management requirements and therefore were considered "newly identified SSCs. The inspectors confirmed all newly identified components had been assigned to existing Aging Management Programs (AMPs) and appropriate aging management strategies had been invoked to detect and manage the applicable aging effects throughout the period of extended operation. The inspectors verified the list of newly identified SSCs were included as an enclosure to the Updated Safety Analysis Reports (USAR) updates issued November 20, 2012 and June 27, 2014, (ML14203A383). The inspectors did not identify any deficiencies.

(2) Review of Updated Safety Analysis Report and Commitment Change Process As part of reviewing the AMPs associated with the commitments, the inspectors reviewed the USAR descriptions to confirm the implemented programs were consistent with the USAR descriptions.

The inspectors reviewed the licensees procedures to ensure that commitment revisions would follow the guidance in NEI 99-04, Guidelines for Managing NRC Commitment Changes, including the elimination of commitments, and would properly evaluate, approve, and report changes to license renewal commitments listed in the USAR, in accordance with 10 CFR 50.59. The inspectors reviewed each change associated with the commitment as noted in the next section. No disparities were identified with respect to implementation.

(3) Review of Commitments The inspectors reviewed supporting documents including completed surveillance records and conducted interviews to verify the licensee completed the necessary actions to comply with the license conditions that are a part of the renewed operating license. The inspectors verified the licensee implemented the AMPs and time-limited aging analyses (TLAA) included in NUREG-1960, Safety Evaluation Report (SER) Related to the License Renewal of the Prairie Island Nuclear Plant Units 1 and 2, (ML11235A622), in accordance with Title 10 of the Code of Federal Regulations (CFR) Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants. The inspectors verified the corrective actions taken to address issues identified during the Prairie Island Unit 1 License Renewal Phase II inspection, which was documented in IR 05000282/2013009 (ML13205A429).

When changes to these commitments were identified, the inspectors reviewed the Commitment Change Evaluation (CCE) to verify the licensee followed the guidance in NEI 99-04 for the license renewal commitment change process, including the elimination of commitments, and properly evaluated, reported, and approved where necessary, changes to license renewal commitments listed in the USAR, in accordance with 10 CFR 50.59.

The inspectors reviewed the commitments listed below which are referenced to Appendix A of the SER. All Commitment Items were selected except Item 36, which was reported as complete in the SER; and therefore, not reviewed. Specific documents reviewed are listed in the Enclosure.

1. Commitment Item 1, Annual Prairie Island Nuclear Generating Plant Amendments to

Prairie Island Nuclear Generating Plant Application Commitment Item 1 specified that each year, following the submittal of the License Renewal Application and at least three months before the scheduled completion of the NRC review, Nuclear Management Company (NMC) will submit amendments to the Prairie Island Nuclear Generating Plant application pursuant to 10 CFR 54.21(b).

These revisions will identify any changes to the Current Licensing Basis that materially affect the contents of the License Renewal Application, including the USAR supplements.

The inspectors reviewed the license renewal application annual amendments submitted prior to completion of the NRC review. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 1.

2. Commitment Item 2, TLAAs, License Renewal Commitments, Incorporated into Prairie

Island Nuclear Generating Plant USAR Commitment Item 2 specified that following the issuance of the renewed operating license, the summary descriptions of AMPs and TLAAs provided in Appendix A, and the final list of License Renewal commitments, will be incorporated into the USAR as part of a periodic USAR update, in accordance with 10 CFR 50.71(e). Other changes to specific sections of the USAR necessary to reflect a renewed operating license will also be addressed at that time.

The inspectors verified that the summary descriptions of AMPs and TLAAs provided in Appendix A of the License Renewal Application, and the final list of License Renewal commitments were incorporated into the USAR.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 2.

3. Commitment Item 3, Above Ground Steel Tanks

Commitment Item 3 states the Above Ground Steel Tanks Program performs visual inspection of accessible external tank surfaces for corrosion. Inaccessible external surfaces (e.g., bottoms of tanks that sit directly on the ground or other support structures) will be inspected by ultrasonic inspection from inside the tank.

The inspectors reviewed the licensing and program basis documents, procedures, work orders, and Action Requests (ARs) associated with this program. This commitment requires that the licensee to ultrasonically examine the condensate storage tank (CST) bottoms to verify adequate thickness. The inspectors reviewed the ultrasonic test (UT) inspection results from the Unit 2 CST inspections. No concerns were identified during this inspection.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 3.

4. Commitment Items 4, Bolting Integrity Program

Commitment Item 4 states, in part, the procedures for the conduct of inspections in the External Surfaces Monitoring Program, Structures Monitoring Program, Buried Piping and Tanks Inspection Program, and the RG 1.127 Inspection of Water-Control Structures Associated with Nuclear Power Plants Program will be enhanced to include guidance for visual inspections of installed bolting.

The inspectors reviewed the licensing and program basis documents, implementing procedures, work orders, and ARs associated with this program. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 4.

5. Commitment Item 5, Buried Piping and Tanks Inspection Program

Commitment Item 5 states the licensee will implement a Buried Piping and Tanks Inspection Program prior to the period of extended operation, as described in LRA, Section B2.1.8. The enhancements to the program are implemented to ensure:

• The program performs visual inspections following excavation of external surfaces of buried piping and associated components (e.g., bolting) for evidence of coating damage and degradation of the underlying carbon steel and cast iron;

• A cathodic protection system is provided as an additional preventive measure, and is maintained at a minimum system availability of 90 percent. Cathodic protection system potential surveys are performed at least annually;

• Representative samples of buried piping, including a minimum of four inspection locations, are inspected every ten-year period of the license renewal term;

• Initial inspections, conducted within the ten years prior to the period of extended operation, will include at least one buried piping segment in each system within the scope of the program. Each inspection will include a minimum of ten linear feet of piping; and

• A minimum of three tank inspections are performed once every ten years, with three tanks inspected in the ten years preceding the period of extended operation.

