ML24239A778
| ML24239A778 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 08/26/2024 |
| From: | Vaughn Thomas NRC/NRR/DNRL |
| To: | Penfield R Perry, OH |
| References | |
| EPID L-2023-RNW-0002 | |
| Download: ML24239A778 (101) | |
Text
August 26, 2024 Mr. Rod L. Penfield Site Vice President Vistra Operations Company LLC -
Perry Nuclear Power Plant P.O. Box 97, Mail Stop A-PY-A290 Perry, OH 44081-0097
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT 1 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2023-RNW-0002)
Dear Mr. Penfield:
By letter dated July 3, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23184A081), as supplemented by letter dated June 27, 2024 (ML24180A010), July 24, 2024 (ML24206A150), and August 7, 2024 (ML24220A270), Energy Harbor Nuclear Corp.(Energy Harbor) applied for license renewal of Facility Operating License No. NPF-58 for Perry Nuclear Power Plant, Unit No. 1, to the U.S. Nuclear Regulatory Commission (NRC). Energy Harbor submitted its application pursuant to Title 10 of the Code of Federal Regulations part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for subsequent license renewal.
Effective March 1, 2024, the facility operating license for Perry was transferred from Energy Harbor Nuclear Generation LLC (owner) and Energy Harbor Nuclear Corp. (operator) to Energy Harbor Nuclear Generation LLC (owner) and Vistra Operations Company LLC (operator)
(ML24057A092). Upon completion of this license transfer, Vistra Operations Company, LLC (the licensee) assumed the responsibility for all licensing actions under NRC review at the time of the transfer and requested that the NRC continue its review of these actions (ML24054A498).
The NRC staff completed its aging management audit from November 20, 2023-April 19, 2024, in accordance with the audit plan (ML23261B019). The audit report is enclosed.
If you have any questions, please contact me by email at Vaughn.Thoas@nrc.gov.
Sincerely,
/RA/
Vaughn V. Thomas, Project Manager License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket No. 50-440
Enclosure:
Audit Report cc w/encl: Listserv
SUBJECT:
PERRY NUCLEAR POWER PLANT, UNIT 1 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2023-RNW-0002)
DATED: AUGUST 26, 2024 DISTRIBUTION:
EMAIL:
PUBLIC V Thomas, NRR/DNRL AIm, NRR/DNRL S Lingam L Gibson, NRR/DNRL L Rakovan, NMSS/REFS T Smith, NMSS/REFS B Smith, NRR/DNRL S Lee, NRR/DNRL S Wall, NRR/DORL J Whited, NRR/DORL T Keene, OEDO S Burnell, HQ/OPA L Wilkins, OCA D McIntyre, HQ/OPA D Roth, OGC P Chandrathil, RIII/OPA V Mitlying, RIII/OPA A Barker, RIII/FCO T Ospino, RIII/DORS J Beavers, RIII/DORS K Stoedter, RIII/DORS M Domke, RIII/DORS EMAIL:
mark.bensi@vistracorp.com ADAMS Accession Nos.:
PKG: ML24156A152 LTR: ML24239A778 Via Email NRR-106 OFFICE PM:NRLP:DNRL BC:SCPB:DSS BC:NPHP:DNRL BC:ELTB:DEX NAME V Thomas M Valentin M Mitchell J Paige DATE 08/13/2024 05/07/2024 07/23/2024 05/07/2024 OFFICE BC:NCSG:DNRL BC:NVIB:DNRL BC:ESEB:DEX BC:SNSB:DSS NAME SBloom ABuford I Tseng P Sahd DATE 07/23/2024 08/13/2024 07/09/2024 06/10/2024 OFFICE Tech Editor BC:NRLP:DNRL PM:NRLP:DNRL NAME Contractor L Gibson V Thomas DATE 08/08/2024 08/16/2024 08/26/2024
Enclosure Aging Management Audit Perry Nuclear Power Plant, Unit 1 License Renewal Application November 20, 2023 - April 19, 2024 Division of New and Renewed Licenses Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
ii U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION DIVISION OF NEW AND RENEWED LICENSES Docket No:
50-440 License No:
DPR-58 Licensee:
Energy Harbor Nuclear Generation LLC (owner) and Vistra Operations Company LLC (operator)
Facility:
Perry Nuclear Power Plant (PNPP), Unit 1 Location:
Rockville, Maryland Perry, Ohio Dates:
November 20, 2023 - April 19, 2024 Approved By:
Steven D. Bloom, Chief Corrosion and Steam Generator Branch Division of New and Renewed Licenses Angie R. Buford, Chief Vessels and Internals Branch Division of New and Renewed Licenses Ian Tseng, Chief Structural, Civil, Geotech Engineering Branch B Division of Engineering and External Hazards Lauren K. Gibson, Chief License Renewal Projects Branch Division of New and Renewed Licenses Jason Paige, Acting Chief Long Term Operations and Modernization Branch Division of Engineering and External Hazards Philip Sahd, Chief Nuclear Systems Performance Branch Division of Safety Systems Matthew A. Mitchell, Chief Piping and Head Penetrations Branch Division of New and Renewed Licenses Milton Valentin, Chief Containment & Plant Systems Branch Division of Safety Systems
iii Reviewers:
Name Organization Naeem Iqbal PRA Licensing B (APLB)/Division of Risk Assessment (DRA)
Adakou Foli Long Term Operations & Modernization Branch (ELTB)/Division of Engineering and External Hazards (DEX)
Matthew McConnell ELTB/DEX Jorge Cintron ELTB/DEX Liliana Ramadan ELTB/DEX Andrew Prinaris Structural, Civil, Geotech Engineering (ESEB)/DEX Amitava Ghosh ESEB/DEX Dan Hoang ESEB/DEX George Wang ESEB/DEX Ata Istar ESEB/DEX Andrew Johnson Corrosion and Steam Generator (NCSG)/New and Renewed Licenses (DNRL)
Brian Allik NCSG/DNRL Gregory Makar NCSG/DNRL James Gavula Joel Jenkins NCSG/DNRL NCSG/DNRL Leslie Terry NCSG/DNRL Lydiana Alvarado NCSG/DNRL Matthew Yoder NCSG/DNRL Paul Klein Reena Boruk NCSG/DNRL NCSG/DNRL Ali Rezai Piping and Head Penetrations (NPHP)/DNRL Bart Fu NPHP/DNRL Varoujan Kalikian NPHP/DNRL Carolyn Fairbanks Vessels and Internals (NVIB)/DNRL Cory Parker NVIB/DNRL David Dijamco Emma Haywood NVIB/DNRL NVIB/DNRL Michael Benson NVIB/DNRL Brian Lee Containment and Plant Systems (SCPB)/Division of Safety Systems (DSS)
David Nold SPCB/DSS Gordon Curran SCPB/DSS Fred Forsaty Santosh Bhatt Nuclear Systems Performance (SNSB)/DSS SNSB/DSS Chris Tyree Vaughn Thomas License Renewal Projects Branch (NLRP)/DNRL NLRP/DNRL Austin Im NLRP/DNRL Siva Lingam NLRP/DNRL Bill Rogers NLRP/DNRL
iv TABLE OF CONTENTS TABLE OF CONTENTS............................................................................................................... iv ACRONYMS AND ABBREVIATIONS........................................................................................... v
- 1.
Introduction............................................................................................................................ 1
- 2.
Audit Activities....................................................................................................................... 2 LRA Section 2.1, Scoping and Screening Methodology............................................................ 2 LRA Sections 2.3.3.24, Fire Protection and 2.4.4, Bulk Commodities (Fire Barrier Portion Only).......................................................................................................................... 6 LRA AMP B.2.1, 10 CFR, Appendix J Program........................................................................ 8 LRA AMP B.2.2, Aboveground Metallic Tanks Program........................................................... 9 LRA AMP B.2.3, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program......................................................................................................................... 9 LRA AMP B.2.4, ASME Section XI, Subsection IWE Program............................................... 10 LRA AMP B.2.5, ASME Section XI, Subsection IWF Program................................................ 12 LRA AMP B.2.6, ASME Section XI, Subsection IWL Program................................................ 14 LRA AMP B.2.7, Bolting Integrity Program.............................................................................. 15 LRA AMP B.2.8, Buried and Underground Piping and Tanks Program.................................. 16 LRA AMP B.2.9, BWR Control Rod Drive Return Line Nozzle Program................................. 17 LRA AMP B.2.10, BWR Feedwater Nozzle Program.............................................................. 18 LRA AMP B.2.11, BWR Penetrations Program....................................................................... 19 LRA AMP B.2.12, BWR Stress Corrosion Cracking Program................................................. 20 LRA AMP B.2.13, BWR Vessel ID Attachment Welds Program.............................................. 21 LRA AMP B.2.14, BWR Vessel Internals Program................................................................ 212 LRA AMP B.2.15, Closed Treated Water Systems Program................................................. 233 LRA AMP B.2.16, Compressed Air Monitoring Program....................................................... 244 LRA AMP B.2.17, Environmental Qualification (EQ) of Electrical Components Program..... 255 LRA AMP B.2.18, External Surfaces Monitoring of Mechanical Components Program........ 266 LRA AMP B.2.19, Fatigue Monitoring Program..................................................................... 266 LRA AMP B.2.20, Fire Protection Program........................................................................... 288 LRA AMP B.2.21, Fire Water System Program................................................................... 3030 LRA AMP B.2.22, Flow-Accelerated Corrosion Program Description................................... 322 LRA AMP B.2.23, Fuel Oil Chemistry Program..................................................................... 333 LRA AMP B.2.24, Fuse Holders Program............................................................................. 344 LRA AMP B.2.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program........................................................................................................ 345 LRA AMP B.2.26, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program.............................................................................. 355
v LRA AMP B.2.27, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program.............................................................................. 377 LRA AMP B.2.28, Lubricating Oil Analysis Program............................................................. 388 LRA AMP B.2.29, Masonry Walls Monitoring Program......................................................... 399 LRA AMP B.2.30, Monitoring of Neutron-Absorbing Materials Other Than Boraflex Program........................................................................................................................... 4040 LRA AMP B.2.31, Non-EQ Electrical Cable Connections Program..................................... 4040 LRA AMP B.2.32, Non-EQ Inaccessible Power Cables Program......................................... 411 LRA AMP B.2.33, Non-EQ Instrumentation Circuits Program............................................... 422 LRA AMP B.2.34, Non-EQ Insulated Cables and Connections Program.............................. 433 LRA AMP B.2.35, One-Time Inspection Program................................................................. 444 LRA AMP B.2.36, One-Time Inspection of ASME Code Class 1 Small Bore-Piping Program............................................................................................................................... 44 LRA AMP B.2.37, Open-Cycle Cooling Water System Program............................................. 45 LRA AMP B.2.38, Protective Coating Monitoring and Maintenance Program....................... 466 LRA AMP B.2.39, Reactor Head Closure Stud Bolting Program........................................... 477 LRA AMP B.2.40, Reactor Vessel Surveillance Program...................................................... 499 LRA AMP B.2.41, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program........................................................................................... 49 LRA AMP B.2.42, Selective Leaching Program...................................................................... 50 LRA AMP B.2.43, Structures Monitoring Program................................................................ 511 LRA AMP B.2.44, Water Chemistry Program........................................................................ 533 LRA TLAA Section 4.1, Time-Limited Aging Analyses............................................................ 54 LRA TLAA Section 4.2.1, Neutron Fluence Projections.......................................................... 55 LRA TLAA Sections 4.2.2, Upper Shelf Energy and 4.2.3, Adjusted Reference Temperature Analyses....................................................................................................... 566 LRA TLAA Section 4.2.4, Pressure-Temperature Limits......................................................... 58 LRA TLAA Section 4.2.5, RPV Shell Welds Failure Probability Assessment Analysis........... 59 LRA TLAA Section 4.2.6, RPV Reflood Thermal Shock........................................................ 611 LRA TLAA Section 4.3.1, Class 1 Fatigue............................................................................. 622 LRA TLAA Section 4.3.2, Non-Class 1 Fatigue..................................................................... 633 LRA TLAA Section 4.3.3, Environmental Fatigue.................................................................. 644 LRA TLAA Section 4.3.4, Reactor Vessel Internals Fatigue................................................. 666 LRA TLAA Section 4.3.5, Intermediate High-Energy Line Break (HELB) Location Determination.................................................................................................................... 677 LRA TLAA Section 4.4, Environmental Qualification of Electric Equipment.......................... 688 LRA TLAA Section 4.5, Containment Vessel, Containment Piping Penetrations and Containment Piping Penetration Bellows........................................................................... 699
vi LRA TLAA Section 4.6.1, Crane Load Cycles....................................................................... 722 LRA TLAA Section 4.6.2, Main Steam Line Flow Restrictors Erosion Analysis.................... 733 LRA TLAA Section 4.6.3, Reduction of Fracture Toughness for the Reactor Vessel Internals............................................................................................................................... 73 LRA TLAA Section 4.6.4, Fatigue Analysis - Earthquake Cyclic Loading............................ 744 LRA TLAA Section 4.6.5, Fatigue due to Partial Feedwater Heating.................................... 755 LRA TLAA Section 4.6.6, Fatigue due to Single Recirculation Loop Operation...................... 75 LRA TLAA Section 4.6.7, Steam Piping Erosion..................................................................... 76 LRA TLAA Section 4.6.8, Silicone Sealant in Engineered Safety Features (ESF)
Heating, Ventilation, and Air Conditioning (HVAC)............................................................ 777 LRA TLAA Section 4.6.9, Top Guide Grid Beam Neutron Fluence......................................... 77 LRA TLAA Section 4.6.10, Jet Pump Fatigue Analysis......................................................... 788 LRA TLAA Section 4.6.11, Allowable Stress Analysis of BOP ASME Code Class 1, 2 and 2 Components.............................................................................................................. 78 LRA TLAA Section 4.6.12, RV Annealing............................................................................ 8080 AMR Items Not Associated with an AMP................................................................................ 80
- 3.
