IR 05000483/2024011

NRC Post-Approval Site Inspection for License Renewal (Phase 2) Report 05000483/2024011

ML24117A310
Person / Time
Site:	Callaway
Issue date:	05/01/2024
From:	Nick Taylor NRC/RGN-IV/DORS/EB2
To:	Diya F Ameren Missouri
Smith W
References
IR 2024011
Download: ML24117A310 (54)

Text

May 01, 2024

SUBJECT:

CALLAWAY PLANT - NRC POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL (PHASE 2) REPORT 05000483/2024011

Dear Fadi Diya:

On March 21, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Callaway Plant and discussed the results of this inspection with John Beck, Vice President Engineering, and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Nicholas H. Taylor, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000483 License No. NPF-30

Enclosure:

As stated

Inspection Report

Docket No.

05000483

License No.

NPF-30

Report No.

05000483/2024011

Enterprise Identifier:

I-2024-011-0006

Licensee:

Ameren Missouri

Facility:

Callaway Plant

Location:

Steedman, MO

Inspection Dates:

March 4-22, 2024

Inspectors:

C. Smith, Senior Reactor Inspector, Team Leader

A. Saunders, Reactor Inspector

G. Pick, Senior Reactor Inspector

C. Young, Senior Reactor Analyst

Approved By:

Nicholas H. Taylor, Chief

Engineering Branch 2

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an NRC POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL (PHASE 2) at Callaway Plant, in accordance with the Reactor Oversight Process.

The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===71003 - Post-Approval Site Inspection for License Renewal Phase 2 Inspection Activities Inspection Procedure 71003, Post-Approval Site Inspection for License Renewal, recommended that the inspection be conducted shortly before the period of extended operation.

The period of extended operation is the additional 20 years beyond the original 40-year licensed term. The period of extended operation for Callaway Plant will begin after midnight on October 18, 2024.

The inspectors evaluated whether the licensee:

(1) completed actions required to comply with the license renewal license condition and commitments;

(2) implemented the aging management programs that agreed with those approved in the safety evaluation report and described in the safety analysis report;

(3) followed the guidance in Nuclear Energy Institute (NEI) 99-04, Guidelines for Managing NRC Commitment Changes, for changing license renewal commitments and followed the guidance in 10 CFR 50.59 when making changes to the license renewal supplement;

(4) identified, evaluated, and incorporated newly identified structures, systems, and components into their aging management programs; and (5)implemented operating experience review and corrective action programs that account for aging effects.

NUREG-2172, Safety Evaluation Report (SER) Related to the License Renewal of Callaway Plant, Unit 1, appendix A, Callaway Plant Unit 1 License Renewal Commitments, listed 46 commitments. The inspectors reviewed 39 of the 46 commitments and closed 37 commitments.

The NRC had previously closed five commitments and evaluated implementation of five aging management programs during the Phase 1 inspection documented in NRC Inspection Report 05000483/2023010 [ML23317A389]. Additionally, the inspectors did not close commitments 32 and 45. Additionally, the inspectors reviewed 32 aging management programs.

For each aging management program reviewed, the inspectors reviewed program documents, license renewal documents, the safety analysis report, and the safety evaluation report.

Supporting documents reviewed included implementing procedures, work orders, inspection reports, engineering evaluations, calculations, database entries, and condition reports. The inspectors interviewed program owners and license renewal program personnel.

The inspectors determined that the licensee had translated their license renewal application into Chapter 19 of their safety analysis report. The inspectors listed specific documents reviewed in the attachment.

Post-Approval Site Inspection for License Renewal===

(1)19.1.1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD (XI.M1) and Commitment 46 This existing program manages cracking, loss of fracture toughness, and loss of material of ASME Class 1, 2, and 3 pressure-retaining components. These components include welds, pump casings, valve bodies, integral attachments, and pressure-retaining bolting. Methods of detection include periodic volumetric, surface, and/or visual examinations and leakage testing. The existing program required no enhancements or exceptions.

Commitment 46 specified:

Perform periodic inspection of the reactor vessel cladding indications identified in FSAR section 5.2.3.2.2 SP and reconcile the inspection results with the corrosion analysis to ensure the analytical basis of the analysis is maintained.

The inspectors reviewed the aging management program basis document, implementing procedures, completed reactor vessel inservice inspection job documentation, and commitment closure documents. The inspectors concluded that the station's implementing procedures are adequate to implement these required existing inservice inspection programs. The inspectors concluded that the inspection activities specified in commitment 46 have been adequately implemented.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(2)19.1.2 Water Chemistry (XI.M2)

This existing mitigation program manages the chemistry in the primary and secondary water. The program required no enhancements or exceptions, and the licensee based this program on the relevant industry standards. The primary water chemistry program monitors and controls the chemical environment in the reactor coolant system and applicable auxiliary systems. The secondary water chemistry program monitors and controls the chemical environment in the steam generator secondary side and the secondary cycle systems. This program required no enhancements or exceptions, and there were no commitments associated with this program.

The inspectors reviewed the aging management program basis document, implementing procedures, and chemistry trends. The inspectors verified that licensee procedures provide instructions and specifications for chemical species, impurities and additives, sampling and analysis frequencies, and corrective actions for out-of-specification primary and secondary water chemistry. The licensee uses control band values as acceptance criteria for the monitored parameters. The inspectors verified the control of selected parameters for both primary and secondary chemistry.

Primary chemistry control uses filtration and ion exchange to control contaminants and ensures high quality makeup water, addition of lithium hydroxide for elevated pH control, hydrazine and dissolved hydrogen for oxygen scavenging, boric acid for reactivity control, and depleted zinc acetate for corrosion control and dose reduction.

Secondary chemistry control uses demineralizers and steam generator blowdown, addition of organic amines and all volatile treatment for pH control, hydrazine scavenges dissolved oxygen present in the feedwater and condensate systems.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(3)19.1.5 Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components (XI.M11B)

This existing program manages loss of material caused by boric acid-induced corrosion in susceptible safety-related components in the vicinity of nickel-alloy reactor coolant pressure boundary components, as well as cracking of nickel-alloy components and associated welds in reactor coolant pressure boundary components.

The program provides inspection requirements for the reactor pressure vessel, pressurizer, and reactor coolant pressure boundary piping components if they contain primary water stress corrosion cracking susceptible materials designated alloys 600/82/182. The program also includes inspection requirements for the reactor pressure vessel upper head. This program required no enhancements or exceptions, and there were no commitments associated with this aging management program.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed inspection activities. The inspectors concluded that the station's implementing procedures are adequate to implement these required programs, and the program appear to be implemented appropriately in accordance with station procedures.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(4)19.1.6 PWR Vessel Internals (XI.M16A) and Commitments 4, 43, and 44 This new program required enhancement and implements the materials reliability program guidelines, particularly MRP-227, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, revision 1A. This program manages aging effects related to

(a) various forms of cracking, including stress corrosion cracking, primary water stress corrosion cracking, irradiation assisted stress corrosion cracking, or cracking caused by fatigue/cyclical loading;

(b) loss of material induced by wear;

(c) loss of fracture toughness caused by either thermal aging or neutron irradiation embrittlement;

(d) changes in dimensions caused by void swelling or distortion; and

(e) loss of preload caused by thermal and irradiation-enhanced stress relaxation or creep.

Commitment 4 specified:

Implement the PWR Vessel Internals Program as described in license renewal amendment. Also address NRC applicant/licensee action item 1 from MRP-227, revision 0A, safety evaluation dated December 16, 2011, which required the licensee to evaluate their design and operating history to identify the plant specific inspection categories.

Commitment 43 specified:

Modify the core design procedures to address the following core design parameters during future core design reviews:

• Active fuel - upper core plate distance greater than 12.2 inches.

• Average core power density remains less than (<) 124 watts/cc.

• Heat generation figure of merit remains less than or equal to (<) 68 watts/cc.

Commitment 44 specified:

For all MRP-191, Materials Reliability Program: Screening, Categorization, and Ranking of Reactor Internals Components for Westinghouse and Combustion Engineering PWR Design, Table 4-4 components, perform one or more of the following resolution options for the non-CASS reactor vessel internals components, which had 20 percent or greater cold work, and 30 ksi (kilo pound per square inch)operating stress: replacement, inspection, impact evaluation, or mitigation.

The inspectors reviewed the aging management program basis document, implementing procedures, nondestructive evaluation reports for evaluating the reactor vessel internals, calculations related to the core design parameters, and commitment closure documents. The licensee utilizes their primary water chemistry program to control the parameters that contribute to the various types of stress corrosion cracking by limiting the amount of oxygen in the primary water.

The inspectors determined that procedure EDP-ZZ-04070, Materials Degradation Management Plan, appendix C, PWR Vessel Internals Aging Management Program, revision 9 implemented the reactor vessel internals program specified in commitment 4. Implementation of MRP 227, revision 1A resolved the applicant/licensee action item 1 when the licensee had categorized their reactor vessel internals components.

The inspectors determined that procedure EDP-ZZ-00014, Reload Design Control and Coordination, revision 24, step 4.4.18 appropriately implemented commitment 43 by verifying for each reload design the specific parameters described in the commitment. The licensee documented in Condition Report 202206600 that they expected they would exceed the heat generation figure of merit for a short period of time (32 days) during cycle 27 (current cycle when this inspection was conducted).

The guidance in MRP 2013-015, Attachment 1: MRP-227-A Applicability Guidelines for Combustion Engineering and Westinghouse Pressurized Water Reactor Designs, dated October 14, 2013, required monitoring the days that the value was exceeded but did not identify it as a concern until the value exceeded exceeds 730 days. The licensee described that they would continue to track whenever they exceed the heat generation of merit but expected to not exceed the value in the future.

The inspectors confirmed that the licensee met commitment 44 by determining that the vessel internals failed to exceed 30 ksi stress or had no more than had 20 percent cold work.

The inspectors determined that the licensee had completed several of the MRP-227, revision 1A inspections, including the baffle bolts, several required remote visual inspections, and the upper internals guide tube. The licensee identified some wear in the upper internals guide tube guide cards and evaluated the amount of wear in report 12-9350920-000, Callaway Unit 1 17x17AS Upper Internals Guide Tube Guide Card Wear Evaluation described some wear but the evaluation concluded that a follow-up evaluation would need to occur before the plant achieved 46.6 effective full power years (EFPY) of operation. The inspectors verified that the licensee scheduled the reinspection through preventive maintenance task 1009113.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(5)19.1.7 Flow-Accelerated Corrosion (XI.M17)

This existing program manages aging effects caused by flow accelerated corrosion, such as wall thinning on internal surfaces. This program includes analysis, inspection, and verification to assure the integrity of all carbon steel lines and fittings containing high energy fluids, and valve bodies retaining pressure in these systems. The program implements nondestructive methods including ultrasonic testing, radiographic testing, and visual inspections to assure structural integrity. The existing program required no enhancements or exceptions, and there were no commitments associated with this aging management program.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed program activities. The inspectors concluded that the station's implementing procedures are adequate to implement these required programs, and the program appear to be implemented appropriately in accordance with station procedures.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(6)19.1.8 Bolting Integrity (XI.M18) and Commitment 5 This existing program manages cracking, loss of material caused by corrosion, and loss of preload. The program includes preload control, selection of bolting material, use of lubricants or sealants, and performance of periodic inspections for indication of aging effects consistent with industry and NRC guidance.

Commitment 5 specified:

Enhance the program to:

• Reference NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation of Failure in Nuclear Power Plants, and Electric Power Research Institute (EPRI) NP-5769 to meet the GALL Report recommendations.

• Include bolting in the list of items inspected during walkdowns.

• Include a visual inspection of a sample of submerged bolting heads in raw water and wastewater environments every four refueling outages (6 years). In addition, when submerged raw water and wastewater pump casings are disassembled during maintenance, the bolting threads will be opportunistically inspected. A sample of submerged bolting on the fuel oil storage tank transfer pumps will be visually inspected every 10 years when the pumps are disassembled for maintenance. The sample for submerged bolting will be 20 percent of the population with a maximum of 25 for each environment, focusing based on time in service and severity of operating conditions.

The inspectors reviewed the aging management program basis document, implementing procedures, corrective action reports, and commitment closure documents.

The inspectors verified that the licensee had incorporated the commitments in the following documents: Callaway Plant Bolting Manual, procedure EDP-ZZ-01131, appendix K, Engineering System Walkdowns, procedure APA-ZZ-00356, Pump and Valve Inservice Test Program, procedure APA-ZZ-00400, Procurement of Parts, Supplies, Materials and Services, and procedure APA-ZZ-00662, ASME Section XI Repair/Replacement Program.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(7)19.1.9 Steam Generators (XI.M19) and Commitments 34 and 35 This existing program manages cracking, loss of material, reduction of heat transfer, and wall thinning of the steam generator tubes, plugs, sleeves, and secondary side steam generator internal components. The program provides preventive measures in the form of predictive assessment, tube plugging, foreign material exclusion, foreign object search, secondary side cleaning and maintenance, and maintaining the chemistry. The program detects degradation through nondestructive examinations, visual inspection, and in situ pressure testing.

Commitment 34 specified:

Perform an analytical evaluation of the steam generator divider plate welds to establish a technical basis which concludes that the steam generator RCS pressure boundary is adequately maintained with the presence of steam generator divider plate weld cracking. The analytical evaluation will be submitted to the NRC for review and approval.