The program will ensure that all seven buried fuel oil tanks will be inspected over the 30-year period, starting ten years prior to the period of extended operation The inspectors reviewed the licensing and program basis documents, procedures, work orders, inspection documentation, and ARs associated with this program. The inspectors verified implementing documents have been established to implement inspections of the cathodic protection system.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 5.

6. Commitment Item 6, Closed Cycle Cooling Water System Program

The Closed-Cycle Cooling Water System Program is an existing program, consistent with, and includes an exception to, the program as described in GALL AMP XI.M21, Closed-Cycle Cooling Water System.

Commitment Item 6 specified the program will be enhanced to include the attributes documented in LRA Section B2.1.9. The following enhancements will be implemented prior to the period of extended operation:

• Periodic inspection of accessible surfaces of components serviced by closed-cycle cooling water will be done when the systems or components are opened during scheduled maintenance or surveillance activities;

• Inspections are performed to identify the presence of aging effects and to confirm the effectiveness of the chemistry controls;

• Visual inspection of component internals will be used to detect loss of material and heat transfer degradation; and

• Enhanced visual or volumetric examination techniques will be used to detect cracking.

The general program requirements for this commitment were previously inspected and determined to be complete as documented in Inspection Report 05000282/2013008.

During this inspection, the inspectors reviewed changes to the program that occurred after the Unit 1 licensing renewal inspection to verify the program remained effective for both units. The inspectors also reviewed program basis documents, implementing procedures, and work orders. In addition to the commitment implementation review, the inspectors reviewed attributes of the Aging Management Program with IP 71002 to determine the adequacy of the program in detecting and monitoring aging effects. No concerns were identified during this inspection.

Based on the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 6.

7. Commitment Item 7, Compressed Air Monitoring Program

The Compressed Air Monitoring Program as an existing program that is consistent with GALL AMP XI.M24, Compressed Air Monitoring, with enhancements and an exception. The enhancements ensure the Station and Instrument Air System air quality will be monitored and maintained, in accordance with the instrument air quality guidance provided in ISA S7.0.01. Particulate testing will be revised to use a particle size methodology as in ISA S7.0.01. The commitment also specifies the program will be enhanced to incorporate on-line dew point monitoring.

The general program requirements for this commitment were previously inspected and determined to be complete as documented in Inspection Report 05000282/2013008.

During this inspection, the inspectors reviewed changes to the program that occurred after the Unit 1 licensing renewal inspection to verify the program remained effective for both units. The inspectors interviewed the program owner and reviewed the implementing procedures, completed work orders, scheduled recurring tasks for the program, and available trending data for applicable components. No concerns were identified during this inspection.

In addition to the commitment implementation review, the inspectors reviewed attributes of the aging management program in accordance with IP 71002 to determine adequacy of the program in detecting and monitoring aging effects.

Based on the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 7.

8. Commitment Item 8, Electrical Cable Connections Not Subject to 10 CFR 50.49

Environmental Requirements Program Commitment Item 8 states the licensee will develop a new program that is consistent, with exceptions, to NUREG-1801, Aging Management Program (AMP) XI.E6 for electrical cable connections not subject to 10 CFR 50.49 environmental qualification (EQ) requirements.

The licensee developed a one-time inspection program, which conducts a test of a representative sample of electrical connections to confirm the absence of aging effects.

The inspectors reviewed licensing and program basis documentation. The licensee credited of all electrical thermography inspections conducted in 2012 to meet this one time inspection requirement. These results were previously reviewed during the Unit 1 inspection as documented in Inspection Report 05000282/2013008 and were not further reviewed.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 8.

9. Commitment Item 9, Electrical Cables and Connections Not Subject to 10 CFR 50.49

Environmental Qualification (EQ) Requirements Program Commitment Item 9 states the licensee will develop a program that is consistent with NUREG-1801, AMP XI.E1 for electrical cables and connections installed in adverse localized environments not subject to 10 CFR 50.49 EQ requirements.

The licensee developed a program to visually inspect a representative sample of accessible electrical cables and connections installed in adverse localized environments to confirm insulation integrity. The program will also help to ensure the applicable electrical components will perform their intended functions.

The inspectors interviewed the program owner, reviewed licensing and program basis documentation, ARs, procedures, work orders, and records of walk downs for determining adverse localized environments, and visual inspections for cables. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 9.

10. Commitment Item 10, Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits Commitment Item 10 states the licensee will develop a program that is consistent with NUREG-1801, AMP XI.E2 for electrical cables and connections used in instrumentation circuits exposed to adverse localized environments, not subject to 10 CFR 50.49 EQ requirements. The program includes periodic testing and review of surveillance data to manage the aging effect of reduced insulation resistance on non-EQ sensitive instrumentation circuit cables and connections.

The inspectors reviewed the licensing and program basis documents, procedures, work orders, and related corrective actions. No concerns were identified during this inspection.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 10.

11. Commitment Item 11, External Surfaces Monitoring Program Commitment Item 11 states the licensee will implement an enhanced External Surfaces Monitoring Program prior to the period of extended operation. The inspectors reviewed the enhancements to verify:

• the scope of the program was expanded as necessary to include all metallic and non-metallic components within the scope of License Renewal that require aging management, in accordance with this program;

• the program ensures surfaces that are inaccessible or not readily visible during plant operations will be inspected during refueling outages;

• the program will ensure surfaces that are inaccessible, or not readily visible during both plant operations and refueling outages will be inspected at intervals to provide reasonable assurance aging effects are managed such that the applicable components will perform their intended function during the period of extended operation;

• the program will apply physical manipulation techniques, in addition to visual inspection, to detect aging effects in elastomers and plastics;

• the program includes acceptance criteria (e.g., threshold values for identified aging effects) to ensure the need for corrective actions will be identified before a loss of intended function; and

• the program ensures program documentation, such as walkdown records, inspection results; and other records of monitoring and trending activities are auditable and retrievable.