Supplements to the LRA.................................................................................................... 899
- 4.
Audit Questions Provided to NSPM................................................................................... 899
- 5.
Applicant Personnel Contacted During Audit..................................................................... 900
- 6.
Exit Meeting......................................................................................................................... 90
v ACRONYMS AND ABBREVIATIONS ADAMS Agencywide Documents Access and Management System AMP aging management program AMR ART aging management review Adjusted reference temperature ASME American Society of Mechanical Engineers BWR boiling water reactor BWRVIP Boiling Water Reactor Vessel and Internals Project Program CFR Code of Federal Regulations CLB current licensing basis CR change request CRDRL control rod drive return line CUFen environmentally adjusted cumulative usage factor DBAR Design Basis Assessment Report DBD design-basis documents EAF environmentally assisted fatigue EFPY effective full-power years EI&C electrical and instrumentation and control ESF Engineered Safety Features FE Further Evaluation FSAR final safety analysis report GALL-LR NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal HVAC heating, ventilation, and air conditioning HELB high energy line break IN Information Notice ISG interim staff guidance ISI in-service inspection LAR License Amendment Request LR license renewal LRA license renewal application NA not applicable NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission OE operating experience P-T pressure-temperature PNPP Perry Nuclear Power Plant RAI request for additional information RCI request for confirmation of information RCPB reactor coolant pressure boundary RPV reactor pressure vessel RTNDT reference temperature nil ductility RV reactor vessel SAR safety analysis report SC structures and the components SE safety evaluation
vi SRP-LR Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants SRV Safety Relief Valves SSC systems, structures, and components TLAA Time-Limited Aging Analyses UFSAR Updated Final Safety Analysis Report USE upper-shelf energy UT ultrasonic testing VT visual examination WO work order
1 Report for the Aging Management Audit Perry Nuclear Power Plant, Unit 1 License Renewal Application
- 1. Introduction The U.S. Nuclear Regulatory Commission (NRC) staff conducted an aging management audit of Energy Harbor Nuclear Corp. (Energy Harbor, the applicant) of (1) plant-specific operating experience (OE); (2) methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal (LR) and subject to an aging management review (AMR) (Scoping and Screening Portion); and (3) aging management programs (AMPs),
AMR items, Time-Limited Aging Analyses (TLAAs), and associated bases and documentation as applicable (AMP and TLAA Portion) for the license renewal (LR) of Renewed Facility Operating License No. DPR-58 for Perry Nuclear Power Plant (PNPP), Unit 1.
The purpose of the plant-specific OE portion of the audit is to identify examples of age-related degradation, as documented in the applicants corrective action program database, and to provide a basis for the staffs conclusions on the ability of the applicants proposed AMPs to manage the effects of aging in the period of extended operation. Energy Harbor searched their OE database and provided the results for the associated AMPs and TLAAs for NRC staff review. Additional word searches were performed by Energy Harbor upon NRC staffs request, and the results were provided to the NRC staff for review.
The purpose of the Scoping and Screening portion of the audit is to evaluate the scoping and screening process as documented in the LR application, implementing procedures, reports, and drawings, such that the NRC staff:
obtain an understanding of the process used to identify the SSCs within the scope of LR and to identify the structures and components subject to an AMR have sufficient docketed information to allow the staff to reach a conclusion on the adequacy of the scoping and screening methodology as documented and applied The purpose of the AMP and TLAA Portion of the audit is to:
examine Energy Harbors AMPs, AMR items, and TLAAs for PNPP verify Energy Harbors claims of consistency with the corresponding NUREG-1801, Generic Aging Lessons Learned for License Renewal (GALL) Report, (GALL-LR Report) issued in December 2010, AMPs, and AMR items assess the adequacy of the TLAAs Enhancements and exceptions will be evaluated on a case-by-case basis. The NRC staffs review of enhancements and exceptions will be documented in the safety evaluation (SE).
The regulatory basis for the audit was Title 10 of the Code of Federal Regulations (10 CFR)
Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. The NRC staff also considered the guidance contained in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), dated December 2010, and NUREG-1801. The SRP-LR allows an applicant to reference in its license renewal application (LRA) the AMPs described in the GALL-LR Report. By referencing the GALL-LR
2 Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and approved in the GALL-LR Report and that no further NRC staff review is required. If an applicant credits an AMP for being consistent with a GALL-LR Report program, it is incumbent on the applicant to make sure the plant program contains all elements of the referenced GALL-LR Report program. The applicant should document this determination in an auditable form and maintain the documentation onsite.
- 2.
Audit Activities A regulatory audit is a planned, license-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain greater understanding of an application, to verify information and, if applicable, to identify information that will require docketing to support the staffs conclusions that form the basis of the licensing or regulatory decision.
The LRA states that every AMP in the LRA is consistent with the program elements of the GALL-LR Report. To verify this claim of consistency, the staff audited each AMP, including any enhancements or exceptions associated with an AMP.
The LRA discusses each TLAA, the disposition of the TLAA in accordance with 10 CFR 54.21(c)(1), and the basis for that disposition. To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited each TLAA.
The staff also audited AMR items not associated with an AMP to determine if the information in the LRA is consistent with the further evaluation (FE) information in the SRP-LR.
Furthermore, the staff audited the final safety analysis report (FSAR) descriptions for each AMP and TLAA for consistency with the SRP-LR. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal.
For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.
Licensing conclusions or staff findings are not made in the audit reports since licensing and regulatory decisions cannot be made solely based on an audit. Therefore, items identified but not resolved within the scope of the audit will be followed using other NRC processes, such as requests for additional information (RAIs), requests for confirmation of information (RCIs), and public meetings. Licensing conclusions, staff findings, staff review of enhancement and exceptions, and resolution of audit items will be documented in the staffs SE.
The following sections discuss the LRA areas reviewed by the staff.
LRA Section 2.1, Scoping and Screening Methodology Summary of Information in the Application. LRA Section 2.1, Scoping and Screening Methodology, describes the process for identifying and determining the PNPP SSCs that are included within the scope of LR. 10 CFR 54.21, Contents of Application - Technical Information, requires that each application for LR contain an integrated plant assessment, which lists, for SSCs within the scope of LR, the structures and the components (SCs) that
3 are subject to an AMR. Section 10 CFR 54.4(a), Scope, provides criteria for inclusion of SSCs within the scope of LR and 10 CFR 54.21(a)(1) requires that SCs within the scope of license renewal, that are determined to be passive and not periodically replaced (long-lived), are subject to an AMR. The staff conducted an onsite scoping and screening methodology audit, from January 16-18, 2024, to review the scoping and screening methodology, administrative controls governing implementation of the methodology, and the scoping and screening results for selected plant SSCs.
Audit Activities.
A. Scoping Methodology Staff Review of Information Sources, Implementing Documents and Scoping Methodology The audit team reviewed the methodology used by the applicant to identify mechanical, structural, and electrical SSCs within the scope of LR (scoping). In addition, the audit team reviewed documentation pertinent to the scoping process. The audit team assessed whether the scoping methodology outlined in the LRA and implementing procedures was consistent with the requirements of 10 CFR Part 54.
The staff determined that the applicants LR project personnel performed the scoping activities, in accordance with the applicable implementing documents. The staff noted that as required by Perry Business Practice PYBP-LRP-0002, Mechanical Scoping and Screening, Attachment 5:
Mechanical System Scoping Confirmation, the applicant had reviewed the information developed for an earlier license renewal project that had been suspended in 2015, and documented and reviewed all plant changes from that period through the development of the current LRA.
The applicant indicated that although previous scoping and screening information had been developed for the 2015 LRA project, the applicant had reperformed the scoping and screening process as described in the PYB-LRP-0002, Perry Business Practice PYB-LRP-0003, Electrical Scoping, Screening and Aging Management Review, and Perry Business Practice PYB-LRP-0005, Civil/Structural Scoping, Screening and Aging Management Review, for the development of the LRA currently under review.
The staff confirmed that the applicants detailed LR program guidelines specified the use of the current licensing basis (CLB) source information in developing scoping evaluations. The staff reviewed pertinent information sources used by the applicant including the component database, the Updated Final Safety Analysis Report (UFSAR), maintenance rule basis documents, design-basis documents (DBD), LR drawings and station drawings.
The staff discussed the applicants administrative controls for the component database and the other information sources used to verify system information. These controls are described and implemented by plant procedures. Based on a review of the administrative controls and on a sample of the system classification information contained in the applicable documentation, the staff determined that the applicant has established adequate measures to control the integrity and reliability of system identification and safety classification data; therefore, the staff determined that the information sources used by the applicant during the scoping and screening process provided a controlled source of system and component data to support scoping and screening evaluations.