Commitment 35 specified:

Perform an analytical evaluation of the steam generator tube-to-tubesheet welds either determining that the welds are not susceptible to primary water stress corrosion cracking or redefining the reactor coolant pressure boundary of the tubes, where the steam generator tube-to-tubesheet welds are not required to perform a reactor coolant pressure boundary function. The redefinition of the reactor coolant pressure boundary will be submitted as part of a license amendment request requiring approval from the NRC. The evaluation for determination that the welds are not susceptible to PWSCC and do not require inspection will be submitted to the NRC for review.

The inspectors reviewed letter ULNRC-06849, Callaway Plant License Renewal Resolution for commitments 34 and 35 - Perform Evaluation of Crack Initiation and Propagation In Steam Generator Divider Plate and Tube-to-Tubesheet Welds, dated December 20, 2023, This letter submitted the analyses to NRC as required by commitments 34 and 35. At the time of the onsite inspection, the NRC HQ staff had not reviewed and approved the analyses, but the inspectors considered the commitments closed as the licensee submitted the analyses as required.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(8)19.1.10 Open-Cycle Cooling Water System (XI.M20) and Commitment 6 This existing testing and inspection program manages loss of material, wall thinning, reduction of heat transfer, cracking, blistering, change in color, and hardening and loss of strength for those components that are exposed to the raw water environment of the essential service water system and heat exchangers and other components in other systems serviced by the essential service water system.

Commitment 6 specified:

Enhance the program procedures to:

• Include polymeric material inspection requirements, parameters monitored, and acceptance criteria.

• Include inspection and cleaning, if necessary, of the airside of safety-related air-to-water heat exchangers cooled by the essential service water system.

• Develop an inspection technique to identify, during a one-time inspection, in a buried carbon steel pipe internal pipe wall degradation caused by microbiologically influenced corrosion.

• Perform periodic visual inspections on all accessible internal surface coatings of the listed equipment.

• Conduct baseline inspections of accessible internal surfaces coatings of the in-scope components. Inspect coatings every 6 years on an alternating train basis.

• Inspect coatings with blisters, peeling, delamination, or rusting that does not require remediation every 4 years.

• For peeling, delamination, and blisters determined to not meet the acceptance criteria and that will not be repaired, replaced, or removed, physical testing is performed where physically possible.

• Inspection results, including blisters, are evaluated by a qualified coatings specialist.

• Corrective actions will be determined using the corrective action program and will incorporate the requirements specified in LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers and Tanks.

The inspectors reviewed the aging management program basis document, implementing procedures, completed surveillances, and completed preventive maintenance tasks. The inspectors verified that the licensee continued to implement the requirements of Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, as prescribed by plant procedures. The inspectors reviewed a sample of the most recent room cooler inspections, component cooling water heat exchanger inspections, essential service water system flow balancing, measurements of wall thinning and pitting in above-ground carbon steel piping caused by microbiological corrosion, required chemical controls for control of corrosion, microbiological influenced corrosion, and algae, and ultimate heat sink maintenance activities that included monitoring monuments, removing silt, and applying chemicals.

The inspectors determined that the licensee established a Raw Water Corrosion Monitoring Program Long Term Asset Management Plan with specific monitoring requirements for their above-ground essential service water piping. The licensee risk-ranked piping segments to prioritize review and evaluation. The licensee identified additional piping segments, particularly in low-flow or stagnant areas, to be replaced with stainless steel.

The inspectors confirmed that the licensee enhanced the following procedures, in accordance with the commitments:

1. EDP-ZZ-01121, Raw Water Systems Predictive Performance Program, to

inspect polymers and to perform coatings inspection.

2. EDP-ZZ-3001, GL89-13 Heat Exchanger Inspection, to require inspecting

the air side of heat exchangers.

3. ETP-ZZ-03050, Aging Management of Loss of Coating or Lining Integrity for

Internal Coatings, to provide the coatings acceptance criteria, which included guidelines for blisters, peeling, delamination, or rusting, to list the in-scope open cycle cooling water components that required inspections, to require a coatings specialist qualified to regulatory guide 1.54, revision 2, and to require corrective actions in accordance with regulatory guide 1.54, revision 2.

The inspectors verified that the licensee had performed the required baseline inspections and included the appropriate references to the requirements of Regulatory Guide 1.54, revision 2.

The inspectors confirmed that the licensee replaced all their buried pipe with high density polyethylene or stainless steel at specific end points such as the discharge of the essential cooling water pumps or the cooling tower supply piping. Because the licensee no longer had any buried carbon steel piping, the inspectors agreed that they had no need to implement the one-time inspection technique to detect microbiologically induced corrosion.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(9)19.1.11 Closed Treated Water Systems (XI.M21A) and Commitment 7 This existing preventive program relies on chemical water treatment, including corrosion inhibitors, to manage loss of material, cracking, and reduction of heat transfer for components within the scope of license renewal in the closed-cycled cooling water systems. The licensee enhanced the program to conduct periodic inspections to assess the presence or extent of corrosion, fouling, and/or cracking.

The aging management program basis document identified eight closed cooling water systems that used one of the following five combinations of chemicals to control corrosion: nitrite/molybdate with tolyltriazole, molybdate with tolyltriazole, ethylene glycol, diesel coolant additive with ethylene glycol, and nitrite with tolyltriazole. This program followed the guidance in EPRI 1001820, Closed Cooling Water Chemistry Guideline, revision 1.

Commitment 7 specified:

Enhance procedures to:

• Perform baseline visual inspections of representative samples of each combination of material and water treatment program and at least every 10 years or opportunistically.

• Select sample locations based on the likelihood of corrosion and cracking.

Use industry standards or a plant-specific inspection procedure with qualified personnel to detect aging. This periodic inspection serves as a leading indicator of the condition of the interior of piping components otherwise inaccessible for visual inspection.

The inspectors reviewed the aging management program basis document, implementing procedures, chemistry trends, and completed inspections. The inspectors verified that licensee procedures provide instructions and specifications for chemicals, impurities and additives, sampling and analysis frequencies, and corrective actions for out-of-specification parameters. The licensee uses control band values as acceptance criteria for the monitored parameters.

The inspectors verified that procedure EDP-ZZ-01140, Closed Treated Water Systems Program, revision 1, provided detailed implementation of the enhancement related to the periodic evaluation including identifying the 20 percent sample of each material and environment up to a maximum of 25 and a minimum of 2 components.

Because the purpose statement in procedure EDP-ZZ-01140 described only the enhancement related to the periodic evaluation without discussing the chemistry controls, the inspectors questioned the licensee whether this program provided the best method for implementing this aging management program. The inspectors determined that chemistry procedure CDP-ZZ-00940, Auxiliary Water Systems Chemistry Optimization Plan, provided the chemical control for the closed systems.

The inspectors identified this as one example of the disconnect from the license renewal documentation to a clear nexus in procedures. The licensee captured this concern in Condition Report 202402070.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(10)19.1.12 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems (XI.M23) and Commitment 8 This existing program manages loss of material and loss of preload for bolting for all cranes, trolley and hoist structural components, fuel handling equipment and applicable rails within the scope of license renewal. Visual inspections managed loss of material caused by corrosion of structural members and bolting, loss of materials caused by wear of rails, and loss of preload for bolted connections.

Commitment 8 specified:

• Inspect crane structural members for loss of material due to corrosion and rail wear, and loss of preload.

• Include performance of periodic inspections as defined in the appropriate ASME B30 series standard for all cranes, hoists, and equipment handling systems within the scope of license renewal. For handling systems that are infrequently in service, such as those only used during refueling outages, periodic inspections may be deferred until just prior to use.

• Require evaluation of loss of material due to wear or corrosion and loss of bolting preload per the appropriate ASME B30 series standard.

• Require repairs to cranes, hoists, and equipment handling systems per the appropriate ASME B30 series standard.

The inspectors reviewed the aging management program basis document, implementing procedures, nondestructive evaluation reports, crane inspection reports, completed work orders, and commitment closure documents. The inspectors verified procedure APA-ZZ-00365, Callaway Lifting and Rigging Program, and specific crane inspection procedures implemented commitment 5. The procedures included the appropriate materials and followed the appropriate ASME B30 series standard.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(11)19.1.14 Fire Water System Program (XI.M27) and Commitments 10 and 39 This existing program manages loss of material and flow blockage caused by corrosion, microbiologically induced corrosion, and fouling of carbon steel, cast-iron, stainless steel and copper alloy components in fire protection systems exposed to water. Components included in the program include fire hose stations, standpipes, piping (above ground, buried and underground), piping components, hydrants, fire pump casings, valve bodies, fittings, spray nozzles, fire hoses, sprinklers, sprinkler heads, and the fire water storage tanks, including coatings. The program includes the internal surfaces of water-based fire protection system piping that is normally drained, such as dry-pipe sprinkler system piping.

Commitment 10 specified:

• Recoat the internal surface of fire water storage tanks.

• Require the inspection of the interior of the fire water storage tanks to include checking for evidence of voids beneath the floor.

• Enhance the program procedures to:

o Perform internal inspections on accessible exposed portions of fire water piping during plant maintenance activities.

o Replace sprinkler heads prior to 50 years in service or have a recognized testing laboratory field-service test a representative sample in accordance with listed standards and test additional samples every 10 years thereafter.

o Review and evaluate trends in flow parameters recorded during the flow tests.

o Perform annual hydrant flow testing and hydrostatic testing of fire brigade hose.

• Enhance the program to include nonintrusive pipe wall thickness examinations every 3 years of a total of 100 feet of aboveground fire water piping based on system susceptibility to corrosion or fouling.

• Perform augmented tests and inspections of water-based fire protection system components that have been wetted but are normally dry. If piping segments cannot be drained or that allow water to collect:

o In each 5-year interval, either conduct a flow test or flush sufficient to detect potential flow blockage or conduct a visual inspection of 100 percent of the internal surface of piping segments.

o In each 5-year interval, 20 percent of the length of piping segments is subject to volumetric wall thickness inspections. Measurement points will be obtained to the extent that each potential degraded condition can be identified (e.g., general corrosion, MIC). The 20 percent of piping will be in different locations than previously inspected piping.

If the results of a 100 percent internal visual inspection are acceptable, and the segment is not subsequently wetted, no further augmented tests or inspections will be performed.

• Change the frequency of trip testing each deluge valve and testing of spray/sprinkler nozzle discharge patterns from every 3 years to every refueling cycle.

• If coating failure is found during the inspection of the fire water storage tanks, perform the following additional inspections as needed: 1) adhesion testing, 2)random dry film thickness measurements, 3) spot wet sponge tests, 4)nondestructive ultrasonic readings to evaluate the wall thickness, 5) ultrasonic testing for metal loss of the tank bottom, or 6) bottom seams vacuum-box tests.

• Remove foreign material if found during pipe inspections.

• Perform main drain tests of a representative sample of 20 percent of the main drains annually.

• Inspect wet pipe suppression systems every 5 years consistent with the commitment criteria.

• Revise the implementation procedure and calculation for changing test and inspection frequencies associated with the NFPA 805 license amendment to:

o Use EPRI Report 1006756, Fire Protection Equipment Surveillance Optimization and Maintenance Guide, to adjust test and inspection frequencies.

o Ony use data in the analysis obtained earlier than 5 years prior to the period of extended operation.

o Use a minimum sample size consistent with EPRI Report 1006756, section 11.2 to modify test and inspection frequencies.

• EPRI Report 1006756 would not be used to modify fire water storage tank inspections/tests, underground flow tests, and inspections of normally dry but periodically wetted piping that will not drain due to its configuration.

Commitment 39 specified:

Enhance the GAP analysis of LRA tables 2.3.3-20 and 3.3.20 was provided to the NRC to between the existing and NFPA 805 post-transition changes.

The inspectors reviewed the aging management program basis documents, implementing procedures, completed work orders and surveillances satisfying the testing and examination requirements for the program, plant operating experience, and corrective action documents. The inspectors interviewed plant personnel and walked down fire water system equipment, including the fire pumps and jockey pumps, fire water storage tanks, fire water deluge system, fire brigade hoses, sprinkler systems in the turbine building, transformer deluge sprinklers, and associated piping and valves.

The inspectors verified that procedure APA-ZZ-00700, appendix A, Fire Water Aging Management Program, incorporated several facets of commitment 10, specifically:

sprinkler testing, sprinkler head testing, hydrant flow testing, hydrostatic testing of fire brigade hoses, non-intrusive pipe wall thickness testing, inspections of nondraining, normally dry, fire protection piping, fire water storage tank inspections, deluge valve trip testing, spray system discharge pattern test, main drain tests, fire suppression system inspections, fire water test trending, obstruction investigations, fire water aging management program inspection frequency revisions, and EPRI Report 1006756. The inspectors determined that the fire protection system engineer trended annual flow tests through review of trending reports and interviews.

The inspectors verified that the licensee coated the inside of the firewater storage tank. The inspectors determined that the licensee repaired the interior tank coatings when they identified loss of coating inside the tanks. Similarly, the inspectors determined that the licensee performed adhesion testing, measured dry film thickness, performed wet sponge testing, performed nondestructive ultrasonic testing for metal loss, and tested vacuum-box for pitting or corrosion near the seam after they found paint flaking off on the inside of one of the fire water storage tanks. The inspectors determined that the licensee inspected the bottom of the fire water storage tanks to confirm there were no voids present.