The inspectors reviewed the licensing and program basis documents, procedures, work orders, and ARs associated with this program. The inspectors verified the program enhancements and program commitments to ensure all have been incorporated into implementing plant procedures. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 11.

12. Commitment Item 12, Fire Protection Program Commitment Item 12 specified the licensee has an existing Fire Protection Program, with enhancements, that is consistent with NUREG-1801, AMP XI.M26. The Fire Protection Program was enhanced to require periodic visual inspection of the fire barrier walls, ceilings, and floors to be performed during walkdowns at least once every refueling cycle.

The general program requirements for this commitment were previously inspected and determined to be complete as documented in Inspection Report 05000282/2013008.

During this inspection, the inspectors reviewed changes to the program that occurred after the Unit 1 licensing renewal inspection to verify the program remained effective for both units. The inspectors also reviewed program basis documents, implementing procedures, and work orders. No concerns were identified during this inspection.

During the Unit 1 licensing renewal inspection, the inspectors reviewed the scheduled frequency of the enhanced inspections and identified the licensee scheduled the fire barriers inspections for every 18 months with a 25 percent grace period attached to it.

The inspectors were concerned the inspection frequency did not meet the committed frequency of at least once per fuel cycle. The licensee initiated AR 01386211 to address this issue. During this inspection, the inspectors reviewed the corrective actions of AR 01386211 and found that the frequency of the inspection was changed to at least once per fuel cycle, which met the commitment. The inspectors reviewed program basis documents, implementing procedures, and work orders. In addition to the commitment implementation review, the inspectors reviewed attributes of the Aging Management Program in accordance with Inspection Procedure (IP) 71002 to determine the adequacy of the program in detecting and monitoring aging effects. No additional concerns were identified during this inspection.

Based on the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 12.

13. Commitment Item 13, Fire Water System Program Commitment Item 13 is an existing Fire Water System Program, with enhancements, that is consistent with NUREG-1801, AMP XI.M27. The Fire Protection Program has been enhanced to add additional areas to the scope of the annual visual inspection and flushing activities, and to replace sprinkler heads that have been in service for 50 years.

The general program requirements for this commitment were previously inspected and determined to be complete as documented in Inspection Report 05000282/2013008.

During this inspection, the inspectors reviewed changes to the program that occurred after the Unit 1 licensing renewal inspection to verify the program remained effective for both units. The inspectors interviewed the program owner, reviewed the licensing and program basis documents, procedures, work orders, and corrective actions. No concerns were identified during this inspection.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 13.

14. Commitment Item 14, Flux Thimble Tube Inspection Program The Prairie Island Nuclear Generating Plant Flux Thimble Tube Inspection Program manages the loss of material due to wear on the in-core instrument thimble tubes. The flux thimble tubes provide a path for the in-core flux monitoring detectors and form part of the reactor coolant pressure boundary. The program conducts periodic inspections to monitor thinning of the flux thimble tube wall through eddy current testing. The program provides evaluation and trending of inspection results and appropriate corrective actions.

Commitment Item 14 states the Flux Thimble Tube Inspection Program will be enhanced as follows:

• The program will require the interval between inspections are established such that no flux thimble tube is predicted to incur wear that exceeds the established acceptance criteria before the next inspection;

• The program will require that re-baselining the examination frequency be justified, using plant-specific wear rate data unless prior plant-specific NRC acceptance for re-baselining have been received. If design changes are made to use more wear-resistant thimble tube materials, sufficient inspections will be conducted at an adequate inspection frequency for the new materials; and

• The program will require that flux thimble tubes that cannot be inspected must be removed from service.

The inspectors reviewed the program basis document, procedures, work orders, and ARs associated with this program. The inspectors verified the program and program enhancements were in place.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 14.

15. Commitment Item 15, Fuel Oil Chemistry Program Commitment Item 15 specified the Fuel Oil Chemistry Program (FOCP) would be enhanced prior to the period of extended operation. Enhancements to the FOCP ensure:

(1) particulate contamination testing of fuel oil in the 11 fuel oil storage tanks in-scope of License Renewal will be performed, in accordance with American Society for Testing and Materials D6217, on an annual basis; and

(2) One-Time ultrasonic thickness measurements will be performed at selected tank bottom and piping locations.

The inspectors reviewed the licensing and program basis documents, procedures, work orders, and ARs associated with this program. The inspectors verified the program enhancements were complete through review of commitment implementing documents for:

• particulate contamination testing of fuel oil in the 11 fuel oil storage tanks in-scope of license renewal (recurring);

• external UT on select tank bottom locations on one of the vaulted fuel oil storage tanks for the Unit 2 emergency diesel generators;

• internal tank cleaning, visual inspection and internal UT on select bottom locations on one of the Unit 1 emergency diesel generator underground storage tanks;

• internal tank cleaning, visual inspection, and internal UT on select bottom locations of the diesel driven cooling water pump fuel oil storage tank. Comparable areas of the tank will be inspected to provide a basis for trend evaluation;

• external UT on select bottom locations on four of the seven diesel fuel oil day tanks;

• external UT on select bottom locations of one of the two D1/D2 clean fuel oil storage tanks; and

• external UT on select piping locations typically considered low flow/stagnant areas.