4 The staff reviewed the implementing procedures and resulting reports used to support identification of SSCs that the applicant relied on to demonstrate compliance with the requirements of 10 CFR 54.4(a). The applicants LR program guidelines provided a listing of documents used to support scoping evaluations. The staff determined that the design documentation sources, required to be used by the applicants implementing procedures, provided sufficient information to ensure that the applicant identified SSCs to be included within the scope of LR consistent with the plants CLB.
During the audit, the applicant stated that it evaluated the types of events listed in Nuclear Energy Institute (NEI) 95-10 (anticipated operational occurrences, design-basis accidents, external events, and natural phenomena) that were applicable to PNPP. The staff reviewed the applicants basis documents, which described design-basis conditions in the CLB, and addressed events defined by 10 CFR 50.49(b)(1) and 10 CFR 54.4(a)(1). The UFSAR and basis documents discussed events, such as internal and external flooding, tornados, and missiles. The staff determined that the applicants evaluation of DBEs was consistent with the SRP-LR.
The staff determined that the applicants LR project personnel performed the scoping activities, in accordance with the applicable implementing documents, as follows:
Mechanical scoping: The applicant used information contained in the plant component database to develop a list of plant systems and used CLB information, DBDs, maintenance rule basis documents, and station drawings to identify system intended functions. The intended functions were evaluated using the criteria of 10 CFR 54.4(a) to identify those systems to be included within the scope of LR.
Structural scoping: The applicant used CLB information, DBDs, and station drawings to develop a structures list and to identify structural intended functions. The intended functions were evaluated using the criteria of 10 CFR 54.4(a) to identify those systems to be included within the scope of LR.
Electrical scoping: the applicant used a bounding approach for plant electrical and instrumentation and control (EI&C) systems and initially included all EI&C systems, and EI&C components contained in mechanical systems, within the scope of LR by default.
B. Screening Methodology The audit team reviewed the methodology used by the applicant to determine if mechanical, structural, and electrical SCs within the scope of LR would be subject to an AMR (screening) and the applicant provided a discussion indicating the processes used for each discipline.
The staff determined that the applicants LR project personnel performed the screening activities, in accordance with the applicable implementing documents, as follows:
Mechanical components were subject to AMR if they met the criteria of being passive and long-lived and the components supported a system intended function, which required the system to be included within the scope of LR. The applicant had identified the component level intended functions (e.g., pressure boundary, heat transfer), which supported a system intended function and highlighted the in-scope components that were subject to AMR on the LR drawings. Mechanical components included within scope in accordance with 10 CFR 54.4(a)(2) and subject to AMR also were identified on the LR drawings.
5 Structural components had been determined by the applicant to be inherently passive and long-lived and were grouped by common structural intended functions (e.g., support, enclosure protection, fire barrier, flood barrier, pressure boundary). The components were treated as bulk commodities based on material of construction for the purposes of the AMR.
Electrical and instrumentation and control components, which were included within the scope of renewal in accordance with the bounding method used for EI&C, were evaluated in accordance with the guidance contained in NEI 95-10 to identify the passive and long-lived components subject to AMR. In addition, the use of the plant spaces approach scoping method eliminates the need for unique identification of each EIC component and its specific location. In addition, the review of SCs located in specific system or spaces could be further reviewed and the SCs screened out if it was determined the SCs did not perform an intended functions and, therefore, were not subject to an AMR.
The audit team noted that the applicants screening process was performed in accordance with its written requirements and was consistent with the guidance provided in the SRP-LR and NEI 95-10. The audit team determined that the screening methodology was consistent with the requirements of 10 CFR Part 54 for the identification of SSCs that meet the screening criteria of 10 CFR 54.21(a)(1).
C. Staff Verification of Scoping and Screening Results for Sampled Systems and Components The staff performed a sampling review of the results of the applicants implementation of the scoping and screening methodology to confirm that the results were in conformance with the applicable implementing documents and the requirements of 10 CFR Part 54.
The staff reviewed a sample of the scoping and screening implementation and performed walkdowns for portions of various systems, focusing on nonsafety-related SSCs in proximity of SR SSCs. The staff reviewed applicable portions of the UFSAR, scoping and screening reports, and LR drawings and performed walkdowns to confirm information contained in the LRA.
The staff performed a site walkdown to observe those buildings that were included within the scope of LR, determined to be subject to an AMR, and were included in AMPs. The staff walkdowns included the exteriors and interiors (as appropriate) of the turbine, emergency diesel generator, switchgear, auxiliary, and containment structures.
D. Aging Management Program Quality Assurance Attributes The audit team reviewed the AMP quality assurance (QA) elements to verify consistency with the staffs guidance described in SRP-LR, Appendix A, Branch Technical Positions, Section A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1). The AMP QA elements are corrective action, confirmation process, and administrative controls.
The applicant described the AMP QA elements in LRA Appendix A, Updated Final Safety Analysis Report Supplement, Section A.1, Summary Descriptions of Aging Management Programs and Activities, and LRA Appendix B, Aging Management Programs, Section B.1.3, Quality Assurance Program and Administrative Controls, and the individual AMPs.
6 LRA Section Appendix A.1 stated that the QA Program for PNPP implements the requirements of 10 CFR Part 50, Appendix B, and will be consistent with the summary in Appendix A.2, Quality Assurance for Aging Management Programs (Branch Technical Position IQMB-1), of NUREG-1800. The QA Program includes the elements of corrective action, confirmation process, and administrative controls, and is applicable to nuclear safety-related SSCs. PNPP will enhance the QA Program to include nonnuclear safety (NNS) SSCs that are subject to AMR for LR.
LRA Section Appendix B.1.3 also stated that the PNPP QA Program implements the requirements of 10 CFR Part 50, Appendix B, Quality Assurance Requirements for Nuclear Power Plants and Fuel Reprocessing Plants and is consistent with the summary in Appendix A.2 of NUREG-1800. The PNPP QA Program includes the elements of corrective action, confirmation process, and administrative controls, and is applicable to nuclear safety-related SSCs and nonsafety-related SSCs that are subject to AMR for LR.
Based on the audit teams evaluation, review of the AMPs and information contained in LRA Sections Appendix A.1 and Appendix B.1.3, the staff determined that the AMP QA elements are consistent with the staffs position regarding QA for aging management.
Documents Reviewed. The table below list documents that were reviewed by the staff and were found relevant. The staff will document its review of this information in the SE.
Document Title Revision Date Perry Business Practice No. PYBP-LRP-0002 Mechanical Scoping and Screening 08/22/2022 Perry Business Practice No. PYBP-LRP-0004 Electrical Scoping, Screening and Aging Management Review dated 04/01/2021 Perry Business Practice No. PYBP-LRP-0005 Civil/Structural Scoping, Screening and Aging Management Review 03/10/2021 LRA Sections 2.3.3.24, Fire Protection and 2.4.4, Bulk Commodities (Fire Barrier Portion Only)
Summary of Information in the Application. The staff reviewed LRA Sections 2.3.3.24, 2.2.4, and the relevant LRA boundary drawings using the evaluation methodology described in NUREG-1800, Revision 2, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Section 2.3. The staff also reviewed the FSAR, Section 9.5.1, Fire Protection System, and Section 9A, Fire Protection Evaluation Report, which describe the fire protection program for PNPP and how it complies with the requirements of 10 CFR 50.48, Fire protection, and the guidelines of Appendix A, to Branch Technical Position Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants Docketed Prior to July 1, 1976. FSAR Section 9A also presents a point-by-point comparison with Branch Technical Position APCSB 9.5-1, Appendix A, and 10 CFR Part 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979.
The staff also reviewed the following fire protection documents cited in the current licensing basis listed in the PNPP, Operating License Condition 2.C(6):
NUREG-0887, Safety Evaluation Report Related to the Operation of Perry Nuclear Power Plant, Units 1 and 2, May 1982 and Supplements Nos. 1 through 10.
7 During its review, the staff evaluated the system functions described in the LRA and FSAR, Section 9.5.1 and Section 9A to verify that the applicant had not omitted from the scope of license renewal any components with intended functions pursuant to 10 CFR 54.4(a). The staff then reviewed those components that the applicant identified as within the scope of license renewal to verify that the applicant had not omitted any passive or long-lived components subject to an AMR in accordance with 10 CFR 54.21(a)(1).
Audit Activities. The staff reviewed the application, methodology, and systems that are within the scope of license renewal in accordance with 10CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1).
During the discussion, the applicant clarified the staffs concerns identified in the LRA Section 2.3.3-24 audit question related to the reactor coolant pressure boundary (RCPB) system passive fire protection components, standpipe and interior hose stations, hose connections and racks, filter housing, odorizer, hanger and piping support, seismic support for standpipes system piping, diesel fire pump exhaust silencer, traveling screens, floor drains and curbs for fire-fighting water, dikes for oil spill confinement, fire wrap/electric raceway fire barrier, and radiant energy shield.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
During the audit, the applicant stated that the RCPB systems intended function is to maintain its pressure boundary during a fire shutdown. Although the RCPB is a requirement of Appendix R, there are no passive fire protection components in the scope of license renewal and subject to an AMR. Further, the applicant stated that except for the odorizer and filter housings, all fire protection component types are included in the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1).
Standpipe and interior hose stations are included in License Renewal Application (LRA) Table 2.3.3.24, under the component type piping; strainer and filter housings are not subject to an AMR; hanger and piping support and seismic support for standpipes system piping are within the scope of license renewal and subject to an AMR included in LRA Section 2.4.4, Structural Bulk Commodities; hose connections and racks are within the scope of license renewal and subject to an AMR included in LRA Table 2.4.4-1; diesel fire pump exhaust silencer included in LRA Table 2.3.3-24 shows that under the component type muffler, traveling screens are within the scope of license renewal and subject to an AMR included in LRA Table 2.3.3-22, floor drains and curbs for fire-fighting water are not scoped within fire protection system, PNPP buildings have floor drains that will support the fire-fighting water and are included in LRA Table 2.3.3-25, Floor and Equipment Drains, dikes for oil spill confinement are within scope of license renewal and subject to an AMR included in LRA Table 2.4.2.26, Fuel Oil Storage Tank Dike, fire Document Title Revision/Date NUREG-0887 Safety Evaluation Report related to the operation of Perry Nuclear Power Plant, Units 1 and 2, Perry Nuclear Power Plant, Revision 23 to Updated Final Safety Analysis Report May 1982 and Supplements Numbers.-10.
UFSAR Perry Nuclear Power Plant, Updated Final Safety Analysis Report
- Section 8.3.3, Fire Protection for Cable Systems
- Section 9.5.1, Fire Protection System
- Appendix 9A, Fire Protection Evaluation Report Revision 23
8 wrap/electric raceway fire barrier are within scope of license renewal and subject to an AMR included in LRA Table 2.4.4-1 under line item fire barriers, and radiant energy shield are within scope of license renewal and subject to an AMR included in LRA Table 2.4.4-1 with AMR results in LRA Table 3.5.2-4, Bulk Commodities Summary of Aging Management Evaluation.
Based on its review, the staff did not identify the need for any additional information. The NRC staff confirmed that the fire protection system and associated components are included in LRA Tables 2.3.3-22, 2.3.3-25, 2.4.2.26, and 2.4.4-1. Based on the information provided in the LRA, the NRC staff did not identify any omissions by the applicant in the scoping and screening of the fire protection systems and components, according to 10 CFR 54.4(a).