The inspectors determined that the licensee started planning for the 50-year sprinkler testing and/or replacement. The inspectors determined the licensee modified the slope of sprinkler systems to ensure water drained as required using their design change and work order process. The inspectors verified that the licensee developed procedure OSP-KC-03005, Main Drain Testing to perform main drain testing and scheduled preventative maintenance tasks to perform the testing.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of significance associated with the aging management program.

(12)19.1.15 Aboveground Metallic Tanks (XI.M29) and Commitment 11 This new program manages cracking and loss of material for the condensate storage tank (CST) and the refueling water storage tank (RWST). Originally, the license renewal application included the two fire water storage tanks, which are exposed to outdoor air and supported on concrete foundations, in this aging management program; however, the licensee moved the aging management of these tanks to the fire water aging management program (section 19.1.14). This program requires that the licensee inspect the insulation covering the CST and RWST for damage, conduct thickness measurements of the walls of tanks when insulation has not been opportunistically removed, and measure the thickness of the bottom of the tanks. This program required no enhancements or exceptions.

Commitment 11 specified:

Implement the Aboveground Metallic Tanks Program as described in LRA section B2.1.15.

The inspectors reviewed the aging management program basis document, implementing procedures, nondestructive evaluation reports, insulation/jacketing corrective action records, completed work orders, and commitment closure documents. In addition the inspectors interviewed the maintenance personnel, program owner, and walked down the accessible portions of the CST to ensure the aluminum jacket coating repairs were acceptable.

The inspectors verified that procedure EDP-ZZ-01180, Aboveground Metallic Tanks Program, implemented the commitment.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(13)19.1.16 Fuel Oil Chemistry (XI.M30) and Commitment 12 This existing monitoring program manages aging caused by water accumulation, microbiological organisms, transport of corrosion product, sludge, or particulates to components from tanks. The components managed include tanks, piping, valves, flame arrestors, strainers, sight gauges, instrument tubing, flexible connectors, and other component types with a fuel oil environment. The licensee enhanced the program to manage the age-related effects on coatings/linings that are applied to the internal surfaces of components regularly exposed to an environment of fuel oil.

The systems in the scope of this AMP include:

• Emergency Diesel Engine Fuel Oil Storage and Transferring System (JE)

• Fire Protection System (KC)

• Standby Diesel Generator Engine System (KJ)

• EOF and TSC Diesels, Security Building/System (UB)

• Alternate Emergency Power System (AEPS)

Commitment 12 specified:

Remove the blisters in the coating, inspect the base metal for aging, and repair the coating in the train A emergency diesel generator fuel oil storage tank.

Enhance the program procedures to include for the listed fuel oil storage tanks the following:

• Periodic removal of the water.

• Addition of biocide if testing indicates biological activity or evidence of corrosion.

• Draining, cleaning, and inspection once every 10 years after entering the period of extended operation.

• Determination of water and sediment in the periodic sampling.

• Determination of particulate concentrations in the periodic sampling.

• Include a determination of microbial activity concentrations in the periodic sampling.

• Receipt sampling of fuel oil for water and sediment prior to introduction.

• Volumetric examination if degradation is observed during the visual inspection performed once every 10 years after entering the period of extended operation.

• Volumetric examination on the external surface at least once every 10 years after entering the period of extended operation.

• Quarterly trending for water, biological activity, and particulate concentrations.

• Immediately remove accumulated water when discovered.

• Perform periodic visual inspections on all accessible internal surface coatings once every 10 years after entering the period of extended operation. If coatings with blisters, peeling, delamination, or rusting that has been determined not to require remediation are inspected on a 4-year frequency.

For peeling, delamination and blisters determined to not meet the acceptance criteria and that will not be repaired, replaced, or removed, physical testing is performed where physically possible (i.e., sufficient room to conduct testing).

Testing consists of destructive or nondestructive adhesion testing using in accordance with the listed standards by qualified coating inspectors.

The inspectors reviewed the aging management program basis document, nondestructive evaluation reports, coating corrective action records, completed work orders, and commitment closure documents. The inspectors verified that the licensee samples for water, sediments, particulates, and other chemical impurities on a regular basis and resolves issues if they are found, including water removal. The inspectors verified that the licensee used an RG 1.54 qualified coatings engineers to inspect the tanks when they were cleaned. The inspectors verified that the licensee completed the baseline inspections of the fuel oil storage tanks required by the license renewal commitments.

This inspectors reviewed procedure CSP-ZZ-07350, Diesel Fuel Oil Testing Program, procedure CTP-JE-01230, Diesel Fuel Oil Sampling, procedure CTP-JE-01235, Diesel Fuel Oil Skid Sampling, Chemical Addition, procedure ETP-ZZ-03050, Aging Management of Loss of Coating or Lining Integrity for Internal coatings, procedure CDP-ZZ-00110, Chemistry Data Trending Program, procedure MSM-KJ-QT001, 10 Year Emergency Diesel Generator Fuel Oil Storage Tank Cleaning, and technical specification surveillance requirement 3.8.3 results.

These programs and procedures, among others, satisfied the requirements of commitment 12.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(14)19.1.17 Reactor Vessel Surveillance (XI.M31) and Commitment 13 This existing surveillance and testing program manages (monitors) loss of fracture toughness for the reactor vessel caused by exposure to neutron fluence as the reactor ages. The licensee removed and tested surveillance capsules containing reactor vessel steel specimens of the limiting beltline material; and associated weld metal and weld heat affected zone metal. The program extends the scope of 10 CFR 50, appendix H, Reactor Vessel Material Surveillance Program Requirements, to provide sufficient data for monitoring irradiation embrittlement at the end of the period of extended operation and determines the need for operating restrictions on the inlet temperature, neutron spectrum, and neutron flux.

Commitment 13 specified:

Enhance this program to:

• Determine the vessel fluence by ex-vessel dosimetry, following withdrawal of the final capsule.

• Require that pulled and tested surveillance capsules are placed in storage for future reconstitution or reinsertion unless given NRC approval to discard.

• Require the design change process to evaluate the impact of plant operation changes on reactor vessel embrittlement.

The inspectors reviewed the aging management program basis document, implementing procedures, capsule evaluations, and engineering evaluations. The inspectors determined that the licensee removed and tested five of the six reactor vessel coupons at the end of cycles 1, 4, 8, 10, and 20. The licensee removed the last coupons (standby Z capsule) after cycle 21 with 71 effective full power years (EFPY) of exposure and placed it into the spent fuel pool for reinsertion into the reactor vessel, if needed.

In 2014, after cycle 20, the licensee installed the ex-vessel neutron dosimetry so that the exposure overlapped that of the final year of the Z in-vessel capsules. After one cycle of exposure, the licensee removed and analyzed three ex-vessel neutron dosimeter chains and reinstalled new ex-vessel neutron dosimetry. The licensee installed the ex-vessel neutron dosimetry to comply with 10 CFR 50, appendix H and to allow for confirmatory measurements of neutron fluence to ensure the actual reflect the analyzed. The licensee established a preventive maintenance task to withdraw and analyze the ex-vessel neutron dosimeters every five cycles. The next withdrawal will occur at the end of cycle 27.

Once the licensee receives the evaluation of the ex-vessel neutron dosimetry, they will confirm that the actual fluence matches the predicted fluence and adjust the following parameters, if needed: the adjusted reference temperature, the pressurized thermal shock parameters, the cold-overpressure mitigation setpoint, and the pressure-temperature curves.

The inspectors verified that the licensee added a requirement in the design attributes table of procedure EDP-ZZ-04600, Engineering Change Control, revision 20, to consider reduced cold leg temperatures or increased neutron fluence on reactor vessel embrittlement.

The inspectors determined that the licensee was operating in accordance with pressure temperature heat up and cool down curves and cold-overpressure mitigation system setpoints through 35 EFPY, which would occur after 40 calendar years of operation. The inspectors determined that the licensee had draft pressure temperature curves that would allow operation through the period of extended operation (54 EFPY). Once the licensee updates their pressure temperature limit curve, they will submit their pressure temperature limits report as required by technical specification 5.6.6. The licensee anticipates updating their pressure temperature limits report in October 2024 prior to entering the period of extended operation.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(15)19.1.18 One-Time Inspection (XI.M32) and Commitment 14 This new program manages loss of material, cracking, and reduction of heat transfer.

This program verifies system-wide effectiveness of other aging management programs using one-time inspection activities that verify unacceptable aging effects are not occurring. This program addresses and verifies the effectiveness of the water chemistry, fuel oil chemistry and lubricating analysis aging management programs.

This program required no enhancements or exceptions.

Commitment 14 specified:

Implement the One-Time Inspection program as described in LRA section B2.1.18.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors concluded that the station's implementing procedures appropriately implemented the one-time inspection activities and associated commitment 14.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(16)19.1.19 Selective Leaching (XI.M33) and Commitment 15 This new program manages loss of material in components caused by selective leaching for gray cast iron and copper alloy with greater than 15 percent zinc that are exposed to treated water, raw water, wastewater, or groundwater environments and require aging management. The licensee had no copper alloy components with greater than eight percent aluminum. Components within the program scope include heat exchanger components, piping components, valve bodies and bonnets, pump casings, tanks, and strainers. This program required no enhancements or exceptions.

Commitment 15 specified:

Implement the selective leaching program as described in final safety analysis report, as modified by LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations.

The inspectors reviewed the aging management program basis document, implementing procedures, and inspection reports. The inspectors reviewed the sample selection process, the identified material and environment combinations, and the inspection results. The inspectors verified that the licensee appropriately selected 20 percent up to a maximum of 25 samples for each material and environment combination. The licensee used x-ray fluorescence to ensure that the copper components selected contained greater than 15 percent zinc and would be a valid sample prior to performing the mechanical hardness test.

The inspectors identified no concerns with the licensees evaluation of the applicability of LR-ISG-2015-01 to their selective leaching program, as documented in Condition Report 201600900. The inspectors determined that the licensee destructively examined a gray cast iron pump casing and a copper alloy valve. This examination determined that selective leaching was present in both components. In addition, from the 68 total samples analyzed from all material environment combinations, the licensee identified selective leaching in additional 7 components.

Based on these indications, the licensee concluded in Condition Report 202401576 that selective leaching required periodic management on their site. The licensee-initiated work orders to remove and replace the valves, then destructively examine the components to inform how to implement their periodic selective leaching program.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(17)19.1.20 One-Time Inspection of ASME Code Class 1 Small-Bore Piping (XI.M35)and Commitment 16 This new program manages cracking of ASME Code Class 1 piping less than four inches nominal pipe size (NPS 4) and greater than or equal to one-inch nominal pipe size (NPS 1). This program included ultrasonic testing examinations conducted in accordance with ASME section XI with acceptance criteria from paragraph IWB-3000 for butt welds, with at least 25 butt welds included in the examination population. The program also included volumetric examination of socket welds to identify potential cracking. The licensee selected eight small-bore Class 1 socket welds for examination, which represented 10 percent of the population. The licensee used the ASME Code Edition consistent with the provisions of 10 CFR 50.55a during the 10-year period prior to the period of extended operation (fourth interval). This program required no enhancements or exceptions.

Commitment 16 specified:

Implement the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program as described in LRA section B2.1.20.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors determined that the licensee established implementing procedures that appropriately conducted the required inspections and had adequately implemented this program and associated commitment 16.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(18)19.1.21 External Surfaces Monitoring of Mechanical Components (XI.M36) and Commitment 17 This new program manages corrosion and material wastage (loss of material), wear (loss of material), leakage from or onto external surfaces (loss of material), worn, flaking, or oxide-coated surfaces (loss of material), evidence of insulation damage or wetting, and degradation of coatings, including cracking, flaking, blistering, peeling, rusting, or physical damage. The licensee performed visual inspection of external surfaces of in-scope mechanical components and monitors external surfaces of metallic components for systems within the scope of license renewal for loss of material and leakage. This program required no enhancements or exceptions.

Commitment 17 specified:

Implement the External Surfaces Monitoring of Mechanical Components Program as described in LRA section B2.1.21.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors concluded that the station's implementing procedures appropriately implemented the external surface visual inspections and associated commitment 17.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(19)19.1.23 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (XI.M38) and Commitment 18 This new program manages cracking, loss of material, hardening and loss of strength.

The program also manages loss of coating integrity on components with an internal coating. The licensee inspects internal surfaces of metallic piping, piping components, piping elements, ducting, heat exchanger components, polymeric and elastomeric components, and other components that are exposed to plant indoor air, ventilation atmosphere, atmosphere/weather, condensation, borated water leakage, diesel exhaust, lubricating oil, fuel oil, and water system environment not managed by the open-cycle cooling water system, closed treated water system, fire water system, and water chemistry aging management programs. This program required no enhancements or exceptions.

Commitment 18 specified:

Implement the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program as described in FSAR section 19.1.23, as modified by LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors concluded that the station's implementing procedures appropriately implemented the internal surface inspection activities and associated commitment 18.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(20)19.1.24 Lubricating Oil Analysis (XI.M39) and Commitment 19 This existing program manages loss of material caused by corrosion or reduction in heat transfer caused by fouling. The licensee implements activities that ensure lubricating oil contaminants (primarily water and particulates) remain within acceptable limits, thereby preserving an environment that is not conducive to loss of material or reduction of heat transfer. Components within the scope of the program include piping, piping components, and piping elements; heat exchanger tubes; reactor coolant pump elements; the chemical and volume control system chiller; and any other plant components subject to aging management review that are exposed to an environment of lubricating oil (including non-water-based hydraulic oils).