No concerns were identified during this inspection. Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 15.

16. Commitment Item 16, Fuse Holders Program Commitment Item 16 states the licensee will develop a program that is consistent with NUREG-1801, AMP XI.E5.

The licensee developed a Condition Monitoring Program, which implements periodic visual inspections and test on fuse holders, in scope of license renewal, which are located in passive enclosures and assemblies, and exposed to environments that could potentially lead to electrical failures if left unmanaged. The licensee chose thermography as a proven test method.

The inspectors reviewed licensing and program basis documentation, procedures, work orders, and thermography inspections and results. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 16.

17. Commitment Item 17, Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Commitment Item 17 states the licensee will develop a program consistent with NUREG-1801, AMP XI.E3 for inaccessible medium and low voltage cables not subject to 10 CFR 50.49, Environmental Qualification.

The licensee developed a program, that performs periodic tests to provide an indication of the condition of the conductor insulation for inaccessible low and medium voltage power cables in scope of License Renewal and exposed to long periods of high moisture (greater than a few days at a time). The program also includes actions to limit the exposure of in-scope inaccessible low and medium voltage power cables to long term significant moisture, through periodic manhole and pull box inspections, for water accumulation, and draining of water, as needed.

The inspectors reviewed the licensing and program basis documents, work orders, and corrective actions. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 17.

18. Commitment Item 18, Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components Aging Management Program The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program is a new condition monitoring program consistent with GALL AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

This program performs visual inspections of the internal surfaces of mechanical components within the scope of License Renewal not covered by other aging management programs. The internal inspections are performed during scheduled preventive and corrective maintenance activities, or during other routinely scheduled tasks such as surveillance procedures, when internal surfaces are made accessible for inspections. The program inspections are performed to provide assurance that existing environmental conditions are not resulting in degradation that could result in a loss of component intended functions.

Commitment Item 18 states, an inspection of internal surfaces of miscellaneous piping and ducting components AMP will be implemented. The program features will be as described in LRA Section B2.1.22. Inspections for stress corrosion cracking will be performed by visual examination with a magnified resolution, as described in 10 CFR 50.55a(b)(2)(xxi)(A), or with ultrasonic methods.

General program requirements for this commitment were determined to be complete in Prairie Island Unit 1 IR 05000282/2013008. The inspectors reviewed changes to the program that occurred after the Unit 1 licensing renewal inspection and ensured that the program remained effective for both units.

The inspectors reviewed the license renewal application, program basis documents, implementing documents, and interviewed the plant personnel responsible for this program.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 18.

19. Commitment Item 19, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program Commitment Item 19 states that the program will be enhanced as follows:

• Program implementing procedures will be revised to ensure the components and structures subject to inspection are clearly identified; and

• Program inspection procedures will be enhanced to include the parameters corrosion and wear, where omitted.

The inspectors reviewed the licensing and program basis documents. The licensee made enhancements to the applicable program basis documents and implementing procedures. These documents were applicable to both units, and since they were reviewed during the Unit 1 inspection documented in IR 05000282/2013008, the inspectors did not perform further review. The inspectors reviewed a sample of work orders performed since the Unit 1 inspection and interviewed the plant personnel responsible for this program.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 19.

20. Commitment Item 20, Metal-Enclosed Bus Program Commitment Item 20 states the licensee will develop a program that is consistent with NUREG-1801, AMP XI.E4 for the interiors of the non-segregated 4160V phase bus between station offsite source auxiliary transformers and plant bus.

The licensee developed a condition-monitoring program that inspects the interiors of non-segregated 4160V phase bus between station offsite source auxiliary transformers and plant buses. The program manages the aging effect of reduction of installation resistance in insulation components, loose connections, and corrosion from moisture or debris intrusion in non-segregated bus ducts.

The inspectors reviewed licensing and program basis documentation, corrective actions, implementing procedures, work orders, and inspections results.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 20.

21. Commitment Item 21, Nickel-Alloy Nozzles and Penetrations Program Commitment Item 21 has been withdrawn according to Revision Letter dated March 27, 2009 (ML090900222).

22. Commitment Item 22, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Head of Pressurized Water Reactors (PWRs) Program Commitment Item 22 was withdrawn by the licensee in the Annual Update of the Application for Renewed Operating License (L-PI-09-043), dated April 13, 2009 (ML091140020). The withdrawal of the commitment was a result of the replacement of the Unit 1 reactor head, which incorporated Nickel-Alloy 690 for each of the penetration nozzles instead of the Nickel-Alloy 600 utilized in the previous heads.

Inspections for the upper reactor vessel head surface and each nickel alloy reactor head penetration nozzle are being implemented, in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Code Case N-729-1.

23. Commitment Item 23, One-Time Inspection Program Commitment Item 23 states a One-Time Inspection Program will be completed and the program features will be as described in LRA Section B2.1.29. The program developed a one-time inspection program to verify unacceptable material degradation is not occurring in areas exposed to oil, steam, treated water, or other environments where significant degradation is not expected to occur. The one-time inspection program addressed potentially long incubation periods for certain aging effects and has verified these aging effects are either, not occurring or are progressing so slowly as to have negligible effect on the intended function of the structure or component.

The inspectors reviewed the licensing and program basis documents. The inspectors previously reviewed the results of the one-time inspections during the Unit 1 inspection as documented in IR 05000282/2013008. The inspectors reviewed results of an additional inspection performed since the Unit 1 inspection. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 23.