LRA AMP B.2.1, 10 CFR, Appendix J Program Summary of Information in the Application. The LRA states that AMP B.2.1, 10 CFR Part 50, Appendix J Program, is an existing PNPP program that is consistent with the GALL-LR Report AMP XI.S4, 10 CFR Part 50, Appendix J.
Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LRReport AMP.
The staff also audited the description of the LRA 10 CFR Part 50, Appendix J provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Document Title Revision/Date LRPY-AMP-XI.S4 Aging Management Program Evaluation Results,10 CFR Part 50, Appendix J Program Revision 5 PAP-1120 PNPP Leak Testing Program Revision 10 NOP-ER-2008 Appendix J Test Program Revision 00 CR 2021-01866 RF018: LLRT - RWCU Isolation Valve PY-1G33F0039 High Leakage During Testing 03/15/2021 CR 2020-00889 Containment Isolation Valve 1G33-F039 LLRT Failure Mechanism Determination 02/05/2020 19-0246-001 1G33F0039 Valve Replacement 09/02/2020 ILRT-R-2009-04 Reactor Containment Building Integrated Leakage Rate Test Report 05/3-4/2009 Appendix J Cycle 14 Report Operating Cycle 14 & 1R14 LLRT Report 07/01/2013 200710364 Repair/Replacement Certification Record 200710364 Revision 00
9 LRA AMP B.2.2, Aboveground Metallic Tanks Program Summary of Information in the Application. The Aboveground Metallic Tanks Program is a new condition monitoring program that will manage the loss of material on the outside and inside surfaces of aboveground tanks in the scope of license renewal constructed on concrete or soil.
Section B.2.2 of the LRA states that the Aboveground Metallic Tanks Program is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M29, Aboveground Metallic Tanks Program, as described in interim staff guidance (ISG)-2012-02 Appendix M and as modified by ISG-2013-01. To verify this claim of consistency, the staff audited the LRA AMP.
At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document including the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, and confirmation process.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M29 Aging Management Program Evaluation Results-Perry Aboveground Metallic Tanks Program Revision 4 LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 CR-2015-14259 Diesel Fire Pump Fuel Oil Storage Tank 10/20/2015 Order 200573758 External Inspection and Leak test CST Tank 03/26/2021 Order 200843016 Perform Internal CST Inspection 01/19/2021 Order 20047724 Clean Condensate Storage Tank 05/17/2021 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, and confirmation Process, program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and the ePortal.
LRA AMP B.2.3, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program Summary of Information in the Application. LRA Section B.2.3 states that the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program. To verify this claim of consistency, the staff audited the LRA AMP.
10 Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant provided a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and reviewed the OE by reviewing the documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date NOP-CC-5710 ASME Section XI Inservice Inspection (ISI) Program Revision 6 09/21/2023 LRPY-AMP-XI.M1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program Revision 3 NOBP-LP-2001 Self-Assessment and Benchmarking Revision 31 06/29/2020 TAI-0507 Boiling Water Reactor Vessel and Internals Project (BWRVIP) Program Revision 17 10/10/2023 CR-2015-10559 2015 NRC PI&R Inspection: Question raised regarding the classification of the reactor pressure vessel (RPV)
Leak Detection Line 08/07/2015 ISEP Perry Operations Manual, Inservice Examination Plan Revision 24 01/12/2023 NOP-CC-5714 Review, Evaluation and Reporting of ISI or PSI NDE Data Revision 2 05/17/2019 LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 ATA-2020-15085 Monitor Quad Cities URI for Transferability 01/22/2021 ATA-2020-14736 Pre-NRC Inspection Self-Assessment on lnservice Inspection Activities - 1R18 03/04/2013 SN-SA-2013-0014 Snapshot Assessment of the ISI Program prior to 1R14 02/03/2013 SN-SA-2019-1319 Pre-NRC Inspection Self-Assessment on lnservice Inspection Activities - 1R17 01/05/2019 CR-2013-00478 Perry is not adequately implementing and institutionalizing OE information, including vendor recommendations and internally generated lessons learned 03/05/2013 CR-2015-04803 Indication Identified in H9 Shroud Support Plate to Reactor Vessel Wall Weld Revision 1 During the audit, the staff verified applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding program elements in the GALL-LR Report AMP.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.4, ASME Section XI, Subsection IWE Program Summary of Information in the Application. The LRA states that AMP B.2.4, ASME Section XI, Subsection IWE, is an existing program that is consistent with the program elements in GALL Report AMP XI.S1, ASME Section XI, Subsection IWE.
11 Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff observed the applicants search of its operating experience database using the following keywords/phrases: containment liner, moisture barrier, IWE examination, liner augmented examination, liner thickness loss, liner distress, liner discontinuities, liner irregularities.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.S1 Aging Management Program Evaluation Results-ASME Section XI, Subsection IWE Program Revision 4 GEH-RPT-7480-322315-KL1-ISI PNPP (P1R17) ISI Final Report Summary 2019 Spring Outage (GE Hitachi Nuclear Energy) 03/29/2019 NQI-1042-R22 Visual Examination of Pumps and Valves Bodies, Containment Surfaces, and License Renewal, One-Time Examination Components 01/23/2024 ISI-T23-T2400-5 Containment and Drywell Vessel (Interior and Exterior) Visual 05/26/2022 ISEP-R24 Perry Operation Manual, Inservice Examination Plan (ISEP) 01/12/2023 N/A PNPP Cycle 18/ Refueling Outage 18, Inservice Inspection Report.
05/10/2021 CR-2013-06563 CR Related to Drywell Interior from Elevation 630 up to ceiling were found to have degraded coating in accordance with ISI-T23-T2400-5 and NQI-1042.
04/25/2013 CR-2013-04105 CR Related to Containment Vessel Interior (Ele. 620 to 640 AZ 90-180, Under Order 200472272 (ISI-T23-010-1), several areas with degraded (e.g. flaking, peeling.) coating were identified.
03/20/2013 CR-2013-04102 Containment Vessel Interior from Ele. 620 to 640, AZ 20-90, under Order 200472272 (ISI-T23-009-1), several are with degraded (e.g., flaking, peeling) coating were identified.
03/20/2013 GEH-RPT-7480-329221-KL1-ISI Perry Nuclear Power Plant ISI Final Report (GE Hitachi Nuclear Energy) 03/25/2023 GEH-RPT-7480-320875-KL1-ISI Perry Nuclear Power Plant (P1R16) ISI Final Report Summary 2017 Spring Outage (GE Hitachi Nuclear Energy) 03/24/2017 N/A Perry 1R-15 ISI Final Report Spring 2015 (WesDyne International, Westinghouse Nuclear Services) 04/07/2015 P0059-014 Perry Nuclear Power Plant Fourteenth ISI Summary Report 08/09/2013 PYBP-LRP-0005 Perry Civil/Structure Scoping, Screening and Aging Management Review Revision 2 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program element(s) of the LRA AMP are consistent with the corresponding element(s) of the GALL-LR Report AMP.
During the audit, the staff made the following observations:
Drywell mechanical penetrations: PNPP plans to have the Fire Protection Program manage all structural commodities with Fire Barrier Function (FB).
LRA Table Items 3.5.1-30: PNPP plans not to use this Table 3.5.1 item for loss of preload of pressure-retaining bolting. Instead PNPP plans to use for loss of structural bolting preload aging effect LRA Table Item 3.5.1-88 in conjunction with LRA AMPs
12 B.2.43, Structures Monitoring program and ASME Section XI IWF Program, as applicable.
The review of ISI Summary Reports from 2013 thru 2023 (RFO14 thru RFO19) identified some minor degraded coatings as identified for example in CR-2013-04102, CR-2013-04105 and CR-2013-06563. However, the staffs review of the operating experience description of LRA B.2.4 noted that the description of plant-specific OE appeared to be adequate to support the stated conclusion. Any degraded/nonconforming conditions identified by the program would be captured in PNPPs corrective action program.
The staff also audited the description of the LRA AMP B.2.4 ASME Section XI, Subsection IWE Program, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRPLR.
LRA AMP B.2.5, ASME Section XI, Subsection IWF Program Summary of Information in the Application. The LRA states that AMP B.2.5 ASME Section XI, Subsections IWF Program, is an existing program with enhancement(s) that will be consistent with the program elements in GALL-LR Report AMP XI.S3, ASME Section XI, Subsections IWF. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff observed the applicants search of its operating experience database using the keyword R(P)V Support Skirt, Support Anchorage, Lubricant(s).
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI. S3 Aging Management Program Evaluation Results - ASME section XI, subsection IWF Program Revision 4 ISS-2600 Fabrication and Installation of Pipe Supports 08/20/1996 SP-44-4549-00 Installation of Safety Class Piping, and Safety Class and Non-safety Class Equipment 05/09/1975 NOP-CC-5730 Visual Examination Procedure for VT-1 and VT-3 Examinations of Hangers, Supports, Restraints and Pressure Retaining Bolting Revision 1 CR-2020-09393 Degraded Service Water Piping Support in Unit 2 Aux building 01/08/2021 CR-2019-02848 Damaged Spring Cans on 1B33F0060A HPU Supply and Return Lines 04/26/2019 CR-2013-18628 Errors in Visual Examination of Pipe Hanger, Support or Restrain (VT-3) Report No. 1042-13-094 12/20/2013 CR-2013-06770 ASME Section XI Examination of RPV Skirt Support Could Not Achieve Full Coverage 05/30/2013 CR-2013-04126 Found Damaged Hanger MK-1N27-H109 04/04/2013 CR-2017-03272 Pipe Support 1E12H0121 Bolt overstress 04/21/2017 CR-2016-09304 Reactor Water Clean Up (RWCU) pipe support 1G33H0240 Legacy Calculation Error 07/28/2016 CR-2016-13877 RWCU Support 1G33H0240 Legacy Calculation Error - Follow-up Results 12/30/2016 CR-2020-05833 Missing Fuel Lift Fatigue Evaluations for New Loads Plants 07/21/2020
13 During the audit, the staff verified the applicants claim that the preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program element(s) of the LRA AMP are consistent with the corresponding element(s) of the GALL-LR Report AMP XI.S3 or will be consistent after implementation of the identified enhancements.
The staff also verified the applicants claim that aspects of the scope of program, program element(s) not associated with the exception(s) identified in the LRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-LR Report AMP.
In addition, the staff found that for the parameters monitored or inspected, program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL-LR Report AMP XI.S3. The staff will consider issuing an RAI(s)/RCI(s) to obtain or confirm the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-LR Report AMP.
During the audit, the staff made the following observations:
Regarding past use of molybdenum disulfide (MoS2) on high-strength bolting, PNPP clarified that its construction specifications for safety related piping/component supports did not expressly call for use of MoS2, with SP-44 restricting the use of lubricants containing sulfur.
Regarding sliding surfaces, PNPP discussed revising its LRA AMP B.2.5 to indicate that it does not have any sliding surfaces whose effects of aging for loss of mechanical function would be managed and inspected by LRA AMP B.2.5 and AMR item 3.5.1-75, respectively.
Regarding reactor vessel (RV) support skirt inspections, PNPP discussed its planned revision to LRA AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program to manage the effects of aging for the skirt in accordance with LRA AMP B.2.3 ASME Section XI, Subsections IWF Program and relevant AMR table 3.5-1 items.
Component supports were reworked to as new condition. Even though they would meet the IWF acceptance criteria, PNPP may consider augmenting the support sample population to include additional supports as representative of the remaining population.