Commitment 19 specified:

Enhance the ASME section XI, Lubricating Oil Analysis Program procedures to:

• Indicate that lubricating oil contaminants are maintained within acceptable limits, thereby preserving an environment that is not conducive to loss of material or reduction of heat transfer.

• State the testing standards for water content and particle count.

• State that phase separated water in any amount is not acceptable.

The inspectors reviewed the aging management basis document, implementing procedures, interviewed the program owner and walked down the lubricating oil storage areas of the plant.

The inspectors reviewed specific documents that implemented the requirements in commitment 19. This review included procedure APA-ZZ-00330, Preventive Maintenance Program, and program document MDP-ZZ-L0001, Lubrication Program. During a tour of the lubricating oil storage room, the inspectors ensured that the licensee maintained appropriate storage, cleanliness, expiration dates, separation, and labeling requirements of the program. The inspectors determined procedure EDP-ZZ-01126, Lubrication Predictive Maintenance Program, included the water content standards prescribed by ASTM D6304 standards and particle counts prescribed by ISO 4406 standards. Additionally, the inspectors confirmed that the procedure did not allow any phase separated water, in any amount. Finally, the inspectors confirmed that the procedure contained appropriate limits for lubrication oil contaminants, and the corrective action program is utilized for any discrepancies.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(21)19.1.26 ASME Section XI, Subsection IWE (XI.S1) and Commitment 21 This existing program manages cracking, loss of material, loss of sealing, loss of preload, and loss of leak tightness by providing aging management of the steel liner of the concrete containment building, including the containment liner plate and its integral attachments, containment hatches and airlocks, and pressure-retaining bolting. IWE inspections are performed to identify and manage any containment liner aging effects that could result in loss of intended function. The program is supplemented with the applicable requirements of 10 CFR 50.55a(b)(2)(ix). This program required two enhancements and no exceptions.

Commitment 21 specified:

Enhance this program to:

• Specify that when replacing bolts, the bolting material, installation torque or tension, and use of lubricants and sealants are in accordance with the guidelines of EPRI NP 5769, EPRI TR 104213, and the additional recommendations of NUREG-1339.

• Perform additional surface examinations (or other applicable technique) of a representative sample of stainless steel penetration sleeves, dissimilar metal welds, bellows, and steel components that are subject to cyclic loading for cracking, unless appendix J testing is adequate to identify cracking.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors concluded that the station's implementing procedures are adequate to implement the required inspection activities, and that this program and associated commitment 21 have been adequately implemented.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(22)19.1.27 ASME Section XI, Subsection IWL (XI.S2) and Commitment 40 This existing program manages: cracking, loss of bond and loss of material (spalling, scaling), increase in porosity and permeability (spalling, scaling), and cracking. The licensee performed periodic visual inspections of reinforced concrete and unbonded post-tensioning systems associated with the reactor containment building. Inspection methods specified in IWL-2500 include visual examination supplemented by testing.

The licensee tested the tendons for yield strength, ultimate tensile strength, and elongation in selected sample tendons. The licensee analyzed the tendon corrosion protection medium (grease) for alkalinity, water content, and soluble ion concentrations. The testing of the tendons is discussed in greater detail in section 19.2.3 of this report Commitment 40 specified:

Enhance the ASME Section XI, Subsection IWL Program to specify that acceptability of concrete surfaces is based on the evaluation criteria provided in ACI 349.3R, Evaluation of Existing Nuclear Safety-Related Concrete Structures.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors noted that, to meet commitment 40, the licensee incorporated references to ACI 349.3R evaluation criteria into station procedure ESP-ZZ-01012, Containment Post-Tensioning System Inspection, as well as specification C-1003, Specification for Inservice Inspection of the Containment Building Post-Tensioning System and Exterior Concrete Shell.

The inspectors determined procedure ESP-ZZ-01012 implemented both the exterior surface inspection of the concrete containment building and the testing of the tendons. The inspectors reviewed documentation of the most recent performance of both activities, which were documented in Jobs 17504654 and 15511748, respectively. The inspectors noted that Job 17504654 (Walk Down Reactor Building Exterior) included guidance to perform the activity in accordance with station procedure ESP-ZZ-01013, Callaway Structures Inspection Program. The inspectors verified that procedure ESP-ZZ-01013, appendix D, Quantitative Categorization Guidelines for License Renewal Implementation, did reference ACI 349.3R evaluation criteria; however, the implementing work order for the containment building exterior concrete surface inspection did not reference procedure ESP-ZZ-01012, which the licensee had credited for both: a) implementing the containment exterior walkdown inspection program requirements and b) incorporating the content specified in commitment 40 into the station's IWL program. The licensee entered this issue into the corrective action program as CR 202402053 because the implementing work order did not have a clear nexus to the procedure that implemented the commitment. The inspectors concluded that the licensee had implemented commitment 40 through incorporation into procedure ESP-ZZ-01013.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(23)19.1.28 ASME Section XI, Subsection IWF (XI.S3) and Commitment 22 This existing program manages loss of material, cracking, fatigue, loss of preload, and loss of mechanical function. This program includes supports of Class 1, 2, and 3 components and subassemblies that includes support members, structural bolting, high strength structural bolting, support anchorage to the building structure, accessible sliding surfaces, constant and variable load spring hangers, guides, stops, and vibration isolation elements.

Commitment 22 specified:

Enhance the procedures to specify that whenever replacement of bolting is required, bolting material, installation torque or tension, and use of lubricants and sealants are in accordance with the applicable EPRI guidelines, ASTM standards, American Institute of Steel Construction specifications, and NUREG recommendations to prevent or mitigate degradation and failure of safety-related bolting due to stress corrosion cracking (SCC). Specifically, if ASTM A325, ASTM F1852, and/or ASTM A490 bolts are used, the preventive actions as discussed in Section 2 of the Research Council for Structural Connections, Specification for Structural Joints Using ASTM A325 or A490 Bolts, will be followed.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection and maintenance activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors concluded that the station's implementing procedures are adequate to implement the required inspection activities, and that this program and associated commitment 22 have been adequately implemented.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(24)19.1.29 10 CFR Part 50, Appendix J (XI.S4)

This existing program monitors leakage rates through the containment pressure boundary, including the penetrations and access openings, to detect degradation of the containment pressure boundary. Containment leak rate tests are performed to assure that leakage through the primary containment as well as systems and components penetrating primary containment do not exceed allowable leakage limits specified in the technical specifications. These components include containment isolation valves/flanges and containment penetrations. This program required no enhancements or exceptions.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed testing activities, and corrective action program evaluation of related issues. The inspectors concluded that the station's implementing procedures are adequate to implement the required inspection activities, and that this program has been adequately implemented.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(25)19.1.30 Masonry Walls (XI.S5)

This existing program, implemented as part of the structures monitoring program, manages cracking of masonry walls. This program required no enhancements or exceptions and incorporates the guidance provided in Bulletin 80-11, Masonry Wall Design and Information Notice 87-67, Lessons Learned from Regional Inspections of Licensee Actions in Response to NRC IE Bulletin 80-11. This program required no enhancements or exceptions.

The inspectors reviewed the aging management program basis document, implementing procedures, work orders, and completed inspection results. The inspectors interviewed the program owner and walked down selected masonry block walls in the control building, intake structure, and auxiliary building. The inspectors selected a sample of walls to confirm the licensee had appropriately reinforced the walls as required to withstand a seismic event. The inspectors confirmed that the licensee had included specific masonry wall inspection acceptance criteria in procedure ESP-ZZ-01013, appendix D, Quantitative Categorization Guidelines for License Renewal Implementation, revision 0.

Based on the review of the documents and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance associated with this aging management program.

(26)19.1.31 Structures Monitoring (XI.S6) and Commitments 23 and 45 This existing inspection and monitoring program, which required enhancement, manages the effects of aging for concrete elements, structural steel, roof systems, masonry walls and metal siding, non ASME mechanical supports, and electrical supports. The licensee included the required inspections of their masonry walls and water control structures aging management programs as part of this program. The program manages the following aging effects for in-scope structures and structural elements: concrete cracking and spalling, cracking and distortion, cracking with loss of material, cracking with loss of bond or loss of material, increase in porosity and permeability, loss of strength, loss of material, loss of mechanical function, loss of sealing, and reduction in concrete anchor capacity.

This program implemented the requirements of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, consistent with guidance of NUMARC 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, revision 2 and regulatory guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, revision 2.

Commitment 23 specified:

Enhance the program procedures to:

• Include the main access facility, the nitrogen storage tank foundation and pipe trench, the alternate emergency power system diesel generator enclosures, switch house, and transformer foundations, and the in-scope reinforced concrete structures under the turbine building and in the yard that provide a return flow path for the circulating water system.

• Ensure when replacing bolting that bolting material, installation torque or tension, and use of lubricants and sealants meet the listed industry guidelines.

• Require that storage of lubricants and sealants meet industry standards.

• Require inspections of penetrations, transmission towers, electrical conduits, raceways, cable trays, electrical cabinets, or enclosures, and anchorages.

• Require monitoring groundwater for pH, chlorides, and sulfates every 5 years.

• Require inspector qualifications in accordance with ACI 349.3R.

• Develop quantitative acceptance criteria and critical parameters for monitoring degradation that meets the three-tier quantitative evaluation criteria recommended in ACI 349.3R.

• Incorporate applicable industry codes, standards, and guidelines for acceptance criteria.

• Require that an engineer evaluate degradation of seismic isolation gaps, obstructions of these gaps, or questionable material in these gaps.

Commitment 45 specified:

Enhance the regulatory guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, program procedures to include the concrete structures in the turbine building that provide a flow path for the circulating water system in the scope of the program.

The inspectors reviewed the aging management program basis document, implementing procedures, work orders, and completed inspection results. The inspectors interviewed the program owner and walked down areas of the plant reviewing the condition of structures and supports throughout the plant. The inspectors verified that the licensee included all the commitment 23 requirements in several steps in procedure ESP-ZZ-01013, Callaway Structures Inspection Program, revision 11. Also, the licensee, generally, included the additional structures required in item 1 to procedure ESP-ZZ-01013, appendix A, Callaway Structures List; and the quantitative acceptance criteria and industry standards in items 7 and 8 in procedure ESP-ZZ-01013, appendix D, Quantitative Categorization Guidelines for License Renewal Implementation.

During review of the onsite structures, the inspectors identified that the licensee had not monitored the hardened condensate storage tank nor the concrete tunnels (also known as vaults) below the turbine building that provided a return path for service water. The inspectors documented the details as an observation, which is documented in the Inspection Results section in this report.

Because the licensee had not performed an inspection of the concrete vault structure in the turbine building that provided a flow path for the circulating water system, commitment 45 and corresponding aging management program remain open and will be reviewed at a future date. Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(27)19.1.32 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants (XI.S7)

This existing program, implemented as part of the structures monitoring program, manages the following aging effects: cracking; loss of bond; and loss of material (spalling, scaling); increase in porosity and permeability; loss of strength; loss of material; and loss of form. Structures within the scope for license renewal aging management include the essential service water supply lines yard vault, essential service water pumphouse and submerged structures, ultimate heat sink retention pond, ultimate heat sink cooling tower and associated submerged discharge structures, and structural steel and structural bolting associated with water-control structures. This program required no enhancements or exceptions.

The inspectors reviewed the aging management program basis document, implementing procedures, surveillances, and completed preventive maintenance tasks. The license implemented activities related to clearing brush, removing algae, underwater inspections, cleaning of the ultimate heat sink, and verifying that the ultimate heat sink retains its form.

During discussions related to the sounding of the ultimate heat sink required by the updated final safety analysis report and regulatory guide 1.127, revision 1, the inspectors determined that the location for the last two soundings in 2019 and 2023 had been performed incorrectly. The inspectors documented the details as an observation, which is documented in the Inspection Results section in this report.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(28)19.1.33 Protective Coating and Monitoring and Maintenance Program (XI.S8)and Commitment 24 This existing program was enhanced and monitors the loss of coating integrity for Service Level I coatings inside containment so that the intended functions of post-accident safety systems that rely on water recycled through the containment sump/drain system are maintained.

Commitment 24 specified:

Enhance the program and procedures to specify:

• Parameters monitored or inspected to include any visible defects, such as blistering, cracking, flaking, peeling, rusting, and physical damage.

• Inspection frequencies, personnel qualifications, inspection plans, inspection methods, and inspection equipment that meet the requirements of ASTM D 5163-08.

• Pre-inspection review of the previous two monitoring reports to prioritize repair areas as either needing repair during the same outage or as postponed to future outages.

• Characterization, documentation, and testing consistent with industry standards and to specify an evaluation of the inspection reports by the responsible coating evaluation specialist.

• Inspection reports prioritize repair areas as either needing repair during the same outage or as postponed to future outages, but under surveillance in the interim period.

The inspectors reviewed procedure EDP-ZZ-03000, Containment Building Coatings.

This procedure, in conjunction with the corrective action procedure, implement commitment 24.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. Additionally, the inspectors reviewed the past results of the containment coatings inspection, as well as the ASTM qualifications of the examiners. The inspectors concluded that the station's implementing procedures are adequate to implement the required inspection activities, and that this program and associated commitment 24 have been adequately implemented.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(29)19.1.34 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program (XI.E1) and Commitment 25 This existing program monitors the loss of coating integrity for Service Level I coatings inside containment so that the intended functions of post-accident safety systems that rely on water recycled through the containment sump/drain system are maintained.