24. Commitment Item 24, One-Time Inspection of American Society of Mechanical Engineers Code Class 1 Small Bore-Piping Program Commitment Item 24 states:

• Part A: A one-time inspection of ASME Code Class 1, Small-Bore Piping Program will be completed prior to the period of extended operation except as noted in Part B of this commitment. The program features will be as described in LRA Section B2.1.30. The following examinations of ASME Code Class 1 small-bore piping socket welds will be performed prior to the period of extended operation: Volumetric examinations of two socket welds on Unit 1 and three socket welds on Unit 2; or Destructive Examination of two socket welds per Unit; and

• Part B: Socket weld examinations required by the one-time inspection of ASME Code Class 1, Small-Bore Piping Program, not performed prior to the period of extended operation, will be performed within three years of each Unit entering the period of extended operation.

The licensee developed a one-time inspection program for inspection of the small-bore piping.

The inspectors reviewed licensing and program basis documentation. The licensee completed inspections of a sample of welds as required by the program. Results of the inspections, with the exception of the volumetric examination of socket welds in Unit 2, were reviewed previously during the Unit 1 inspection documented in IR 05000282/2013008. The inspectors reviewed results of a sample of the Unit 2 socket weld examinations and identified no issues.

During review of the licensees License Renewal Proof Notebook, the inspectors identified the sample size of Unit 1 socket welds did not meet the minimum 3 percent required by the program. According to the commitment, the licensee was required to perform two examinations prior to the period of extended operations and the remaining examinations as required to meet the minimum 3 percent sample size, were to be completed within three years after entering the period of extended operation. For Unit 1, this inspection is expected to be complete by August 9, 2016. Based on a population of 76 socket welds on Unit 1, the licensee needed to perform a minimum of three (2.28 rounded up) examinations. The licensee performed two examinations prior to the period of extended operations for Unit 1 per the commitment, but had not planned to perform the third examination. The licensee personnel rounded down the 2.28 value to two and believed that they had met the 3 percent sample size. In response to inspectors concern, the licensee initiated AR 1439207 and AR 1441222 to capture the concern and to track completion of the required examination within the period specified in the commitment. As stated above, since the third inspection is required to be complete by August 9, 2016, no violation or deviation from this commitment was identified at this time.

Based on the review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 24.

25. Commitment Item 25, PWR Vessel Internals Program Commitment Item 25 originally stated the licensee committed to the following activities for managing the aging of reactor vessel internal components:

• Participate in the industry programs for investigating and managing aging effects on reactor internals;

• Evaluate and implement the results of industry programs, as applicable to the reactor internals; and

• Upon completion of these programs, but not less than 24 months before entering; and the period of extended operation, submit an inspection plan for reactor internals to the NRC for review and approval. The licensee will implement an enhanced Reactor Vessel Internals Program prior to the period of extended operation.

By letter to the NRC, dated May 12, 2009 (ML091620163), the licensee amended the LRA and revised the commitment to read as follows:

• A PWR Vessel Internals Program will be implemented. The program features will be described in LRA Section B2.1.32. The program will be implemented prior to the period of extended operation; and

• An inspection plan for reactor internals will be submitted for NRC review and approval at least 24 months prior to the period of extended operation.

Then, by letter to the NRC, dated June 24, 2009, (ML091900037), as a response to follow up request for additional information (RAI) B2.1.38, the commitment was revised to read as follows:

• A PWR Vessel Internals Program will be implemented. Program features will be described in LRA Section B2.1.32 and will be implemented prior to the period of extended operation.

• An inspection plan for reactor internals will be submitted for NRC review and approval at least 24 months prior to the period of extended operation. In addition, the submittal will include any necessary revisions to the scoping, screening, and aging management review results for reactor internals, to conform to the NRC-approved Inspections and Evaluation Guidelines.

Lastly, by letter to the NRC, dated August 8, 2011, (ML112210299), Part B of the commitment has been revised by a commitment change to read as follows:

• An inspection plan for reactor internals will be submitted for NRC review and approval no later than October 1, 2012. In addition, the submittal will include any necessary revisions to the PWR Vessel Internals Program, as well as any related changes to the scoping, screening, and aging management, review results for reactor internals, to conform to NRC-approved Inspection and Evaluation Guidelines.

The inspectors reviewed procedures, program basis documents, commitment change evaluation, and ARs associated with this program. In a letter dated October 1, 2012, (ML12276A041), the licensee provided the inspection plan; therefore, the inspectors determined the licensee met Commitment Item 25.

26. Commitment Item 26, Reactor Head Closure Studs Program Commitment Item 26 specified the implementation of inservice inspection of the reactor vessel head closure studs. The program incorporates controls which ensure procurement of reactor head closure studs will be, in accordance with the material and inspection guidance provided in NRC Regulatory Guide (RG) 1.65.

The inspectors reviewed the licensing and program basis documents, implementing procedures, work orders and ARs associated with this program. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 26.

27. Commitment Item 27, Reactor Vessel Surveillance Program The Reactor Vessel Surveillance Program is an existing program that manages the reduction of fracture toughness of the reactor vessel due to neutron embrittlement using monitoring methods, in accordance with 10 CFR Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements. This program ensures the reactor vessel materials meet fracture toughness requirements and have adequate margin against brittle fracture caused by pressurized thermal shock. Commitment Item 27 specified the licensee save and store all withdrawn and tested surveillance capsules and withdrawn, untested spare capsules.

The inspectors reviewed the licensing and program basis documents, procedures, work orders and related ARs associated with this program. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 27.

28. Commitment Item 28, Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program Commitment Item 28 states the program will be enhanced as follows:

• Include inspections of concrete and steel components that are below the water line at the Screenhouse and Intake Canal. The scope will also require inspections of the Approach Canal, Intake Canal, Emergency Cooling Water Intake, and Screenhouse immediately following extreme environmental conditions or natural phenomena including an earthquake, flood, or tornado.