Fatigue evaluation of the RV Support Skirt is evaluated in LRA Section 4.3.1.1 Reactor Pressure Vessel. In its evaluation, PNPP considered effects of future OE involving upset condition on dynamic fuel lift fatigue, addressed in GE safety 2020 R0 condition report.
The staff also audited the description of the LRA AMP B.2.5 ASME Section XI, Subsection IWF Program provided in the UFSAR Supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP B.2.5 ASME Section XI, Subsection IWF Program. The staff will consider issuing (an) RAI(s)/RCI(s) to obtain the information necessary to verify/confirm the sufficiency of the UFSAR supplement program description.
14 LRA AMP B.2.6, ASME Section XI, Subsection IWL Program Summary of Information in the Application. The LRA states that AMP B.2.6, ASME Section XI, Subsection IWL Program, is an existing program with enhancement(s) that will be consistent with the program elements in GALL-LR Report AMP XI.S2, ASME Section XI, Subsection IWL.
At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff observed the applicants search of its operating experience database using the keyword:
annulus AND concrete.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date Item #37 TRP-042-01, Breakout Audit November 2023, Items 669, 670 12/01/2023 LRPY-OE-0001 Operating Experience Review Revision 3 PYBP-LRP-0006 Operating Experience Review 11/13/2023 LRPY-AMP-XI.S2 Aging Management Program Evaluation Results - ASME Section XI, Subsection IWL Program, Perry License Renewal Project Revision 4 PNP-079830 WO 200860119 Visual Examination of IWL 03/16/2023 (part of) WO 200561307 1R16 Walkdown, Maintenance Rule Evaluation Worksheet 04/10/2017 CR-2019-03629 Plant Underdrain, Water level has exceeded 573 04/18/2019 CR-2015-12810 Intermediate Building roof leakage at Unit 2 shield building 06/23/2015 CR-99-1625 Reactor Building (RB) Annulus 06/09/1999 CR-99-1624 Exterior Dome, Reactor Building (RB) Annulus 06/14/1999 DWG SS-305-503 Reactor Building-Containment Fix, Annulus Area. Plan Elevation 598-4 Concrete Outline (ISI Program use only) 01/20/1999 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program element(s) of the LRA AMP are consistent with the corresponding element(s) of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancement(s).
During the audit, the staff made the following observations:
It is not clear how PNPP plans to monitor potential cracking of the annulus concrete from reaction with aggregates, when there are no Table 2 AMR line items for the concrete fill-in annulus referencing LRA Table 1 line item 3.5.1-19. The staff will consider issuing RAIs and/or RCIs to obtain the necessary information and/or use a voluntary LRA supplement offered by the applicant to address issues identified in the audit.
The staff also audited the description of the LRA AMP B.2.6 ASME Section XI, Subsection IWL Program. provided in the UFSAR Supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
15 LRA AMP B.2.7, Bolting Integrity Program Summary of Information in the Application. The LRA states that AMP B.2.7 Bolting Integrity Program is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M18 Bolting Integrity. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff observed the applicants search of its operating experience database using the keyword:
submerged and bolting.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M18 Aging Management Program Evaluation Results Revision 4 TRP-019 1-29-24.PDF Breakout Audit Report November 2023 (Item # 37) 11/2023 N/A TRP-019 Follow Up AMP B.2.18 (Item # 677) 11/2023 N/A TRP-019 Follow up Leakage at underwater bolted joints (Item # 678) 11/2023 N/A TRP-019 Follow up Bolting Integrity (Item # 679) 11/2023 N/A TRP-019 Follow up Bolting Integrity (Item # 680) 11/2023 N/A TRP-019 Follow up Bolting Integrity (Item # 681) 11/2023 OE-2012-1413-1 to -4 NRC IN-15, Use of Seal Cap Enclosures to Mitigate Leakage from Joints that Use A-286 Bolts Closure 08-20-2012 WO#200513438 Diver-Clean Suppression Pool, Prefabricate Gaskets/
Assemblies, - Functional Location PY-1T21 (Ref. CR-2013-07375) 05-07-2013 CR-G202-2008-50704 Heat Exchanger 0G41-B001A Head Flange Leakage of 2 DPM (potential for bolting corrosion) 12-11-2008 CR-G202-2007-1785 RFO 11 ISI Order 200173602 UT Exam of 13 to 18 Body to Bonnet Studs.
04-07-2007 NOP-OP-1012 Material Readiness and Housekeeping Inspection Program Revision 12 ISEP Operations Manual - Inservice Inspection Plan Revision 23 97-010 Bolt Torquing (PNPP No. 10003, NEI-0362)
Revision 3 GMI-0021 General Torquing Revision 15 ISS-2000 Piping and Mechanical Equipment Installation Revision 11 SP-527 Inquiry Number 110483-300-JD Rev. 637 Sp-527-4549-00 Rev. XIV Control No. 101-1 thru 101-7 11-07/1983 SP-350 Inquiry Number 041583-300-MH Rev.#550 Conformed Specification 35-4549-00 Rev. X Control No.
101-1 thru 101-7 04-20/1983 EPRI TR-104213 Bolted Joint Maintenance & Applications Guide 12/1995 EPRI 1010639 Non-Class I Mechanical Implementation Guidelines and Mechanical Tools Revision 4 During the audit, the staff verified the applicants claim that the scope of program, monitoring and trending, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. Additionally, preventive actions, parameters monitored/(inspected) affected, detection of aging effects and parameters
16 acceptance criteria, program elements will be consistent after implementation of the identified enhancements.
During the audit, the staff made the following observations:
The applicant discussed potentially requesting an exception to the submerged bolting periodic inspection frequency of at least once every refueling cycle, as stated in GALL-LR. Inspection of submerged bolting would be performed on representative samples during each 10-year interval of the period of extended operation, as identification of leaks of submerged bolting is difficult to identify. (Such a request would need to be made through a supplement to the application.)
The applicant plans to enhance the existing bolting integrity program, as described in the current LRA B.2.7 (July 2023), by performing visual inspection of submerged bolting for the emergency water pumps, diesel and motor fire pumps, emergency service water screen wash pumps, and Spent Fuel Rack Grid structure (steel/raw water) for loss of material and loss of preload on a 10-year frequency.
The applicant plans to enhance the existing bolting integrity program as described in the current LRA B.2.7 (July 2023) by performing visual inspection of submerged bolting of the emergency core colling systems and reactor core isolation colling system suction strainer (stainless steel/treated water) in the suppression pool for loss of material and loss of preload on a 10-year frequency.
As the GALL-LR does not specify the type and frequency of the inspection to be conducted of the submerged bolting or bolting in inaccessible locations, the applicant plans to use the guidance of GALL-SLR. Accordingly, submerged closure bolting will be visually inspected during the maintenance activities. Bolt heads will be inspected when made accessible. Bolt threads will be inspected when the joints are disassembled. In addition, GALL-SLR guidance states that the inspection would include a representative sample of 20 percent of the population (for a material with its environment combination) up to a maximum of 25 bolt heads and threads over a 10-year period.
The staff also audited the description of the LRA AMP B.2.7 Bolting Integrity Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP LR.
LRA AMP B.2.8, Buried and Underground Piping and Tanks Program Summary of Information in the Application. The LRA states that AMP B.2.8, Buried and Underground Piping and Tanks Program, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M41, Buried and Underground Piping and Tanks, as revised by LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M41 Aging Management Program Evaluation Results - XI.M41 Buried and Underground Piping and Tanks Program Revision 5 NOP-ER-2007 Underground Piping and Tanks Integrity Program Revision 11 PTI-R35-P0002 Annual Structure to Soil Potential Surveys Revision 8
17 Document Title Revision/Date ISS-2000 Piping and Mechanical Equipment Installation Revision 11 NOP-ER-2007-01 As-Found Buried/Underground Piping Examination Report Revision 0 PTI-R45-P5199 Diesel Generator Fuel Oil Storage Tank Cleaning and Inspection Revision 0 PTI-R35-P0001 Cathodic Protection Monthly Rectifier and Anode Terminal Box Check Revision 6 CR-2013-18952 P11 Condensate Transfer & Storage Buried Pipe Coating Found to be Degraded and Disbonded in Excavation 11/26/2013 CR-2014-10690 ONI-ZZZ-6 Entry 06/19/2014 CR-2014-10684 Water Leak South of Fire Hydrant #37 06/19/2014 CR-2015-05016 PA-PY-15-01: Long Standing Unresolved Equipment Aux Boiler Fuel Oil Level Challenges 04/10/2015 CR-2016-11251 R35 Cathodic Protection Two Test Wells Found Not Meeting PTI-R35-P0002 Acceptance Criteria 09/23/2016 CR-2019-02683 Hydrant 22 Has Underground Leak in Hydrant House 03/22/2019 CR-2020-01366 Waterproofing Membrane for Service Water Pump House Damaged 02/21/2020 CR-2020-08181 Sink Hole Forming, Potential P54 Water Leak 10/22/2020 CR-2021-07304 Annual Cathodic Protection Survey Data Did Not Meet Acceptance Criteria 09/29/2021 CR-2022-08707 Cathodic Protection System Failed to Meet Maintenance Rule (a)(1) Goals After Performance of Annual Soil Structure Test 11/14/2022 SP-528-4549-00 Fabrication and Delivery of Safety Class Yard Piping -
Group IV 07/01/1974 SP-146-4549-00 Installation of Underground Fire Protection Water, Potable Water, and Miscellaneous Steel Piping 08/05/1974 SP-225-4549-00 Technical Requirements for Excavation and Backfill 12/08/1975 During the audit, the staff found that for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.
The staff also audited the description of the LRA Buried and Underground Piping and Tanks Program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA Buried and Underground Piping and Tanks Program. The staff will consider issuing RAIs to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
LRA AMP B.2.9, BWR Control Rod Drive Return Line Nozzle Program Summary of Information in the Application. The LRA states that AMP XI.M6, BWR Control Rod Drive Return Line Nozzle, is an existing program that is consistent with the program elements in NUREG-1801, GALL-LR Report AMP XI.M6, BWR Control Rod Drive Return Line Nozzle.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the staff conducted its review of the applicants methodology and operating experience
18 by reviewing documentation contained in the LRA and ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date L-24-020 Perry Nuclear Power Plant, LRA Supplement 2, 1 06/27/2024 LRPY-OE-001 Operating Experience Review 09/07/2023 P0059-0008 RFO8 ISI Summary Report 06/18/2001 P0059-014 RFO14 ISI Summary Report 08/09/2013 GEH-RPT-7480-322315-KL1-ISI P1R17 ISI Final Report Summary 03/29/2019 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
During the audit, the staff made the following observations:
The applicant stated that prior to initial operation, the Control Rod Drive System was modified to eliminate the return line to the reactor vessel and the control rod drive return line (CRDRL) nozzle was capped. Therefore, augmented inspections required by NUREG-0619, BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking: Resolution of Generic Technical Activity A 10, are not applicable.
The applicant stated and the staff confirmed that the CRDRL nozzle-to-vessel weld and the nozzle inner radius volumetric ultrasonic test (UT) examinations are performed at the frequency specified in ASME Section XI (2013 Edition), Subsection IWB, Table IWB-2500-1, Examination Category B-D. The CRDRL nozzle to safe-end and the nozzle safe-end-to-cap weld visual (VT-2) inspections are performed during the reactor pressure test performed each refueling outage.