Commitment 24 specified:

Enhance the program procedures to specify:

• Parameters monitored or inspected to include any visible defects, such as blistering, cracking, flaking, peeling, rusting, and physical damage.

• Inspection frequencies, personnel qualifications, inspection plans, inspection methods, and inspection equipment that meet the requirements of ASTM D 5163-08.

• Pre-inspection review of the previous two monitoring reports to prioritize repair areas as either needing repair during the same outage or as postponed to future outages.

• Characterization, documentation, and testing consistent with industry standards and to specify an evaluation of the inspection reports by the responsible coating evaluation specialist.

• Inspection reports prioritize repair areas as either needing repair during the same outage or as postponed to future outages, but under surveillance in the interim period.

The inspectors reviewed procedure EDP-ZZ-03000, Containment Building Coatings.

This procedure, in conjunction with the corrective action procedure, implement commitment 24.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. Additionally, the inspectors reviewed the past results of the containment coatings inspection, as well as the ASTM qualifications of the examiners. The inspectors concluded that the station's implementing procedures are adequate to implement the required inspection activities, and that this program and associated commitment 24 have been adequately implemented.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(30)19.1.35 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits (XI.E2) and Commitment 26 This existing monitoring program manages the insulation resistance to ensure that cables and connections used in sensitive instrumentation circuits with high voltage low-level current signals within the ex-core neutron monitoring system remain capable of performing their intended functions. The in-scope components included intermediate, source, gamma metrics, and power range detector cabling.

Commitment 26 specified:

Enhance the program procedures to:

• Identify the scope of cables requiring aging management.

• Require engineering review of instrument surveillance results, or perform direct cable testing, every 10 years.

• Initiate corrective actions when test results do not meet acceptance criteria and perform an engineering evaluation. Determine whether to increase the frequency of the review of instrument surveillance results or the cable testing.

The inspectors reviewed the license renewal program basis documents, completed work orders, 10 CFR 50.49 equipment tracking documents, cable routing and plant drawings, and corrective action documents.

The inspectors verified that procedure EDP-ZZ-00701, appendix A, License Renewal In-scope Cables, table 2 identified the required cabling for testing. The inspectors verified the licensee developed procedure ESP-SE-0XIE2, Testing of the Excore Nuclear Instrumentation Cables to Support License Extension Requirement XI.E2, revision 0, to perform direct cable resistance testing every 10 years. The inspectors determined that the licensee performed baseline insulation testing of their instrumentation cables. Procedure EDP-ZZ-07001 required that the licensee document unacceptable results in their corrective action program and perform an engineering evaluation. The inspectors determined the licensee appropriately dispositioned their results using the corrective action program.

Based on the review of the procedures, work orders, and discussions with licensee personnel, the inspectors did not identify any findings or violations associated with this aging management program.

(31)19.1.36 Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements Program (XI.E3) and Commitment 27 This existing program manages reduced insulation resistance leading to electrical failure of in-scope non-EQ inaccessible power cables (greater than or equal to 400 volts) exposed to wetting or submergence caused by significant moisture. Significant moisture is defined as periodic exposures to moisture that last more than a few days.

The licensee inspected and tested the cables listed in procedure EDP-ZZ-07001, Cable Management Program, appendix A, License Renewal In-scope Cables, table 3, XI.E3 - Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

Commitment 27 specified:

Enhance the program procedures to:

• Identify the in-scope power cables (greater than or equal to 400 volts),manholes, pits, and duct banks.

• Include periodic inspection of manholes, pits, and duct banks, to confirm cables are not submerged or immersed in water, cable splices and supports remain intact, and dewatering systems and alarms operate properly.

• Require annual inspections and inspections after event-driven occurrences (e.g., heavy rain or flooding).

• Test in-scope power at least once every 6 years or 4 refueling outages.

Acceptance criteria for cable testing will be defined prior to each test. Require an engineering evaluation when the test or inspection acceptance criteria are not met.

• Compare test results to previous test results to evaluate the rate of cable degradation.

• Confirm cables are not submerged or immersed in water, cables, splices, and cable support structures are intact, and dewatering/drainage systems (i.e.,

sump pumps) and associated alarms operate properly.

The inspectors reviewed license renewal program basis documents, implementing procedures, corrective action program documents, completed work orders, and cable testing. The inspectors interviewed the program owner. The licensee managed aging effects through daily indication walkdowns, annual cable vault inspections with thermography, and tan delta testing. The inspectors completed multiple walkdowns of the protective area for Manhole MH59-31 with the program owner. The inspectors used thermography and confirmed no cable damage existed for the cables inside Manhole MH59-31. From an inspection during inclement weather, the inspectors determined sump pumps functioned properly and prevented water from submerging the cables.

The inspectors identified during the walkdowns of the manhole dewatering system that the sump pumps operated more than expected because of residual water being in the manhole; however, the water level remained several feet below the cables.

Based on the review of the procedures, work orders, and discussions with licensee personnel, the inspectors did not identify any findings or violations associated with this aging management program.

(32)19.1.37 Electrical Cable Connections NOT Subject To 10 CFR 50.49 Environmental Qualification Requirements Inspection Program (XI.E6) and Commitment 28 This new one-time program manages increased resistance of electrical connections caused by thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, or oxidation. The licensee used thermography to test the connections selected for their representative sample. The sample included various voltages and current in multiple plant locations. This program required no enhancements or exceptions.

Commitment 28 specified:

Implement the Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program as described in LRA Section B2.1.37.

The inspectors reviewed the sampling plan, aging management program basis document, completed work orders, and corrective action documents. The inspectors discussed the results of the inspections with the program owner. Procedure EDP-ZZ-07001, Cable Management Program, prescribed implementation of the one-time inspections. The inspectors verified that the licensee used infrared thermography to measure for heat generated as a result of increased resistance at the connections.

The licensee selected a sample that included various voltage levels (medium and low voltage), circuit loading (high loading), connection type, and location (high temperature, high humidity, vibration, etc.). The licensee did not identify any high resistance connections.

Based on the review of the procedures, work orders, and discussions with licensee personnel, the inspectors did not identify any findings or violations associated with this aging management program.

(33)19.1.38 Monitoring of Neutron-Absorbing Materials other than BORAFLEX (XI.M40) and Commitment 29 This new program manages reduction of neutron-absorbing capacity, changes in dimension of the Boral panel sheaths, and loss of material. The components monitored include the Boral panels in the Spent Fuel Pool. If required, corrective actions will be taken to ensure intended function as credited in the applicable Criticality Safety Analyses is maintained. This program required no enhancement or exceptions.

Commitment 29 specified:

Implement the Monitoring of Neutron-Absorbing Materials Other than Boraflex Program as described in LRA Section B2.1.38.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. In addition, the inspectors reviewed the baseline BADGER reports for determining the boral density of the neutron-absorbing materials in the spent fuel pool and found no issues. The licensee will perform subsequent inspections every 10 years in accordance with procedure ESP-KE-01018, Neutron-Absorbing Material Monitoring Program. The inspectors concluded that the station's implementing procedures are adequate to implement the required inspection activities, and that this program and associated commitment 29 have been adequately implemented.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(34)19.1.39 Metal-Enclosed Bus Program (XI.E4) and Commitment 30 This new program manages non-segregated phase metal enclosed buses including aging of electrical bus bar bolted connections, connections for flexible links (connectors between a metal enclosed bus and transformers/switchgear), bus bar insulation, bus bar insulating supports, bus enclosure assemblies (internal and external), and elastomers. The licensee inspects: 1) internal surfaces of bus enclosure assemblies are inspected for cracks, corrosion, foreign debris, excessive dust buildup, and evidence of moisture intrusion; 2) bus insulation for signs of reduced insulation resistance caused by degradation of organics/thermoplastics, as indicated by embrittlement, cracking, chipping, melting, discoloration, or swelling; 3)external portions of a bus, including gaskets and sealants, for surface cracking, crazing, scuffing, dimensional change, shrinkage, discoloration, hardening and loss of strength; and 4) external surfaces for loss of material caused by general, pitting, and crevice corrosion. This program required no enhancements or exceptions.

Commitment 30 specified:

Implement the Metal Enclosed Bus Program as described in LRA Section B2.1.39.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors interviewed the program owner. The inspectors verified procedure EDP-PB-00001, Metal Enclosed Bus, had identified the parameters and acceptance requirements for the program. The inspectors reviewed the completed work orders and resulting engineering evaluations and did not identify any issues. The inspectors determined the licensee dispositioned their results using the corrective action program.

Based on the review of the procedures, work orders, and discussions with licensee personnel, the inspectors did not identify any findings or violations associated with this aging management program.

(35)19.2.1 Fatigue Monitoring (X.M1) and Commitments 31, 36, 37, and 38 This existing program manages fatigue cracking caused by anticipated cyclic strains in metal components of the reactor coolant pressure boundary. The program ensures that actual plant experience remains bounded by the transients analyzed in the design calculations and fatigue crack growth analyses, or that corrective actions maintain the design and licensing basis. This program tracks the number of transient cycles and will track cumulative fatigue usage at monitored locations. The program tracks fatigue by one of the following:

1. The cycle counting monitoring method tracks transient event cycles affecting

the location to ensure that the numbers of transient events analyzed by the fatigue analyses are not exceeded.

2. The cycle-based fatigue monitoring method utilizes the cycle counting results

and stress intensity ranges generated with the ASME methods that use three-dimensional six component stress-tensor methods to determine the cumulative usage factor at specific locations. The licensee tracks fatigue accumulation to identify when it approaches the ASME allowable fatigue limit of 1.0.

3. The stress-based fatigue monitoring method computes a real time stress

history for a given component from data collected from plant instruments to calculate transient pressure and temperature, and the corresponding stress history at the critical location in the component. The licensee calculates the cumulative usage factor using a three-dimensional, six component stress tensor method meeting ASME requirements or will be benchmarked consistent with the NRC Regulatory Issue Summary (RIS) 2008-30.

Commitment 31 specified:

Enhance the program procedures to:

• Include fatigue usage calculations that consider the effects of the reactor water environment for sample locations with fatigue usage calculations, including environmentally assisted fatigue.

• Ensure the scope includes the fatigue crack growth analyses to support other analyses and that selection criterion remain valid by counting the transients used in the analyses.

• Require the review of the temperature and pressure transient data from the operator logs and plant instrumentation.

• Include additional transients that contribute significantly to fatigue usage.

• Include additional locations that require more detailed monitoring because of ASME Section III fatigue analyses and the reactor coolant environment.

• Project the transient count and fatigue accumulation of monitored components into the future.

• Include additional cycle count and fatigue usage action limits, which permit completion of corrective actions if the design limits are expected to be exceeded within the next three fuel cycles. This will include the hot leg surge nozzle.

• Include appropriate corrective actions to be invoked if a component approaches a cycle count or cumulative usage factor action limit or if an experienced transient exceeds the design transient definition.

• Limit the number of the most severe reactor coolant pump component cooling water temperature transients to 75 percent of design value.

• Include non-NUREG/CR-6260 locations with a U(en) greater than 1.0 for further evaluation.

• The sentinel location analysis, when refined, will be revisited to confirm bounding reactor coolant pressure boundary environmentally assisted fatigue susceptible sentinel locations are updated appropriately and remain bounded consistent with the refined analysis.

Commitment 36 specified:

Implement stress-based fatigue or cycle-based fatigue consistent with RIS 2008-30 to monitor the cumulative usage factor of the limiting location out of the pressurizer lower head, surge nozzle, and heater penetrations to accommodate the insurge-outsurge transient. The reevaluation of insurge-outsurge analysis demonstrated that this type of detailed monitoring was not necessary.

Commitment 37 specified:

Complete an evaluation to determine if there are any additional plant-specific bounding environmentally assisted fatigue locations. The supporting environmental factors, F(en), calculations will be performed in accordance with NUREG/CR-6909 or NUREG/CR-6583 for carbon and low-alloy steels, NUREG/CR-6909 or NUREG/CR-5704 for austenitic stainless steels, and NUREG/CR-6909 for nickel alloys. To determine if the pressurizer contains a limiting environmentally assisted fatigue location, the fatigue analyses will be revised to incorporate the effect of insurge-outsurge transients on the pressurizer lower head, surge nozzle, and heater well nozzles at plant-specific conditions..

Commitment 38 specified:

Limit the number of the most severe reactor coolant pump component cooling water temperature transients to 75 percent of design value to accommodate the seasonal temperature change transient in the reactor coolant pump thermal barrier flange fatigue analysis.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection and maintenance activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors concluded that the station's implementing procedures are adequate to implement the required inspection activities, and that this program and associated commitments 31, 36, 37, and 38 have been adequately implemented.

Based on the review of the procedures, work orders, and discussions with licensee personnel, the inspectors did not identify any findings or violations associated with this aging management program.

(36)19.2.2 Environmental Qualification (EQ) of Electrical Components (X.E1)

This existing aging management program is consistent with NUREG-1801, section X.E1 and includes an exception. The EQ program manages component thermal, radiation, and cyclical aging using aging evaluations based on 10 CFR 50.49 qualification methods.

The exception includes aging management of the qualified life of safety-related mechanical components located in harsh environments. The inclusion of environmentally qualified mechanical components is acceptable in that the license renewal amendment identifies the same materials, environment, and aging effects requiring management for both electrical equipment environmentally qualified under 10 CFR 50.49 and the mechanical components qualified under criterion 4 of appendix A to 10 CFR Part 50.