• Include an inspection of water-control concrete components that are below the water line for cavitation and erosion degradation.

• Visually inspect for damage such as cracking, settlement, movement, broken bolted and welded connections, buckling, and other degraded conditions following extreme environmental conditions or natural phenomena.

The inspectors reviewed the licensing and program basis documents. The licensee made enhancements to the applicable program basis documents and implementing procedures. These documents were applicable to both units, and since these were reviewed during the Unit 1 inspection as documented in IR 05000282/2013008, the inspectors did not perform further review. The inspectors reviewed a sample of work orders and corrective actions since the Unit 1 inspection. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined that the licensee met Commitment Item 28.

29. Commitment Item 29, Selective Leaching of Materials Program Commitment Item 29 states the implementation of an one-time Selective Leaching of Materials Program. However, when examinations indicated that the selective leaching aging mechanism was present, the licensee implemented a continuing Selective Leaching of Materials Program (USAR change 01372330).

The inspectors reviewed the licensing and program basis documents, implementing procedures, work orders and ARs associated with this program. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 29.

30. Commitment Item 30, Structures Monitoring Program Commitment Item 30 states the Structures Monitoring Program will be enhanced prior to the period of extended operation to add the following structures, components, and component supports to the scope of the inspections:

• Approach Canal;

• Fuel Oil Transfer House;

• Old Administration Building and Administration Building Addition;

• Component supports for cable tray, conduit, cable, tubing tray, tubing, non-ASME vessels, exchangers, pumps, valves, piping, mirror insulation, non-ASME valves, cabinets, panels, racks, equipment enclosures, junction boxes, bus ducts, breakers, transformers, instruments, diesel equipment, housings for heating, ventilation, and air conditioning (HVAC) fans, louvers, and dampers, HVAC ducts, vibration isolation elements for diesel equipment, and miscellaneous electrical and mechanical equipment items;

• Miscellaneous electrical equipment and instrumentation enclosures including cable tray, conduit, wire-way, tube tray, cabinets, panels, racks, equipment enclosures, junction boxes, breaker housings, transformer housings, lighting fixtures, and metal bus enclosure assemblies;

• Miscellaneous mechanical equipment enclosures including housings for HVAC fans, louvers, and dampers;

• Station Blackout (SBO) yard structures and components including SBO cable vault and bus duct enclosures;

• Fire Protection System hydrant houses;

• Caulking, sealant and elastomer materials; and

• Non-safety-related masonry walls that support equipment relied upon to perform a function that demonstrates compliance with a regulated event(s).

Furthermore, the licensee committed the program will:

• be enhanced to include additional inspection parameters;

• require an inspection frequency of once every five

(5) years for structures and structural components within the scope of the program. The frequency of inspections can be adjusted, if necessary, to allow for early detection and timely correction of negative trends; and

• require periodic sampling of groundwater and river water chemistries to ensure they remain non-aggressive The inspectors reviewed the licensing and program basis documents. The licensee made enhancements to the applicable program basis documents and implementing procedures. These documents were applicable to both units and were reviewed during the Unit 1 inspection documented in IR 05000282/2013008; therefore, the inspectors did not perform further review. The inspectors reviewed a sample of corrective actions since the Unit 1 inspection and interviewed the plant personnel responsible for this program. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 30.

31. Commitment Item 31, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Program Commitment Item 31 states a Cast Austenitic Stainless Steel (CASS) Program be implemented with features as described in LRA Section B2.1.39. The CASS Program manages the loss of fracture toughness due to thermal aging embrittlement of components, other than pump casings and valve bodies. The program determines the susceptibility of CASS components to loss of fracture toughness due to thermal aging embrittlement based upon the casting method, molybdenum content, and percent ferrite. For components determined to be potentially susceptible to thermal aging embrittlement, component-specific flaw tolerance evaluations are being prepared.

The inspectors reviewed the licensing and program basis documents, procedures, work orders and related ARs associated with this program. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 31.

32. Commitment Item 32, Water Chemistry Program Commitment Item 32 is an existing Water Chemistry Program, with enhancements, that is consistent with NUREG-1801, AMP XI.M27. Commitment Item 32 states the licensee will implement an enhanced Water Chemistry Program prior to the period of extended operation. The enhancements to the Water Chemistry Program require an increased sampling as needed, per revised fleet procedure, FP-CY-CHEM-01, to confirm the effectiveness of corrective actions taken to address abnormal chemistry conditions. The program will also require Reactor Coolant System dissolved oxygen action level limits to be consistent with the limits established in the Electric Power Research Institute (EPRI) PWR Primary Water Chemistry Guidelines.

The general program requirements for this commitment were previously inspected and determined to be complete as documented in Inspection Report 05000282/2013008.

During this inspection, the inspectors reviewed changes to the program that occurred after the Unit 1 licensing renewal inspection to verify the program remained effective for both units. The inspectors also reviewed program basis documents, implementing procedures, and work orders. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 32.

33. Commitment Items 33, 34, 35, and 47, Metal Fatigue of Reactor Coolant Pressure Boundary Program Commitment Item 33 states that the program will be enhanced as follows:

• The program will monitor the 6-component locations identified in NUREG/CR-6260 for older vintage Westinghouse plants, either by tracking the cumulative number of imposed stress cycles using cycle counting, or by tracking the cumulative fatigue usage, including the effects of coolant environment. The following locations will be monitored:

(a). Reactor Vessel Inlet and Outlet Nozzles; (b). Reactor Pressure Vessel Shell to Lower Head; (c). Reactor Coolant System (RCS) Hot Leg Surge Line Nozzle; (d). RCS Cold Leg Charging Nozzle; (e). RCS Cold Leg Safety Injection Accumulator Nozzle; and (f). Residual Heat Removal-to-Accumulator Piping Tee

• Program acceptance criteria will be clarified to require corrective action is taken before a cumulative fatigue usage factor exceeds 1.0 or a design basis transient cycle limit is exceeded.