The staffs operating experience review included review of a sampling of ISI reports. No reportable indications had been recorded in these examinations.
The staff also audited the description of the LRA AMP BWR Control Rod Drive Return Line Nozzle provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.10, BWR Feedwater Nozzle Program Summary of Information in the Application. The LRA states that AMP B.2.10, BWR Feedwater Nozzle Program, is an existing program with exception that is consistent with the program elements in GALL-LR Report AMP XI.M5, BWR Feedwater Nozzles.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date ML22006A167 Perry Nuclear Power Plant, Unit No. 1 - Authorization and Safety Evaluation for Alternative Request IR-063 (EPID L-2022-LLR-0005) 09/30/2022 LRPY-OE-001 Operating Experience Review Revision 3
19 Document Title Revision/Date LRPY-AMP-XI.M5 BWR Feedwater Nozzle Program Revision 3 N4A FINAL REPORT.PDF N4E FINAL REPORT.PDF N4F FINAL REPORT.PDF 007030 (1B13-N4C-KA).PDF 007020 (1B13-N4C-IR).PDF ASME Code,Section XI examination results of the feedwater nozzles N/A During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. The staff also verified the applicants claim that aspects of the detection of aging effects and monitoring and trending program elements not associated with the exception identified in the LRA are consistent with the corresponding program elements in the GALL-LR Report AMP.
During the audit, the staff made the followingobservations:
In lieu of inspecting 100 percent of the population of the feedwater nozzle to vessel welds and the feedwater nozzle inner radius welds, there is an existing NRC-approved alternative to sample a minimum of 25 percent of the population of each weld type during the current, fourth, 10-year ISI interval. The existing alternative is approved through May 17, 2019, which continues into the period of extended operation. The applicant noted that, prior to entering the subsequent 10-year ISI intervals, they will need to submit another alternative request for subsequent 10-year ISI intervals consistent with the request during the initial operating period or comply with the ASME Code requirements.
The applicant reported operating experience in which flaws were found in feedwater nozzle welds by the existing program and dispositioned as appropriate. These examples demonstrate that the existing BWR Feedwater Nozzle program adequately manages aging effects.
The staff also audited the description of the LRA BWR Feedwater Nozzle Program provided in the UFSAR supplement. Thestaff verified this descriptionisconsistent with the description provided in the SRP-LR Report.
LRA AMP B.2.11, BWR Penetrations Program Summary of Information in the Application. The LRA states that AMP B.2.11, BWR Penetrations, is an existing program with an enhancement that will be consistent with the program elements in GALL-LR Report AMP XI.M8, BWR Penetrations. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. The staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
20 Document Title Revision/Da te LRPY-AMP-XI.M8 Aging Management Program Evaluation Results - BWR Penetrations Program Revision 2 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of LRA AMP will be consistent with the corresponding elements of the GALL-LR Report AMP after implementation of the identified enhancement.
The staff also audited the description of the LRA BWR Penetrations provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.12, BWR Stress Corrosion Cracking Program Summary of Information in the Application. LRA Section B.2.12 states that the BWR Stress Corrosion Cracking Program is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M7, BWR Stress Corrosion Cracking. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant provided a presentation on the process used to identify and evaluate the pertinent OE. Afterward, the staff conducted its review of the applicants methodology and reviewed the OE by reviewing the documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M7 Perry License Renewal Project - BWR Stress Corrosion Cracking Revision 2 LRPY-AMP-XI.M1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program Revision 3 ISEP Perry Operations Manual, Inservice Examination Plan Revision 24 01/12/2023 NOP-CC-5714 Review, Evaluation and Reporting of ISI or PSI NDE Data Revision 2 05/17/2019 LRPY-OE-001 Operating Experience Review Revision 3 CR-2013-09049 Drywell Unidentified Leak Rate Action Level 2 (Yellow) Entered per PYBP-SITE-0029 06/11/2013 CR-2014-14964 RX Recirc Sample Cooler Failure Analysis 09/26/2014 CR-2015-01439 Liquid Penetrant Pre-Service Examination Reveals Unacceptable Indication 02/03/2015 CR-2016-06372 2016 NRC Mod/50.69 Inspection: Depth of Indications Found in Class 1 Components Not Documented 05/05/2016 CR-2016-06648 EPRI Issuance of NDE 20160509-001 Alert Letter: Industry NDE Evaluation of the 2016 Calvert Cliffs Operating Experience (OE)
Related to Dissimilar Metal Weld Examination of Mitigated Alloy 600/82/182 Welds with the Mechanical Stress Improvement 05/11/2016 CR-2017-03823 Reactor Water Chloride and Sulfate Excursion During Startup from 1R16 04/04/2017
21 During the audit, the staff verified applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding program elements in the GALL-LR Report AMP.
The staff also audited the description of the LRA AMP provided in the UFSAR Supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.13, BWR Vessel ID Attachment Welds Program Summary of Information in the Application. The LRA states that AMP XI.M4, BWR Vessel ID Attachment Welds, is an existing program that with an enhancement and an exception, is consistent with the program elements in NUREG-1801 (GALL-LR Report) AMP XI.M4, BWR Vessel ID Attachment Welds.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the operating OE review, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date L-24-020 Perry Nuclear Power Plant, LRA Supplement 2, Attachment 51 6/27/2024 LRPY-OE-001 Operating Experience Review 9/7/2023 LRPY-AMP-XI.M4 AMP Evaluation Results - BWR Vessel ID Attachment Welds Revision 4 P1059-015 RFO15 ISI Summary Report 6/22/2015 P0059-014 RFO14 ISI Summary Report 8/9/2013 P0059-0008 RFO8 ISI Summary Report 6/18/2001 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. The staff also verified the applicants claim that aspects of the detection of aging effects and monitoring and trending, program elements not associated with the exception identified in the LRA and Supplement 2 are consistent with the corresponding program elements in the GALL-LR Report AMP or will be consistent after implementation of the enhancement identified in the LRA.
During the audit, the staff made the following observations:
The applicant stated in the LRA, in Table 3.1.1, that PNPP does not have nickel alloy vessel shell attachment welds exposed to reactor coolant in the reactor vessel, internals, and reactor coolant systems, lessening the susceptibility to SCC.
The staff verified in the examination results of several recent ASME Code Section XI in-service inspections that there were no NDE indications reported.
The staff requested confirmation from the applicant that the use of industry guidance in lieu of ASME Code requirements and NRC-approved guidance, while currently permitted by an alternative approved under 10 CFR 50.55a(z)(1), will not be automatically authorized for the license renewal period. The applicant submitted LRA Supplement 2
22 with revised text that confirmed the applicants understanding of the need to either comply with the ASME Code requirements and NRC approved BWRVIP-48 guidance, or to request an alternative to those requirements.
The staff also audited the description of the LRA BWR Vessel ID Attachment Welds provided in the UFSAR supplement. The staff made the following observations:
The UFSAR supplement states, The BWR Vessel ID Attachment Welds aging management program is an existing condition monitoring program that includes the inspection and evaluation recommendations within BWRVIP-48 and the requirements of ASME Code,Section XI, Subsection IWB (Appendix A).
In LRA Appendix C, Section C.1, Response to BWRVIP Applicant Action Items, the applicant cites BWRVIP-48, Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines, Revision 1, among documents credited for PNPP license renewal. The staff noted that BWRVIP-48, Rev. 1 is not a staff-approved report (Appendix C).
As the applicant acknowledged in LRA Supplement 2, prior to entering the subsequent 10-year ISI intervals, PNPP would have to either comply with the ASME Code requirements and NRC approved BWRVIP-48 guidance, or request [NRC approval of an alternative to] the requirements consistent with what PNPP has done during the initial operating period.
The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP BWR Vessel ID Attachment Welds. Specifically, the staff observed discrepancies among Appendix A, which credits BWRVIP-48 and ASME Section XI; Appendices B and C, which credit BWRVIP-48, Rev.
1 in place of BWRVIP-48-A and ASME Section XI; and LRA Supplement 2, which acknowledges that use of BWRVIP-48, Rev. 1 is an exception to the GALL Report guidance to use BWRVIP-48-A and ASME Section XI to manage degradation in BWR vessel ID attachment welds. The staff will consider issuing an RAI to confirm the information necessary to verify the sufficiency of the UFSAR supplement program description.
LRA AMP B.2.14, BWR Vessel Internals Program Summary of Information in the Application. The LRA states that AMP B.2.14, BWR Vessel Internals Program, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M9, BWR Vessel Internals.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date ML22006A167 Perry Nuclear Power Plant, Unit No. 1 - Authorization and Safety Evaluation for Alternative Request IR-063 (EPID L-2022-LLR-0005) 09/30/2022 LRPY-OE-001 Operating Experience Review Revision 3 LRPY-AMP-XI.M9 BWR Vessel Internals Program Revision 4 BWRVIP-139NP-R1-A BWR Vessel and Internals Project: Steam Dryer Inspection and Flaw Evaluation Guidelines 11/2017
23 During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, detection of aging effects, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
The staff also verified the applicants claim that aspects of the scope of program, monitoring and trending, and acceptance criteria program elements not associated with enhancements identified in the LRA are consistent with the corresponding program elements in the GALL-LR Report AMP.
During the audit, the staff made the followingobservations:
The discussion of the use of BWRVIP-139-R1-A to manage aging effects on steam dryer components noted by Action Item BWRVIP-139-R1-A(2) is captured in the applicants second supplement (ML24180A010) to the LRA.
The staff reviewed operating experience in the LRA and during the audit. The staff noted instances of inspections finding age-related degradation in components managed by the existing BWR Vessel Internals program. In all the examples, the aging effect was addressed by the applicants corrective action program.
The staff also audited the description of the LRA BWR Vessel Internals Program provided in the UFSAR supplement. Thestaff verified this descriptionisconsistent with the description provided in the SRP-LR Report.
LRA AMP B.2.15, Closed Treated Water Systems Program Summary of Information in the Application. The LRA states that AMP B.2.15, Closed Treated Water Systems Program, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M21A, Closed Treated Water Systems. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M21A Aging Management Program Evaluation Results - Closed Treated Water Systems Program Revision 4 PYPM-OC-0002 Closed Cooling and Auxiliary Systems Strategic Chemistry Plan Revision 0 CHI-0046 Cooling Water Corrosion Monitoring and Inspections Revision 3 REC-0104 Chemistry Specifications Revision 49 NOP-OP-3603 Recording and Trending of Chemistry Data Revision 2 CR-2015-04575 The Closed Cooling Systems Chemistry Department monthly performance indicator is RED for March 2015.
04/03/2015 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, and detection of aging effects program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. In addition, the staff found that for the parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program element, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-LR Report AMP.
The staff will consider issuing an RAI to obtain the information necessary to verify whether these
24 program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.
The staff also audited the description of the LRA Open-Cycle Cooling Water System Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.16, Compressed Air Monitoring Program Summary of Information in the Application. The LRA states that AMP B.2.16, Compressed Air Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M24, Compressed Air Monitoring. To verify this claim of consistency, the staff audited the LRA AMP.
During the audit, the staff also reviewed enhancements associated with this AMP. The staff will document its review of the enhancements in the SE. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document including the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, and confirmation process.
Audit Activities. The table below lists the documents that were reviewed by the staff and were found relevant to the Compressed Air Monitoring Program. These documents were provided by the applicant on the ePortal. The staff will document its review of relevant operating experience in the SE.