The inspectors verified that procedure APA-ZZ-00390 Environmental and Seismic Qualification of Safety-Related Equipment, was updated to address aging management. The inspectors verified that all components that were required to be replaced before the period of extended operation have already been replaced. The inspectors reviewed the components that are required to be replaced before the 60-year date and verified there was a replacement schedule planned. The inspectors reviewed the plant qualification evaluations and did not identify any concerns. The inspectors reviewed the corrective action program for this aging management program and determined the licensee dispositioned their results.

Based on the review of the procedures, work orders, and discussions with licensee personnel, the inspectors did not identify any findings or violations associated with this aging management program.

(37)19.2.3 Concrete Containment Tendon Prestress Program (X.S1) and Commitment 32 This existing program, which is part of the ASME section XI, subsection IWL inservice inspection program, manages loss of tendon prestress consistent with the requirements of 10 CFR 50.55a(b)(2)(viii)(B). The inspectors determined that technical specification 5.5.6, Containment Tendon Surveillance Program, specified the program monitors any tendon degradation, including the effectiveness of the corrosion protection medium to ensure containment structural integrity, as specified in section XI, subsection IWL of the ASME Code. This program required enhancement to meet the requirements of the generic aging lessons learned report.

Commitment 32 specified:

Enhance the program to:

• Include random samples for the 40-, 45-, 50-, and 55-year surveillances.

• Extend the predicted lower limit lines for the vertical and hoop tendon groups to 60 years.

• Require the final report for each surveillance interval to plot the measured results against time and to include the predicted lower limit, minimum required value, and trend lines.

• Require a regression analysis consistent with the requirements of Information Notice 99-10, Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments, revision 1, attachment 3, Comparison and Trending of Prestressing Forces.

The inspectors reviewed the aging management program basis document, calculations, specifications, aging management program implementing procedure, and completed inspection reports. Procedure ESP-ZZ-01012, Containment Post-Tensioning System Inspection, revision 10, specified that the procedure performs the tendon surveillance and concrete examinations required by ASME, section XI, subsection IWL. The inspectors determined that the procedure did not list in the references the commitments related to the containment tendons aging management program nor discuss how the licensee implemented the commitments.

The inspectors confirmed the commitments had been implemented as described in the following documents; however, the inspectors determined that none of these documents followed the licensees procedure writers guidance for referencing commitments. The inspectors identified that the failure to reference the commitments in the overarching document and failure to effectively reference commitments in calculations could potentially allow removal of the aging management requirements.

The inspectors determined that the licensee planned to address this line-of-sight issue during resolution of the issue documented in Condition Report 202402070.

Calculation AMNROLI00015-CALC-006, Callaway Surveillance Tendons for Period of Extended Operation, revision 0, determined the pre-selected random tendons for testing during the 45-, 50-, 55-, and 60-year tests, as specified in the first item for this commitment. Calculation AMNROLI00015-CALC-007, Time Limited Aging Analysis of Callaway Containment Prestressed Tendons for License Renewal (LR), revision 0, developed representative lower bound curves for both the vertical and horizontal tendons; performed a regression analysis of the measured tendon forces through year 35; and extended the force trendlines, lower bound curves and minimum required tendon force for both the vertical and horizontal tendons through 60 years.

This calculation implemented the second item for this commitment.

Specification C-1003(Q), Specification for Inservice Inspection of the Containment Building Posttensioning System & Exterior Concrete Shell, revision 15, step 1.1, specified that the regression analysis performed for the 40th year through the 60th year must be consistent with the requirements of Information Notice 99-10, which implements the fourth item in the commitment. Step 4.3.5.f requires that the measured forces be compared to the graphs contained in appendix E, Tendon Stress Relaxation Curves and Normalization Factors, which were developed in calculation AMNROLI00015-CALC-007 and implemented the third item in this commitment.

The inspectors determined that the licensee had not completed the 40-year tendon post-tensioning surveillance required by ASME section XI, subsection IWL. The licensee requested relief from the requirements by Letter ULNRC-06831, Request for Relief from Requirements of ASME BPV Code,Section XI, Subsection IWL Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01), dated October 26, 2023 [ML23299A195]. On February 26, 2024, the staff issued Letter Callaway Plant, Unit No. 1 - Regulatory Audit Plan in Support of Proposed Alternative for ASME Code,Section XI Requirements for Containment Building Inspections (EPID L-2023-LLR-0061) [ML24052A366] that identified performance of an in-office audit of the relief request from March through May 2024.

The inspectors determined that, if this one-time relief request from containment testing is approved, the licensee would slide (move forward in time) the tendons that would be tested.

Because the licensee requested a one-time relief from the testing requirements and had not received approval, the inspectors could not review the 40-year surveillance results and concluded the aging management program review was incomplete.

Consequently, this aging management program and commitment 32 remains open and will be reviewed at a future date. Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

Administrative Commitments

(38) Commitment 1 The commitment requires the licensee to enhance procedures and apply the elements of corrective actions, confirmation process, and administrative controls of the licensees quality assurance program to those nonsafety-related structures, systems and components requiring aging management.

The inspectors verified that the licensee updated procedure APA-ZZ-0500, Corrective Action Program, to account for aging management activities in their corrective action program. The inspectors verified that the corrective action process required including the words aging and aging management program identifiers, such as XI.S1 or XI.E1, so that the responsible program owners would be flagged to address any item related to their program or system.

(39) Commitment 2 This commitment specified:

Enhance the station operating experience review process and corrective action program to perform reviews of plant-specific and industry operating experience to confirm the effectiveness of the license renewal aging management programs, to determine the need for aging management programs to be enhanced or indicate the need to develop a new aging management program.

To provide additional assurance that internal and external operating experience related to aging management continues to be used effectively in aging management programs, AMPs, Callaway will enhance its operating experience program to:

• Explicitly require the review of operating experience for age related degradation.

• Establish criteria to define age-related degradation.

• Establish coding for use in identification, trending, and communications of age-related degradation.

• Require communication of significant internal age-related degradation, associated with SSCs in the scope of license renewal, to the industry.

• Require review and evaluation of external operating experience for information related to aging management, and evaluation of such information for potential improvements to aging management activities. Consider license renewal interim staff guidance (LR-ISG) documents external operating experience information.

• Provide training to those responsible for screening, evaluating, and communicating operating experience items related to aging related degradation. This training will be commensurate with their role in the process.

• Explicitly require AMP activities, criteria, and evaluations integral to the elements of the AMPs be included in the operating experience evaluation.

The inspectors verified that the licensee created procedure APA-ZZ-01400, appendix E, Operating Experience, to require the review of operating experience for age related degradation. The procedure provided guidance for sending to the industry internal operating experience and required review of external operating experience that could affect their aging management programs, including License Renewal Interim Staff Guidance. From review of condition reports, the inspectors verified that fields existed to identify when aging affects, or aging management reviews were required. The inspectors verified that the licensee performed training related to aging management for engineers commensurate with their role in the process. The inspectors verified that the licensee requires new engineers to complete aging management training in their initial qualifications.

(40) Commitment 33 This commitment specified, as additional industry and plant-specific applicable operating experience becomes available, it will be evaluated and incorporated into each new program. The new aging management programs included: Aboveground Metallic Tanks, Selective Leaching, One-time Inspection, One-time Inspection of ASME Code Class 1 Small-Bore Piping, External Surfaces Monitoring of Mechanical of Mechanical Components, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, Buried and Underground Piping and Tanks, and Monitoring of Neutron-Absorbing Materials Other than Boraflex.

The inspectors reviewed all affected programs and verified all had accounted for operating experience. The inspectors determined that the one-time inspection programs did not have an ongoing need to review operating experience since they were not ongoing programs. The inspectors observed that procedure EDP-ZZ-0119, External Surfaces Monitoring of Mechanical Components Program, should have better identification in the references that the license renewal commitment applied to the procedure. The licensee documented this in Condition Report 202402037.

The inspectors did not identify any findings or violations of more than minor significance associated with commitments 1, 2 and

INSPECTION RESULTS

Observation: Monitoring of the Hardened Condensate Storage Tank and the Concrete Circulating Water Vault 71003 During the review of procedure ESP-ZZ-01013, Callaway Structures Inspection Program, the inspectors identified that that the licensee failed to include the hardened condensate storage tank [Condition Report 202401621] in appendix A, Callaway Structures List.

Additionally, the inspectors identified that a reinforced concrete structure known as the circulating water vault, which is a structure that spans from under the turbine building and into the yard and provides a return flow path for the circulating water system had not been inspected because it was considered inaccessible [Condition Report 20242038].

The inspectors confirmed that although the hardened condensate storage tank was not in the structures list, it had been inspected. However, the licensee had not inspected the below-ground concrete circulating water vault. This vault is a 10-foot by 10-foot square section, approximately 30 feet long, with 3-foot-thick walls. The licensee appropriately recognized that the underground circulating water vault tunnel structure was credited in the fire probabilistic assessment because it makes use of the volume of water in that section, but failed to inspect this structure after they transitioned from deterministic to risk-informed fire protection requirements.

The licensee considered the below-ground concrete circulating water vault tunnel inaccessible and described that they would inspect the tunnel on demand when accessible because of personnel safety concerns. The licensee considered the essential service water intake structure, which had been inspected, as a surrogate for the underground tunnel because they had been constructed with similar concrete specifications and the structures have similar service conditions. Following additional discussions, the inspectors determined the concrete tunnel vault was accessible and the licensee had several opportunities to inspect the concrete vault since it was determined to be in scope in 2014, particularly during outages in which flow is secured in the vault to support cleaning of the circulating water-cooling tower basin. From review of drawings, a 3-feet diameter manhole access port exists near to the end of the concrete tunnel vault.

The structures monitoring program implements monitoring required by 10 CFR 50.65(a)(2).

The inspectors determined that the licensee should have inspected the concrete vault as required by 10 CFR 50.65(b)(2)(i), which requires that nonsafety related structures relied upon to mitigate accidents or transients to be monitored. The inspectors determined that the failure to perform the inspections as specified in commitment 45 prior to entering the period of extended operation is a performance deficiency for failure implement the monitoring required by 50.65(a)(2). The inspectors determined that this failure to monitor was of minor significance and had not impacted the function related to water flow as credited by the fire probabilistic assessment. The inspectors determined that there was reasonable assurance that the concrete vault was structurally sound because the licensee inspected the surrogate essential service water intake structure, which has similar concrete exposed to the same service conditions, and that surrogate did not identify any degradation. The inspectors determined that this performance deficiency was minor. The licensee documented this deficiency in Condition Report 20242039.

Observation: Ultimate Heat Sink Soundings 71003 During discussions related to the sounding of the ultimate heat sink required by the updated final safety analysis report and regulatory guide 1.127, revision 1, the inspectors determined that the location for the last two soundings in 2019 and 2023 had been performed incorrectly.

While reviewing procedure ESP-EF-03002, Ultimate Heat Sink Retention Pond In-Service Inspection, revision 7, section 7.5 guidance, the inspectors determined that the procedure provided insufficient guidance to determine the datum points nor an acceptable elevation for the water level. In other words, the procedure did not measure the silt accumulation at the same location each time, so the data was not useful in developing a trend or an indicator of when to perform cleaning. This surveillance had a 5-year performance frequency to ensure the intake and discharge for the essential service water system did not have a reduced water level caused by silting or degradation of the pond structure. However, the inspectors determined that the licensee removed silt throughout the ultimate heat sink bottom on a 4-year frequency.

During the last two surveillances, the largest depth of as-found silt recorded six and ten inches, respectively, with a range from zero to four inches being the average. The design basis conditions allow up to twelve inches of silt distributed throughout the ultimate heat sink.

Similarly, operators monitor water level at the surface each shift to ensure it remains above the required minimum level. Because the licensee cleans the silt from the ultimate heat sink more frequently than the sounding, and the licensee had sufficient water level in the ultimate heat sink, the inspectors determined that the inadequate guidance provided by procedure ESP-EF-03002 was a minor violation of regulatory requirements. The licensee documented this performance deficiency in Condition Report

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On March 21, 2024, the inspectors presented the inspection results to John Beck, Vice President Engineering, and other members of the licensee staff.

NRC closed commitments: 3, 9, 20, 41, and 42, in Inspection Report 05000483/2023010.

During this inspection, the inspectors closed the following commitments listed in the updated safety evaluation report: 1, 2, 4, 5, 6, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 33, 34, 35, 36, 37, 38, 39, 40, 43, 44, and 46.