Commitment Item 34 states the reactor internals baffle bolt fatigue transient limits of 1,835 cycles of plant loading at 5 percent per minute and 1,835 cycles of plant unloading at 5 percent per minute will be incorporated into the Metal Fatigue of Reactor Coolant Pressure Boundary Program and USAR Table 4.1-8.

Commitment Item 35 states the licensee will perform an ASME Section III fatigue evaluation of the lower head of the pressurizer to account for effects of insurge/outsurge transients. The evaluation will determine the cumulative fatigue usage of limiting pressurizer component(s) through the period of extended operation.

The analyses will account for periods of both Water Solid and Standard Steam Bubble operating strategies. Analysis results will be incorporated, as applicable, into the Metal Fatigue of Reactor Coolant Pressure Boundary Program.

Commitment Item 47 states the licensee will perform a review of the design basis ASME Class 1 fatigue evaluations to determine whether the NUREG/CR6260 components that have been previously evaluated for the effects of reactor coolant environment on fatigue life are the limiting components.

• If a more limiting component(s) is identified, the most limiting component will be evaluated for the effects of the reactor coolant environment on fatigue usage; and

• If the limiting component identified consists of nickel alloy, the methodology used to perform the Environmentally Assisted Fatigue (EAF) calculation for nickel alloy will be consistent with NUREG/CR-6909, or otherwise justified.

The inspectors reviewed the licensing and program basis documents. Commitment Items 34, 35, and 36 were completed prior to the Unit 1 inspection as documented in inspection report 05000282/2013008; and therefore, the inspectors did not perform further review. Program documents and procedures associated with commitment Item 33 were also reviewed during the Unit 1 inspection. The inspectors reviewed a sample of work orders associated with Commitment Item 33 and the Unit 2 calculations associated with Commitment Item 47. The inspectors also interviewed the plant personnel responsible for this program. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Items 33, 34, 35, and 47.

34. Commitment Items 36, Metal Fatigue of Pressurizer Surge Line Hot Leg nd the Charging Nozzles Commitment Item 36 states the licensee will complete fatigue calculations for the pressurizer surge line hot leg nozzle and the charging nozzle using the methodology of the ASME Code (Subsection NB) and will report the revised Cumulative Usage Factor (CUF) and CUFs adjusted for environmental effects at these locations as an amendment to the application. Conforming changes to LRA Section 4.3.3, PINGP EAF results, will also be included in that amendment to reflect analysis results and remove references to stress-based fatigue monitoring. Commitment 36 was completed per Attachment A of the SER.

35. Commitment Items 37, 38, 39, and 40, Cultural Resources Management Plan The Cultural Resources Management Plan (CRMP) was developed by the licensee in cooperation with the Prairie Island Indian Community and the U.S. Department of the Interior, Bureau of Indian Affairs. The CRMP was developed as a tool to licensee employees responsible for planning, reviewing, approving, overseeing, and/or participating in construction and excavation activities or other undertakings on the plant property. The CRMP seeks to:

• prevent disturbances of known and unknown archaeological, cultural, and historical (AC&H) resources by presenting the history of Prairie Island, its inhabitants, and the location and significance of its known AC&H resources;

• establish specific review and notification procedures for those who manage and conduct construction or excavation projects at the facility; and

• present guidance for proper identification of previously unidentified AC&H resources so the appropriate actions can be made.

Commitment Item 37 states the licensee will revise procedures for excavation and trenching controls and archaeological, cultural and historic resource protection to identify sensitive areas and provide guidance for ground-disturbing activities. The procedures will be revised to include drawings and illustrations to assist users in identifying culturally sensitive areas, and pictures of artifacts that are prevalent in the area of the site. The revised procedures will also require training of the Site Environmental Coordinator and other personnel responsible for proper execution of excavation or other ground-disturbing activities.

Commitment Item 38 states the licensee will conduct a Phase I Reconnaissance Field Survey of the disturbed areas within the sites boundaries. In addition, the licensee will conduct Phase I field surveys of areas of known archaeological sites to precisely determine their boundaries. The licensee will use the results of these surveys to designate areas for archaeological protection.

Commitment Item 39 states the licensee will prepare, maintain and implement a CRMP to protect significant historical, archaeological, and cultural resources that may currently exist on the plant site. In connection with the preparation of the CRMP, the licensee will conduct botanical surveys to identify culturally and medicinally important species on the plant site, and incorporate provisions to protect such plants into the CRMP.

Commitment Item 40 states the licensee will consult with a qualified archaeologist prior to conducting any ground-disturbing activity in any area designated as undisturbed and in any disturbed are that is described as potentially containing archaeological resources (as determined by the Phase I Reconnaissance Field Survey discussed in Commitment Number 38).

These commitments were reviewed during the Unit 1 inspection as documented in IR 05000282/2013008, and were not further reviewed. Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 37, 38, 39, and 40.

36. Commitment Items 41, 42, and 44, Reactor Cavity Leakage Commitment Item 41 states that during the first outage after refueling cavity repairs, the site will excavate the concrete in Sump C (containment low point) to perform examination of the containment vessel, concrete and rebar. This commitment was met for Units 1 and 2 prior to the Unit 1 inspection as documented in IR 05000282/2013008; and therefore, the inspectors did not perform further review.

Commitment Item 42 states that for two consecutive outages after refueling cavity repairs, the site will inspect areas with a history of leakage. If leakage is identified, it will be entered into the corrective action program and evaluated for additional actions.