Document Title Revision/Date LRPY-AMP-XI.M24 Perry License Renewal Project/ Nuclear Generating Plant Aging Management Program Evaluation Results Compressed Air Monitoring Program Revision 5 ANSI/ISA 7.0.01 S7.3 Quality Standard for Instrument Air 11/12/1996 ASME-American Society of Mechanical Engineers Performance Testing of Instrument Air Systems in Light Water Reactor Power Plants Division 2, Part 28 Revision of ASME OM-2012 PY-CEI/NRR-0971-L Instrument Air Supply Problems 02/22/1989 PTI-R44-P001 A Division 1 Standby Diesel Generator Starting Air System Revision 17 PTI-R44-P001 B Division 2 Standby Diesel Generator Starting Air System Revision 19 PTI-R44-P001 C Division 3 HPCS Diesel Generator Starting Air System Revision 13 EPRI TR-103595 Report of the Instrument Air Working Group 04/1994 NEI 14-12 Aging Management Program Effectiveness Revision 0 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, acceptance criteria, and corrective actions program elements of the LRA AMP is consistent with the corresponding element of the GALL-LR Report AMP.
During the audit, the staff verified the applicants claim that the parameters monitored or inspected, monitoring and trending, and detection of aging effects program elements of the LRA AMP will be consistent after implementation of the identified enhancements.
For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants
25 methodology and operating experience by reviewing documentation contained in the LRA and ePortal. The staff will evaluate any identified plant-specific operating experience in the SE.
The staff also audited the description of the LRA AMP Compressed Air Monitoring program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-LR Report.
LRA AMP B.2.17, Environmental Qualification (EQ) of Electrical Components Program Summary of Information in the Application. The LRA notes that AMP B.2.17, Environmental Qualification (EQ) of Electrical Components Program, is an existing program that is consistent with the program elements in GALL-LR Report AMP X.E1, Environmental Qualification (EQ) of Electric Components.
Audit Activities. An onsite audit was performed from October 24-25, 2023. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-X.E1 Aging Management Program Results - Environmental Qualification (EQ) of Electrical Components Program Revision 4 NOP-CC-5301 Environmental Qualification Program Revision 4 NEI-0701 Environmental Qualification Process Revision 18 EQ-203 Qualified Life of Raychem (TE Connectivity) NMCK8 and NHVT electrical connection kits with reformulated BBIT-N material Revision 8 (Draft)
ATA-2023-21353 Verify References of EPRI-1558 in Environmental Qualification Calculations at Perry 12/14/2023 (date created) 1/11/2024 (date provided)
EQ-178 Qualified Life of NAMCO EC210 Series Connectors with cable Revision 1 (Draft)
EQ-016 Qualified Life of PYCO Temperature Elements Revision 5 (Draft)
GMI-0008 Pressure Relief Device Bench Testing Revision 24 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored/inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LRReport AMP.
During the audit, the staff made the followingobservation:
The staff identified that Table 3.6.2, Electrical Commodities Summary of Aging Management Evaluation, of the LRA did not include line items for electrical equipment subject to 10 CFR 50.49 EQ requirements in accordance with VI.B.L-05 of the GALL-LR Report. In response to a breakout question on the topic, the applicant agreed to add two line items for EQ to Table 3.6.2 in a future supplement, one for various metallic materials (Electrical Continuity) and one for various polymeric materials (Insulate Electrical).
The staff also audited the description of the LRA EQ of Electrical Components Program provided in the UFSAR supplement. The staff verified this descriptionisconsistent with the description provided in the SRP-LR.
26 LRA AMP B.2.18, External Surfaces Monitoring of Mechanical Components Program Summary of Information in the Application. The LRA Section B.2.18, External Surfaces Monitoring of Mechanical Components Program is described as a new condition monitoring program that will be consistent with the program elements in the GALL-LR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components, as revised by LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation. At the time of the audit, the applicant had not fully developed the documents necessary to implement this new program, and the staffs audit only addressed the program elements described in the applicants basis document.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M36 Aging Management Program Evaluation Results -
External Surfaces Monitoring of Mechanical Components Program Revision 4 LRPY-OE-001 Operating Experience Review Revision 3 Dwg 302-0605 Nuclear Boiler [showing flex hoses from P52 (safety related air system) to safety relief valves NA CR-2011-95414 SRV air supply leak on SRV-051B 05/25/2011 CR-2017-03192 Air supply leak to SRV 1B21F-041B 03/21/2017 CR-2021-02192 Hissing noise from flex hose on SRV ks 0324/2021 CR-2021-02296 Leak on air flex hose to SRV-051B discovered while repairing flex hose to SRV-041B 03/27/2021 CR-2023-02255 Air leak on flex hose to SRV-041B 03/24/2023 CR-2023-02318 Air leak on flex hose to SRV-047B 03/26/2023 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions program elements of the LRA AMP will be consistent with the corresponding program elements in the GALL-LR Report AMP.
The staff also reviewed the UFSAR supplement in LRA Section A.1.18, External Surfaces Monitoring of Mechanical Components Program. The staff verified this description is consistent with the description provided in SRP-LR Table 3.0-1, as modified by LR-ISG-2012-02.
LRA AMP B.2.19, Fatigue Monitoring Program Summary of Information in the Application. The LRA states that AMP B.2.19, Fatigue Monitoring, is an existing preventive program with enhancements that is consistent with the program elements in GALL Report (Revision 2) AMP X.M1, Fatigue Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SE.
At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the program elements described in the applicants basis document. The staff will address issues identified but not resolved in this audit report in the SE.
27 Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 09/07/2023 PYBP-LRP-0006 Operating Experience Review Revision 3 09/07/2023 LRPY-AMP-X.M1 Aging Management Program Evaluation Results - Fatigue Monitoring Program Revision 4 05/11/2023 LRPY-TLAA-002 TLAA - Metal Fatigue Revision 6 05/16/2023 CR-2012-03259 Reactor Vessel Cycle Monitoring 03/01/2012 CR-2013-08592 Design Basis Assessment Report (DBAR) Indicator for Thermal Cycle Tracking Is Yellow for First Triennial Period 12/12/2013 CR-2015-05582 Perry Cycle Counting DBAR Remains Yellow 04/21/2015 ECP 09-0792-001 Transition from Cycle Counting to Fatigue Monitoring Revision 0 FTI-F0002 Vessel Cycle Duty Monitoring Revision 5 06/11/2020 Calculation B13-029 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 0 11/10/2022 Structural Integrity Associates (SIA) 1000488.402 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 4 06/30/2021 Calculation B13-025 Fatigue Update for Perry Nuclear Power Plant from 10/01/16 to 04/13/2021 Revision 1 12/21/2022 SIA 2001140.301 Fatigue Update for Perry Nuclear Power Plant from 10/01/16 to 04/13/2021 Revision 3 10/25/2022 Calculation B13-003 Projected Reactor Cycles and Fatigue Effects on Limiting Components: Closure Flange, Feedwater Nozzle, Control rod Drive Penetration, Water Level Instrument Nozzle, Core Spray Bracket and Steam Dryer Bracket Revision 0 02/13/2009 SIA 0800184.301.R0 Cycle Projections and Fatigue Usage Calculations Revision 0 10/13/2008 Calculation B13-036 Cycle Based Fatigue Report for the Transient and Fatigue Monitoring System at the Perry Nuclear Power Plant Revision 4 11/10/2022 SIA FP-PERY-403 Cycle Based Fatigue Report for the Transient and Fatigue Monitoring System at the Perry Nuclear Power Plant Revision 4 08/31/2022 During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP or will be consistent after implementation of the identified enhancements.
28 The staff found that, for the scope of program program element, sufficient information was not available to verify whether it was consistent with the corresponding program element of the GALL Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP.
During the audit, the staff made the following observation.
In relation to the scope of the program program element, enhancement 1 of the Fatigue Monitoring AMP states that the station implementing procedures will be updated to clarify the scope of the Fatigue Monitoring Program. However, it is not clear to the staff whether the clarification in the implementing procedures will be consistent with the scope of the fatigue time-limited aging analyses in the LRA, which credit the Fatigue Monitoring AMP, such as LRA Sections 4.3.1 (Class 1 fatigue analysis), 4.3.3 (environmental fatigue analysis), 4.3.4 (reactor vessel internals fatigue analysis), 4.3.5 (intermediate high energy line break location analysis), 4.5.1 (containment vessel fatigue analysis) and 4.5.2 (containment piping penetration fatigue analysis).
The staff also audited the description of the LRA Fatigue Monitoring AMP provided in the UFSAR supplement. The staff verified this description is consistent with the acceptance criteria provided in SRP-LR Section 3.1.2.5.
LRA AMP B.2.20, Fire Protection Program Summary of Information in the Application. The license renewal application (LRA) states that Aging Management Program (AMP) B.2.20, Fire Protection Program, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M26, Fire Protection. The applicant considered LR-ISG-2021-02 as part of operating experience. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the description of the enhancements in the LRA and the applicants basis document.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the Fire Protection program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M26 Aging Management Program Evaluation Results -
Fire Protection Program Revision 3 LRPY-OE-001 Operating Experience Review Revision 3 OTCOMBINEDP54 (Halon)
Fire Protection Halon System Revision 1 OTCOMBINEDP54 (CO2)
Fire Protection (Carbon Dioxide) System Revision 1 SP-2100 Detailed Specifications for Penetration Seals, Raceway Fire Barriers, and Radiant Heat Energy Shields Revision 2 PTI-P54-P0075 Appendix R Fire Wrap Inspection Revision 5 PTI-P54-P0069 Process Computer Room CO2 System Functional Test Revision 6 PTI-P54-P0068 RX Recirc Pumps CO2 Systems Detection/Operability Test Revision 7 PTI-P54-P0056 Penetration Seal Visual Inspection Revision 11
29 Document Title Revision/Date PTI-P54-P0054A Refuel Outage Fire Barrier Visual Inspection Revision 2 PTI-P54-P0054 Fire Barrier Visual Inspection Revision 6 PTI-P54-P0044 Fire Door Verification Revision 17 PTI-P54-P0041 Semiannual Fire Door Inspection Revision 17 GMI-0077 Installation, Removal, and Repair of Foam Penetration Seals Revision 2 GMI-0076 Installation, Removal and Repair of Non-Foam Penetration Seals Revision 2 FPI-A-I01 Fire Rated Assemblies and Detector Inspection Guidelines Revision 3 FPI-A-I02 Fire Suppression Equipment Inspection Guidelines Revision 3 PAP-1910 Fire Protection Program Revision 45 CR-2019-02455 P54 Fire Barrier in need of repair. Pyrocrete.