As described in the report, the inspectors did not close the following commitments: 32 and 45.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Calculations

03-134-F

Auxiliary Building Shielding Block Walls

71003

Calculations

AMNROLI00015-

CALC-006

Callaway Surveillance Tendons for Period of Extended

Operation

71003

Calculations

AMNROLI00015-

CALC-007

Time Limited Aging Analysis of Callaway Containment

Prestressed Tendons for License Renewal (LR)

71003

Calculations

FP-CALL-327

FatiguePro4 Update Analysis of Callaway Plant Cycles and

Fatigue Usage

2/18/2023

71003

Corrective Action

Documents

CR

200200511, 200406604, 200407394, 200908855,

201301702, 201302911, 201305119, 201305264,

201306544, 201600900, 201603688, 201603730,

201604304, 201700982, 201705894, 201706428,

201803981, 201804678, 201804890, 201805431,

201806569, 201807118, 201901119, 201902231,

201902237, 201902921, 201904752, 201906878,

2001255, 202002899, 202005407, 202005496,

2005604, 202100788, 202100951, 202101386,

2103224, 202104071, 202104381, 202106289,

2200985, 202201471, 202202269, 202202323,

2202344, 202202364, 202302466, 202203825,

2204507, 202204923, 202205644, 202205795,

2206109, 202206251, 202206414, 202206455,

2206456, 202207984, 202300553, 202301145,

2302474, 202302543, 202302702, 202302955,

2303924, 202304048, 202304085, 202304127,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

2306807, 202307037, 202307432, 202307519,

2307749, 202307759, 202307890, 202308870,

2309037, 202401977

71003

Corrective Action

Documents

Resulting from

Inspection

CR

2401598, 202401601, 202401621, 202401811,

2401976, 202401977, 202401988, 202401998,

2402024, 202402035, 202402036, 202402037,

2402038, 202402039, 202402053, 202402070

71003

Drawings

1839E72

Ex-Vessel Neutron Dosimetry Housing, Clamp, & Chain Stop

71003

Drawings

8600-X-88148

Installation Details Water - Circulating Water System Piping -

Bifurcation

71003

Drawings

8600-X-88195

Piping Plan - Circulating Water System

71003

Drawings

8600-X-88196

Piping Elevations - Circulating Water System

71003

Drawings

A-2301

Auxiliary and Reactor Building Floor Plan, El 1974'-0"

71003

Drawings

A-2341

Architectural - CMU Wall Penetrations Control Bldg &

Communication Corridor

71003

Drawings

A-2360

Architectural - CMU Wall Penetrations Auxiliary Building

71003

Drawings

A-2361

Architectural - CMU Wall Penetrations Control Bldg &

Communication Corridor

71003

Drawings

A-2904

Architectural - General Masonry Details

71003

Drawings

A-2905

Architectural - General Masonry Details

71003

Drawings

C-2031, sheet 20

Civil Structural Standard Details

71003

Drawings

C-2C1910, sheet

Auxiliary Building Conc? Neat Lines & Reinforcing Wall

Elevation

71003

Drawings

C-OR4003, sheet 3

Turbine Building Reinforcing Sections & Details

71003

Drawings

C-OR4004, sheet 4

Turbine Building Reinforcing Sections & Details

71003

Drawings

M-01EA01

System Flow Diagram - Service Water

D

71003

Drawings

M-22DA01

Piping & Instrumentation Diagram - Circulating Water & Water

Box Drains System

71003

Drawings

M-22EA02

Piping & Instrumentation Diagram - Service Water System

71003

Engineering

Changes

MP 12-0029

Install Ex-Vessel Neutron Dosimetry

71003

Engineering

Changes

MP 23-0007

Engineering Change Package for Cycle 27 Core Reload

Design

71003

Engineering

CALILRT.14-

INTEGRATED LEAKAGE RATE TEST REPORT

10/12/2014

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Evaluations

R141231B

71003

Engineering

Evaluations

REP-1160-510

FINAL REPORT FOR THE 35TH YEAR TENDON

SURVEILLANCE AT CALLAWAY

71003

Engineering

Evaluations

RFR 230043

Evaluation of Cycle 27 License Renewal Program

Requirements for Reactor Internals

71003

Engineering

Evaluations

Technical Report

EP-2014-0001-01-

TR

Ameren Missouri - Callaway Energy Center FAC System

Susceptibility Evaluation (SSE)

71003

Engineering

Evaluations

Technical Report

EP-2014-0001-02-

TR

Ameren Missouri - Callaway Energy Center FAC Susceptible

Non-Modeled (SNM) Analysis

71003

Engineering

Evaluations

Technical Report

EP-2014-0001-03-

TR

Ameren Missouri - Callaway Energy Center Erosion

Susceptibility Evaluation (ESE)

71003

Miscellaneous

Raw Water Corrosion Monitoring Program Long Term Asset

Management Plan

71003

Miscellaneous

2-9350920-000

Callaway Thermal Sleeve Wear Rate Assessment

8/12/2020)

71003

Miscellaneous

2100105

Evaluation for Selective Leaching in Cast Iron Valve

11/30/2022

71003

Miscellaneous

23060165

Evaluation for Selective Leaching in Pump Casing

8/10/2023

71003

Miscellaneous

ACI 349.3R-96

Evaluation of Existing Nuclear Safety-Related Concrete

Structures

71003

Miscellaneous

AMN$ROLI~00006-

REPT-009

Electrical Cable Aging Management Adverse Localized

Environment Walkdown Report

71003

Miscellaneous

AMNROLI00019-

REPT-002

Selective Leaching Inspection Summary Report

71003

Miscellaneous

AMNROLI00019-

REPT-004

CTW Inspection Summary Report

71003

Miscellaneous

AMNROLI001-

REPT-001

Buried and Underground Piping and Tanks Review of LR-

ISG-2015-01

71003

Miscellaneous

CW-AMP-B2.1.10

Open-Cycle Cooling Water System

71003

Miscellaneous

CW-AMP-B2.1.11

Closed Treated Water Systems

71003

Miscellaneous

CW-AMP-B2.1.17

Reactor Vessel Surveillance

71003

Miscellaneous

CW-AMP-B2.1.19

Selective Leaching

71003

Miscellaneous

CW-AMP-B2.1.2

Water Chemistry

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Miscellaneous

CW-AMP-B2.1.30

Masonry Walls

71003

Miscellaneous

CW-AMP-B2.1.31

Structures Monitoring

71003

Miscellaneous

CW-AMP-B2.1.32

Regulatory Guide 1.127, Inspection of Water Control

Structures Associated with Nuclear Power Plants

71003

Miscellaneous

CW-AMP-B2.1.6

PWR Vessel Internals

71003

Miscellaneous

CW-AMP-B3.3

Concrete Containment Tendon Prestress

71003

Miscellaneous

E170.0105

Fourth Interval Inservice Inspection Program Plan

71003

Miscellaneous

Figure 14.9

Callaway Plant Pressure and Temperature Limits Report

71003

Miscellaneous

Figure 8-6

RCS Pressure-Temperature Limitations

71003

Miscellaneous

Information Notice 99-10, Attachment

Comparison and Trending of Prestressing Forces

4/13/1999

71003

Miscellaneous

LCDR 201610087

Changes to FSAR-SP Chapter 19, "License Renewal

Supplement," based on reviews per 10 CFR 54.37{b)

71003

Miscellaneous

Letter

Callaway Plant, Unit No. 1 - Regulatory Audit Plan in Support

of Proposed Alternative to ASME Code,Section XI

Requirements for Containment Building Inspections (EPID L-

23-LLR-0061)

2/26/2024

71003

Miscellaneous

LR-ISG-2013-01

Aging Management of Loss of Coating or Lining Integrity for

Internal Coatings/Linings on In-Scope Piping, Piping

Components, Heat Exchangers and Tanks

71003

Miscellaneous

LR-ISG-2015-01

Changes to Buried and Underground Piping and Tank

Recommendations

71003

Miscellaneous

LTR-REA-03-179

Callaway Energy Center Ex-Vessel Neutron Dosimetry

System Description and Safety

Evaluation Factors

71003

Miscellaneous

LTR-RIDA-12-59

Transmittal of Requested RV Internals CMTRs

3/13/2012

71003

Miscellaneous

MRP 2013-025,

MRP-227-A Applicability Guidelines for Combustion

Engineering and Westinghouse Pressurized Water Reactor

Designs

71003

Miscellaneous

MRP-191

Materials Reliability Program: Screening, Categorization, and

Ranking of Reactor Internals Components for Westinghouse

and Combustion Engineering PWR Design

71003

Miscellaneous

PQE E-057B-

600V Cross-linked Polyethylene Insulated Control and Power

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

00014P01

Cable

71003

Miscellaneous

PQE E-057CP01

600V Cross-linked Polyethylene Insulated Control and Power

Cable

71003

Miscellaneous

PQE E-21013XP01

Splice

71003

Miscellaneous

PQE J-301-

00086P01

Electrical Conduit Seal Assembly

71003

Miscellaneous

PQE J-603A-

00130P01

Solenoid Valve

71003

Miscellaneous

Regulatory Guide 1.127

Criteria and Design Features for Inspection of Water Control

Structures Associated with Nuclear Power Plants

71003

Miscellaneous

Regulatory Guide 1.35.1

Determining Prestressing Forces for Inspection of

Prestressed Concrete Containments

71003

Miscellaneous

WCAP-14040-A

Methodology Used to Develop Cold Overpressure Mitigating

System Setpoints and RCS Heatup and Cooldown Limit

Curves

71003

Miscellaneous

WCAP-18001-NP

Analysis of Capsule W from the Ameren Missouri Callaway

Unit 1 Reactor Vessel Radiation Surveillance Program

71003

Miscellaneous

WCAP-18149-P

Callaway Ex-Vessel Neutron Dosimetry As-Installed Report

71003

Miscellaneous

WCAP-18203-NP

Ex-Vessel Neutron Dosimetry Program for Callaway Cycle 21

71003

Miscellaneous

WCAP-18216-NP

Callaway Unit 1 Heatup and Cooldown Limit Curves for

Normal Operation through End of License Extension

71003

Miscellaneous

WCAP-18764-P

Callaway Unit 1 - 17X17AS Upper Internals Guide Tube

Guide Card Wear Evaluation (Spring 2022)

71003

Miscellaneous

X.E1

Environmental Qualification (EQ) of Electrical Components

71003

Miscellaneous

X.S1

Concrete Containment Tendon Prestress Aging Management

Program Notebook

71003

Miscellaneous

XI.E1

Insulation Material for Electrical Cables and Connections Not

Subject to 10 CFR 50.49 Environmental Qualification

Requirements Aging Management Program Notebook

71003

Miscellaneous

XI.E2

Insulation Material for Electrical Cables and Connections Not

Subject to 10 CFR 50.49 Environmental Qualification

Requirements Used

in Instrumentation Circuits Aging Management Program

Notebook

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Miscellaneous

XI.E3

Inaccessible Power Cables Not subject to 10 CFR 50.49

Environmental Qualification Requirements

71003

Miscellaneous

XI.E4

Metal Enclosed Bus Aging Management Program Notebook

71003

Miscellaneous

XI.E6

Electrical Cables Connections Not Subject to 10 CFR 50.49

Environmental

Qualification Requirements (thermography)