The licensee performed the required inspections during refueling outages 2R27 and

2R28 and identified the leakage had not been totally eliminated. The licensee entered

the identified leakage into their corrective action program and created actions for continued investigations and identification of leakage reduction opportunities.

Commitment Item 44 states that during the first refueling outage following refueling cavity leak repairs in each Unit (repairs performed in refueling outages 1R26 and

2R26 ), a concrete sample will be obtained from a location known to have been wetted

by borated water leakage from the refueling cavity. These concrete samples will be tested for compression strength and will be subjected to petrographic examination to assess the degradation. This commitment item was met for both units as documented in IR 05000282/2013008; and therefore, the inspectors did not perform further review.

The inspectors reviewed the licensing and program basis documents, ARs, and work orders documenting the inspection results and additional actions. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Items 41, 42, and 44.

37. Commitment Item 43, Diesel Generator Hose Replacement Commitment Item 43 states the licensee would implement a Diesel Generator Hose Replacement Program prior to the period of extended operation.

License Renewal (LR) Commitment 43, Replace DG Rubber Hoses, was created to ensure procedures are in place to require the periodic replacement of rubber hoses in contact with fuel oil and lube oil environments. During a previous inspection as documented in Inspection Report 05000306/2012005-03 (ML13038A671), the inspectors identified a non-cited violation of 10 CFR Part 50, Appendix B, Criterion III for the licensees failure to establish measures for the review for suitability the use of rubber hoses beyond the vendor recommended service life. Specifically, several hoses in the D5 and D6 emergency diesel generators and in the diesel driven fire pump had been installed beyond the vendor recommended service life of 10-years without further evaluation of acceptability. The licensee entered this issue into their CAP as CAP 1361849, evaluated the installed hoses condition, and replaced or scheduled the replacement of hoses installed longer than the recommended service interval.

During this inspection effort, the inspectors reviewed program basis documents, periodic replacement procedures, vendor manuals, work orders, and associated ARs and interviewed plant personnel responsible for this program. The inspectors verified the program requirements for this commitment were complete. The inspectors also verified the licensee implemented actions to periodically replace rubber flexible hoses exposed to fuel oil or lubricating oil internal environments in the emergency diesel generators, their support systems, and in the 122 diesel driven fire pump. No additional concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Item 43.

38. Commitment Items 45 and 46, Steam Generator Tube Integrity Program The Steam Generator Tube Integrity Program is an existing program that manages the aging effects of steam generator tubes, tube repairs, and accessible steam generator secondary side internal components. Incorporating the guidance of NEI 97-06, the program manages aging effects through a balance of mitigation, inspection, evaluation, repair, and leakage monitoring measures.

Commitment Item 45 states the performance of an inspection of each original Unit 2 steam generator to assess the condition of the divider plates and associated welds if they are not replaced prior to entry into the period of extended operation.

Commitment Item 46 states the performance of a one-time inspection sample of tube-to-tube-sheet welds in each Unit 1 steam generator to determine if primary water stress corrosion cracking is present. The inspections are to be performed during the first Unit 1 refueling outage after the steam generators have reached 20 years of service.

The inspectors reviewed the program basis document, implementing procedures, completed work orders and ARs associated with this program. With respect to Commitment Item 45, the licensee did replace the Unit 2 steam generators; therefore, no additional action is required for this commitment. No concerns were identified during this inspection.

Based on review of the timeliness and adequacy of the licensees actions, the inspectors determined the licensee met Commitment Items 45 and 46.

39. LR-TR-543, GALL Gap Analysis (LR-TR-543/LRI-TR-001)

At the time the licensee submitted their application for a renewed license, the NRC used Revision 1 of NUREG-1801, Generic Aging Lessons Learned (GALL) Report.

Since that time, the agency revised the NUREG incorporate

(1) lessons learned from the reviews of previous license renewal applications,

(2) operating experience obtained after the NRC issued Revision 1 to the GALL Report, and

(3) other public input, including industry comments. On July 1, 2011, the NRC issued NRC Regulatory Issues Summary (RIS) 2011-05, Information on Revision 2 to the Generic Aging Lessons Learned Report for License Renewal of Nuclear Power Plants, which describes the more noteworthy differences between the two revisions. Although the RIS does not require specific action or written response, this document highlights the value the NRC staff places on operating experience. It reminds licensees that the determination of the adequacy of AMPs is based, in part, on the applicants consideration of, and its actions taken to address, both plant-specific and industry operating experience.

The licensee entered the RIS into their corrective action program as LRI-TR-001 to evaluate the impact on the current AMPs. The inspectors noted the licensee only addressed the issues specifically identified in the RIS but did not perform a review of other differences between the revisions. After further discussion, the licensee initiated AR 01438469, Some Aging Management Programs Not Considering GALL Revision 2, to evaluate any inconsistencies or gaps that could warrant changes to the AMPs based on this operating experience.

b. Findings and Observations

The inspectors identified two observations of minor significance as documented above.

4OA6 Management Meetings

.1 Exit Meeting Summary

On August 1, 2014, the inspectors presented the inspection results to the Site Vice-President, Mr. K. Davison and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Davison, Site Vice President

C. Younie, Plant Manager

B. Hammargren, Regulatory Affairs Engineer

J. Whitfield, Programs Engineer

L. Farrell, Senior Programs Engineer

K. Davison, Director, Site Operations

A. Mitchell, Site Engineering Director

S. Sharp, Plant Manager

T. Allen, Assistant Plant Manager

J. Anderson, Regulatory Affairs Manager

LIST OF ITEMS

Opened, Closed, and Discussed

None Attachment