71003

Miscellaneous

XI.M16A

PWR Vessel Internals Aging Management Program Notebook

71003

Miscellaneous

XI.M18

Bolting Integrity Aging Management Program Notebook

71003

Miscellaneous

XI.M2

Water Chemistry Aging Management Program Notebook

71003

Miscellaneous

XI.M20

Open-Cycle Cooling Water System Aging Management

Program Notebook

71003

Miscellaneous

XI.M21A

Closed Treated Water Systems Aging Management Program

Notebook

71003

Miscellaneous

XI.M27

Fire Water System Aging Management Program Notebook

71003

Miscellaneous

XI.M29

Aboveground Metal Tanks Aging Management Program

Notebook

71003

Miscellaneous

XI.M30

Fuel Oil Chemistry Aging Management Program Notebook

71003

Miscellaneous

XI.M31

Reactor Vessel Surveillance Aging Management Program

Notebook

71003

Miscellaneous

XI.M33

Selective Leaching Aging Management Program Notebook

71003

Miscellaneous

XI.M38

Inspection of Internal Surfaces in Miscellaneous Piping and

Ducting Components Aging Management Program Notebook

71003

Miscellaneous

XI.M39

Lubricating Oil Analysis Aging Management Program

Notebook

71003

Miscellaneous

XI.S5

Masonry Walls Aging Management Program Notebook

71003

Miscellaneous

XI.S6

Structures Monitoring Aging Management Program Notebook

71003

Miscellaneous

XI.S7

Regulatory Guide 1.127, Inspection of Water Control

Structures Associated with Nuclear Power Plants Aging

Management Program Notebook

71003

Miscellaneous

XI.S8

Protective Coating Monitoring and Maintenance Program

Aging Management Program Notebook

71003

NDE Reports

Twentieth Year Surveillance of the Post-Tensioning System

at the Callaway Nuclear Plant

2004

71003

NDE Reports

180-9347417-000

Callaway RF25 Baffle to Former Bolts Ultrasonic

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Examinations

71003

NDE Reports

180-9347867-000

Callaway RF25 10 Year ISI & MRP-227 Remote In-Vessel

Visual Examination

71003

NDE Reports

A140.0004

Inservice Examination of Condensate Storage and Refueling

Water Storage Tanks

5/2022

71003

NDE Reports

A140.0004

Phased Array Ultrasonic Socket Weld Examinations

4/30/2022

71003

NDE Reports

AMNROLI00019

License Renewal External Surfaces - Insulated Components

Inspection Report

71003

NDE Reports

AMNROLI00019-

REPT-003

OTI Inspection Summary Report

71003

NDE Reports

E170.0105

Fourth Interval Inservice Inspection Program Plan

71003

NDE Reports

NET-28209-000-01

BADGER Testing of BORAL Neutron Absorber Panels at

the Callaway Energy Center

3/1/2024

71003

NDE Reports

NET20200038

Flow-Accelerated Corrosion (FAC) Refuel 24 Outage Report

2/17/2020

71003

NDE Reports

NET20220023

Flow-Accelerated Corrosion (FAC) Refuel 25 Outage Report

2/07/2022

71003

NDE Reports

REP-1117-510

Final Report for the 30th Year Tendon Surveillance at

Callaway Nuclear Power Plant

C

71003

NDE Reports

REP-1160-510

Final Report for the 35th Year Tendon Surveillance at

Callaway

71003

NDE Reports

ULNRC-06021

Owner's Activity Reports (OAR-1 Forms) for Cycle 19 and

Refuel 19

4/21/2013

71003

NDE Reports

ULNRC-06173

Owner's Activity Reports (OAR-1 Forms) for Refuel 20

2/19/2015

71003

NDE Reports

ULNRC-06762

Owner's Activity Reports (OAR-1 Forms) for Cycle/Refuel 25

8/25/2022

71003

NDE Reports

UT 5019-22-133

EG-203-HBC-24 Inlet to Component Cooling Water A

6/1/2022

71003

Procedures

CALLAWAY ENERGY CENTER PROCEDURE WRITERS

MANUAL

71003

Procedures

BOLTING MANUAL

71003

Procedures

APA-ZZ-00345

FUEL RELIABILITY PROGRAM ADMINISTRATIVE

CORRECTION

71003

Procedures

APA-ZZ-00365

CALLAWAY LIFTING OPERATIONS

71003

Procedures

APA-ZZ-00662

ASME SECTION XI REPAIR/REPLACEMENT PROGRAM

71003

Procedures

APA-ZZ-00700

FIRE PROTECTION PROGRAM

71003

Procedures

APA-ZZ-00703

FIRE PROTECTION OPERABILITY CRITERIA AND

SURVEILLANCE REQUIREMENTS

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Procedures

APA-ZZ-01020

PRIMARY CHEMISTRY PROGRAM

71003

Procedures

APA-ZZ-01021

SECONDARY CHEMISTRY PROGRAM

71003

Procedures

APA-ZZ-01021,

ADDENDUM 3

SECONDARY WATER CHEMISTRY STRATEGIC

OPTIMIZATION PLAN

71003

Procedures

APA-ZZ-01025

Raw Water Systems Control Program

71003

Procedures

APA-ZZ-0390

ENVIRONMENTAL AND SEISMIC QUALIFICATION OF

SAFETY-RELATED EQUIPMENT

71003

Procedures

C-1003 (Q)

SPECIFICATION FOR INSERVICE INSPECTION OF THE

CONTAINMENT BUILDING POSTTENSIONING SYSTEM &

EXTERIOR CONCRETE SHELL

71003

Procedures

CDP-ZZ-00110

CHEMISTRY DATA TRENDING PROGRAM

71003

Procedures

CDP-ZZ-00200

CHEMISTRY SCHEDULE AND WATER SPECS

71003

Procedures

CDP-ZZ-00200

APPENDIX A

WATER MAKEUP AND STORAGE TABLES

71003

Procedures

CDP-ZZ-00200

APPENDIX D

CLOSED COOLING SYSTEMS TABLES

71003

Procedures

CDP-ZZ-00200,

APPENDIX C

SECONDARY PLANT SYSTEMS TABLES

71003

Procedures

CDP-ZZ-00940

AUXILIARY WATER SYSTEMS CHEMISTRY

OPTIMIZATION PLAN

71003

Procedures

CSP-ZZ-07350

DIESEL FUEL OIL TESTING PROGRAM

71003

Procedures

CTO-ZZ-01020

OFFNORMAL PRIMARY CHEMISTRY CORRECTIVE

ACTION

71003

Procedures

CTO-ZZ-01021

OFF NORMAL SECONDARY CHEMISTRY CORRECTIVE

ACTIONS

71003

Procedures

CTP-JE-01230

DIESEL FUEL OIL SAMPLING

71003

Procedures

EDP-BB-04002

PERFORMANCE OF REACTOR VESSEL IRRADIATION

SPECIMEN TESTING

71003

Procedures

EDP-PB-00001

METAL ENCLOSED BUS PROGRAM

71003

Procedures

EDP-ZZ-00014

RELOAD DESIGN CONTROL AND COORDINATION

71003

Procedures

EDP-ZZ-01003

INSERVICE INSPECTION PROGRAM

71003

Procedures

EDP-ZZ-01004

BORIC ACID CORROSION CONTROL PROGRAM

71003

Procedures

EDP-ZZ-01112

Heat Exchanger Predictive Performance Manual

71003

Procedures

EDP-ZZ-01113

INFRARED THERMOGRAPHY PROGRAM GUIDE

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Procedures

EDP-ZZ-01115

FLOW-ACCELERATED CORROSION OF PIPING AND

COMPONENTS PREDICTIVE PERFORMANCE MANUAL

71003

Procedures

EDP-ZZ-01121

Raw Water Systems Predictive Performance Program

71003

Procedures

EDP-ZZ-01123

FATIGUEPRO CYCLE/TRANSIENT MONITORING

71003

Procedures

EDP-ZZ-01126

LUBRICATION PREDICTIVE MAINTENANCE PROGRAM

71003

Procedures

EDP-ZZ-01131

APPENDIX K

ENGINEERING SYSTEM WALKDOWNS

71003

Procedures

EDP-ZZ-01140

CLOSED TREATED WATER SYSTEMS PROGRAM

71003

Procedures

EDP-ZZ-01140,

APPENDIX 1

COMPONENT INSPECTION SELECTION CRITERIA

71003

Procedures

EDP-ZZ-01150

ONE-TIME INSPECTION PROGRAM

71003

Procedures

EDP-ZZ-01160

SELECTIVE LEACHING PROGRAM

71003

Procedures

EDP-ZZ-01170

INSPECTION OF INTERNAL SURFACES IN

MISCELLANEOUS PIPING AND DUCTING COMPONENTS

PROGRAM

71003

Procedures

EDP-ZZ-01180

ABOVEGROUND METALLIC TANKS PROGRAM

71003

Procedures

EDP-ZZ-01190

EXTERNAL SURFACES MONITORING OF MECHANICAL

COMPONENTS PROGRAM

71003

Procedures

EDP-ZZ-04070

MANAGEMENT OF ENGINEERING MATERIALS

DEGRADATION MANAGEMENT PLAN SUBPROGRAMS

ACTIVITIES

71003

Procedures

EDP-ZZ-04070,

APPENDIX C

PWR VESSEL INTERNALS AGING MANAGEMENT

PROGRAM

71003

Procedures

EDP-ZZ-04600

ENGINEERING CHANGE CONTROL

71003

Procedures

EDP-ZZ-07001

CABLE MANAGEMENT PROGRAM

71003

Procedures

EDP-ZZ-07001

APPENDIX A

LICENSE RENEWAL IN-SCOPE CABLES

71003

Procedures

EDP-ZZ-07001,

APPENDIX B

INSULATION MATERIAL FOR ELECTRICAL CABLES AND

CONNECTION NOT SUBJECT TO 10 CFR 50.49

ENVIRONMENTAL QUALIFICATION REQUIREMENTS

USED IN INSTRUMENTATION CIRCUITS

71003

Procedures

EDP-ZZ-07001,

APPENDIX C

ELECTRICAL CABLE CONNECTION NOT SUBJECT TO 10 CFR 50.49 ENVIRONMENTAL QUALIFICATION

REQUIREMENTS

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Procedures

EDP-ZZ-07001,

APPENDIX D

INSTRUCTIONS FOR PERFORMANCE OF TAN DELTA

TESTING, ANALYSIS AND TROUBLESHOOTING

71003

Procedures

EDP-ZZ-07001,

APPENDIX E

INSTRUCTIONS FOR ANALYZING AND

TROUBLESHOOTING INSULATION

RESISTANCE TESTING RESULTS

71003

Procedures

ESP-EF-03002

ULTIMATE HEAT SINK RETENTION POND IN-SERVICE

INSPECTION

71003

Procedures

ESP-GP-01007

REACTOR BUILDING INTEGRATED LEAK RATE TEST -

IPTE

71003

Procedures

ESP-KC-00700

FIRE SUPPRESSION SYSTEMS INTERNAL VISUAL

INSPECTIONS

71003

Procedures

ESP-KE-01018

NEUTRON-ABSORBING MATERIAL MONITORING

PROGRAM

71003

Procedures

ESP-SE-0XIE2

TESTING OF THE EXCORE NUCLEAR

INSTRUMENTATION CABLES TO SUPPORT LICENSE

EXTENSION REQUIREMENT XI.E2

71003

Procedures

ESP-SM-01001

CONTAINMENT LEAKAGE RATE TESTING PROGRAM

71003

Procedures

ESP-ZZ-01012

CONTAINMENT POST-TENSIONING SYSTEM

INSPECTION

71003

Procedures

ESP-ZZ-01013

CALLAWAY STRUCTURES INSPECTION PROGRAM

71003

Procedures

ESP-ZZ-01013,

APPENDIX A

MAINTENANCE RULE STRUCTURE LIST

71003

Procedures

ESP-ZZ-01013,

APPENDIX B

MAINTENANCE RULE WALKDOWN GUIDELINES

71003

Procedures

ESP-ZZ-01013,

APPENDIX D

QUANTITATIVE CATEGORIZATION GUIDELINES FOR

LICENSE RENEWAL IMPLEMENTATION

71003

Procedures

ESP-ZZ-01016

ASME SECTION XI IWE CONTAINMENT PRESSURE

BOUNDARY INSPECTION

71003

Procedures

ETP-ZZ-00015

PREPARATION, REVIEW, APPROVAL AND CONTROL OF

THE CURVE BOOK

71003

Procedures

ETP-ZZ-01002

TRACKING TRANSIENTS

71003

Procedures

ETP-ZZ-03001

GL89-13 Heat Exchanger Inspection

71003

Procedures

ETP-ZZ-03050

AGING MANAGEMENT OF LOSS OF COATING OR LINING

INTEGRITY FOR INTERNAL COATINGS

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Procedures

MDP-ZZ-L0001

LUBRICATION PROGRAM

71003

Procedures

MDP-ZZ-LM001

FLUID LEAK MANAGEMENT PROGRAM

71003

Procedures

MDP-ZZ-LR001

TEMPORARY REPAIR OF LEAKS

71003

Procedures

MPM-KC-FW001

THREE YEAR WATER SPRAY FLOW TEST

71003

Procedures

MPM-KE-QH001

CASK HANDLING CRANE INSPECTION

71003

Procedures

MSM-KC-FT002

FIRE PROTECTION WATER TANK INSPECTION

71003

Procedures

MSM-KC-FW004

FIRE HOSE HYDROSTATIC TESTING

71003

Procedures

MSM-KC-FW007

HYDRANT INSPECTION, LUBRICATION AND FLUSH

71003

Procedures

MSM-KC-FW008

FIRE HOSE HYDROSTATIC TESTING IN POTENTIALLY

CONTAMINATED AREAS

71003

Procedures

MSM-KJ-QT001

YEAR EMERGENCY DIESEL GENERATOR FUEL OIL

STORAGE TANK CLEANING

71003

Procedures

OSP-BB-00009

RCS INVENTORY BALANCE

71003

Procedures

OSP-EF-00004

ULTIMATE HEAT SINK RIPRAP INSPECTION

71003

Procedures

OSP-EF-0002A

ESSENTIAL SERVICE WATER TRAIN A FLOW

VERIFICATION

71003

Procedures

OSP-EF-0002B

ESSENTIAL SERVICE WATER TRAIN B FLOW

VERIFICATION

71003

Procedures

OSP-KC-00019

NON-SAFETY RELATED SPRAY/SPRINKLER SYSTEMS

FUNCTIONAL TESTS SECONDARY AND INSIDE

WATCHSTATIONS

71003

Procedures

OSP-KC-03003

FIRE MAIN FLOW TEST

71003

Procedures

OSP-KC-03004

FIRE PUMP PERFORMANCE TEST

71003

Procedures

OSP-KC-03005

FIRE WATER MAIN DRAIN TESTING

71003

Procedures

OTO-BB-00003

RCS EXCESSIVE LEAKAGE

71003

Procedures

QCP-ZZ-05040

VISUAL EXAMINATION TO ASME VT-1

71003

Procedures

QCP-ZZ-05042

VISUAL EXAMINATION TO ASME VT-3

71003

Procedures

QCP-ZZ-05048

BORIC ACID WALKDOWN FOR RCS PRESSURE

BOUNDARY

71003

Procedures

S-1088 (Q)

SPECIFICATION FOR REACTOR VESSEL INTERNALS

INSPECTION

71003

Self-Assessments

2000212-003

INPO Materials Review Visit (MRV) Preparation Self-

Assessment

3/11/2020

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Work Orders

JOB

09511816, 09512423, 10507445, 11514152, 12502875,

2503606, 12512139, 13001166, 13503632, 13506829,

13509040, 13511179, 13511468, 13512497, 13513168,

14508807, 15511748, 15511793, 16005026, 16504015,

16504021, 16504220, 16505711, 16511799, 16512177,

16512336, 17501541, 17502689, 17504654, 17504901,

17505255, 17507931, 17509345, 17509690, 17512690,

18501108, 18505811, 18509724, 19003189, 19504386,

19504389, 19504445, 19506352, 19508972, 19513607,

19513608, 19513623, 19513624, 20001864, 20501885,

20509440, 21508424, 22002919, 22501871, 22503628,

2505516, 22505595, 22505720, 22510724, 22512431,

23004482, 23004513, 23504069, 23507487, 24501045,

24501221, 24501686