03/18/2019 CR-2019-01234 Fire Barrier does not meet FPI-A-I01 guidelines per Section 6.4 Barriers Inspection Guidelines 02/10/2019 CR-2018-06012 CO2 tank 6 high pressure 07/01/2018 CR-2017-07629 Unplanned Fire Barrier Impairment for Baseline Inspection 07/21/2017 CR-2017-05605 MS-C-17-05-31, Finding - Fire Protection Barrier Issues 05/16/2017 CR-2017-03345 Unplanned Fire Suppression Impairment for Reactor Recirc Pump B CO2 System 03/23/2017 CR-2016-07846 Unplanned Fire Impairment / Unresolved Safety Concern 06/17/2016 CR-2016-03179 Unplanned Impairment for Appendix R Fire Wrap 03/08/2016 CR-2016-03149 Unplanned Impairments for Appendix R Fire Wrap 03/07/2016 CR-2015-16959 NRC ID: Hole in barrier between Unit 2 Div 1 and Div 2 DC switchgear rooms 12/18/2015 CR-2015-11946 Open conduit passing through Fire Barrier 08/10/2015 CR-2015-11506 Fire door for ECP 15-0028-003 did not latch as required 09/012015 CR-2015-05607 2 Cable penetration opening identified during work walk down in CC 559 Nuclear Closed Cooling Pump Room 04/22/2015 CR-2013-14122 Deficiencies identified during MR walkdown of Htr Bay 09/11/2013 512-0078-00006 Lead Shielding Plan 11/18/2011 SP-2300 Insulation of Plant Systems Revision 1 No. 00-5022 Engineering Change Package Revision 2 SP-2100 Detailed Specifications for Penetration Seals, Raceway Fire Barriers, and Radiant Heat Energy Shields Revision 2 07A-0001-00000 Drawing - Penetration Seals 01/23/1984 07A-0003-00000 Drawing - Penetration Seals 02/05/1984 07A-0008-00000 Drawing - Penetration Seals 01/26/1984 CR-00-2600 Pyrocrete deficiencies 08/24/2000 CR-99-2133 Periodic inspection of Pyrocrete 08/31/1999 ECN-28328-98-48 Engineering Change Note - Penetration Seals Revision A Email Penetration seal acceptance criteria 0227/2024 N/A Table 722.2.1.1 of International Building Code N/A N/A Pyrocrete Thermal Transmission 11/03/1992 N/A Pryocrete 241 Assembly Illustrations & Data 02/2015
30 Document Title Revision/Date LRPY-CAMR-001 Structural Material/Environment/Aging Effect Bases Report Revision 6 During the audit, the staff verified that for the program elements that the applicant declared were consistent, the preventive actions, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
In addition, the staff found that for the scope of the program and parameters monitored or inspected program elements, sufficient information was not available to determine whether they are consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether the program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.
During the audit of the OE program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the LRA Fire Protection program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-LR Report.
LRA AMP B.2.21, Fire Water System Program Summary of Information in the Application. The LRA states that AMP B.2.21, Fire Water System Program, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M27, Fire Water System, revised by LR-ISG-2012-02 and LR-ISG-2013-01. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the description of the enhancements in the LRA and the applicants basis document.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the Fire Water System program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M27 Aging Management Program Evaluations Results - Fire Water System Program Revision 3 SOI-P54 (WTR)
Fire Protection - Water Revision 30 PTI-P54-P0065A Water Spray Flow Test for Unit 2 Interbus Transformer A Revision 8 PTI-P54-P0063 Water Spray Flow Test for the Unit 1 Main Transformers and ISO Phase Bus Duct Revision 15 PTI-P54-P0029 Fire Hydrant Semiannual Inspection Revision 13 PTI-P54-P0004 Annual Hydrant Flow and Hose Replacement Revision 8 PTI-P54-P0003 Fire Main Flow Test Revision 10 PMI-0072 Diesel Fire Service Pump Preventive Maintenance Revision 8 PAP-1910 Fire Protection Program Revision 45 FIP-A-I02 Fire Suppression Equipment Inspection Guidelines Revision 3 FIP-A-A02 Periodic Fire Inspections Revision 6
31 Document Title Revision/Date Work Order (WO) 200860058 Replaced Valve 08/04/2021 WO 200857295 Through wall pipe leak 06/16/2021 WO 200848874 Cracked pipe due to pipe vibration from relief valve opening and closing 04/12/2021 WO 200790095 Possible leak in Fire Water System 06/18/2019 WO 200786194 Damaged fire service jockey pump 04/24/2019 WO 200783611 Underground leak inside hydrant house 04/15/2019 WO 200774299 Water bubbling and puddle around hydrant 12/27/2018 WO 200768778 Pin hole through wall leak downstream of motor fire pump relief valve 10/07/2018 WO 200765093 Six-inch fire water pipe separated in Auxiliary Boiler Fuel Oil Pump House 09/10/2018 WO 200745736 Hydrants not draining, contain water and ice 03/30/2018 WO 200734146 Water spray flow test for Unit 1 Interbus Transformer A 10/08/2019 (test date)
WO 200728875 Dime size through wall pipe leak 09/06/2017 WO 200727052 Erosion in two locations on spool piece (one with sight glass) downstream of relief valve 10/12/2018 WO 200678169 Clean nozzles during water spray flow test of Station Transformers 04/07/2016 WO 200608461 Leak in underground piping upstream of hydrant 09/03/2014 WO 200588395 Frozen fire protection piping 01/14/2014 CR-2022-06177 Pin hole leak found on firewater piping 08/10/2022 CR-2020-03269 Fire jockey pump system leakage exceeds 10 gpm 04/15/2020 CR-2020-01941 Possible fire water piping leak 03/08/2020 CR-2019-10284 Deluge supply piping rusty, scaly, and has loose rust and paint 12/10/2019 CR-2019-10149 Clogged/obstructed nozzles in fire protection deluge system 12/05/2019 CR-2019-03738 Jockey fire pump casing failed in two places 04/22/2019 CR-2018-08805 Motor fire pump pin hole leak downstream of pump relief valve 10/072018 CR-2017-09178 Through-wall pipe leak 09/05/2017 CR-2015-15970 Fire water pipe leak above hose reel 11/24/2015 CR-G202-2008-39696 Underground piping with pitting, below acceptable wall thickness 05/02/2008 CR-G202-2007-24354 Collective significance review of fire protection underground piping condition 07/30/2007 71-0205-00001 Drawing - Foam Chamber 12/1978 ONI-ZZZ-6 Leak in Underground Piping (In-Field Reference)
Revision 7 914-0001 Drawing - Fire Protection Revision 1 12-0482-001 Engineering change package - Incomplete drainage of pre-action piping Revision 0 CR-2012-09439 Examination scope of fire protection piping 06/07/2012 PMI-0072 Diesel Fire Service Pump Preventive Maintenance Revision 8 SOI-P54 (WTR)
Fire Protection System - Water (In-Field Reference)
Revision 30 200727052 Erosion in two locations on spool piece downstream of relief valve 2018 CR-2017-08251 Erosion of piping on second spool piece of Motor Driven Pump Relief Valve 08/09/2017 914-0004 Drawing - Fire Protection Revision 0 22-0160-00000 Drawing - Jockey Pump 06/30/2009
32 During the audit, the staff verified that for the program elements that the applicant declared was consistent, the preventive actions, monitoring and trending, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
The staff also verified the applicants claim that aspects of the detection of aging effects and acceptance criteria program elements not associated with the enhancements identified in the LRA are consistent with the corresponding program elements in the GALL-LR Report AMP.
In addition, the staff found that for the scope of the program, and parameters monitored or inspected program elements, sufficient information was not available to determine whether they are consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether the program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.
During the audit of the OE program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate the identified plant-specific operating experience in the SER.
The staff also audited the description of the LRA Fire Water System Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-LR Report.
LRA AMP B.2.22, Flow-Accelerated Corrosion Program Description Summary of Information in the Application. The LRA states that AMP B.2.22, Flow-Accelerated Corrosion Program is an existing condition monitoring program that, after completing specified enhancements, will be consistent with the program elements in the GALL-LR Report AMP XI.M17, Flow-Accelerated Corrosion as revised by LR-ISG-2012-01, Wall Thinning Due to Erosion Mechanisms.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M17 Aging Management Program Evaluation Results - Flow-Accelerated Corrosion Program Revision 4 LRPY-OE-001 Operating Experience Review Revision 3 NOP-ER-2005 Flow-Accelerated Corrosion Program Revision 9 PYPM-OC-0001 Strategic Chemistry Plan Revision 5 CR-2017-04246 Elevated iron in RWCU shown to be due to flow-accelerated corrosion in the carbon steel piping under hydrogen water chemistry NA CR-2019-02332 Flow-accelerated corrosion exams on RWCU pipe NA CR-2021-01903 RWCU regen heat exchanger shell side pipe unacceptable for continue service NA During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions program elements of the LRA AMP are consistent with the corresponding elements in the GALL-LR Report AMP or will be consistent after implementation of the enhancements identified in the LRA.
33 During the audit, the NRC staff made the following observation:
BWRVIP-205 included Perry as a Category A plant with very low predicted wall loss and very limited susceptibility to bottom head drain line wall thinning due to flow-accelerated corrosion. However, the above document has not been updated since 2008 and does not include recent industry operating experience regarding this piping. In addition, the site considers any volumetric examination of this piping to be impractical due to limited access from control rod drive interferences.
The staff also reviewed the UFSAR supplement in LRA Section A.1.22, Flow-Accelerated Corrosion Program. The staff verified this description is consistent with the description provided in the SRP-LR Table 3.0-1, as revised by LR-ISG-2012-01.
LRA AMP B.2.23, Fuel Oil Chemistry Program Summary of Information in the Application. The LRA states that AMP B.2.23, Fuel Oil Chemistry, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M30, Fuel Oil Chemistry. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SE.
Audit Activities. During its audit, the staff reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the Fuel Oil Chemistry Program. These documents were provided by Perry. The staff will document its review of this information in the SE.
Document Title Revision/Date Report NO. XCELMO 00017-REPT-069 Perry License Renewal Project Aging Management Program Evaluation Results Fuel Oil Chemistry Revision 3 Technical Specification 5.5.9 Docket No. 50-440 Diesel Fuel Oil Testing Program Revision 146 PYPM-OC-0003 Diesel Fuel Oil Strategic Plan Revision 0 Procedure CHI-0004 System Chemical Treatment Revision 20 REC-0104 Chemistry Specifications Revision 51 LR Boundary Drawing 302-0352 Diesel Generator Fuel Oil Revision 0 CR 2015-13758 Condition Report 2015-13758 Out of Specification Water and Sediment of Division 1 Fuel Oil Storage Tank Annual Sample 10/12/2015 During the audit, the staff verified the applicants claim that the scope of program parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LRReport AMP.
During the audit, the staff verified Perrys claim that the preventive actions and detection of aging effects program elements of the LRA AMP will be consistent after implementation of the
34 identified enhancements with the corresponding elements of the GALL-LR Report AMP. The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified that the description is consistent with the description in the GALL-LR Report.
LRA AMP B.2.24, Fuse Holders Program Summary of Information in the Application. The LRA notes that AMP B.2.24, Fuse Holders, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.E5, Fuse Holders. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.E5 Aging Management Program Evaluation Results - Fuse Holders Program Revision 3 LRPY-OE-0001 Operating Experience Review Revision 3 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptancecriteria, and corrective actions program elements of the LRA AMP will be consistent with the corresponding elements of the GALL-LRReport AMP.
During the audit, the staff made the following observations:
During its review of the Perrys Fuse Holders AMP basis document (i.e., LRPY-AMP-XI.E5, Revision 3), the staff identified that some of the AMP elements such as the Detection of Aging Effects and the Acceptance Criteria were not consistent with the corresponding elements in the GALL-LRReport AMP XI.E5. The Detection of Aging Effects element did not include contact resistance testing or other method of testing for the metallic clamp of the fuse holders; and the Acceptance Criteria element did not provide the acceptance criteria for the thermography or contact resistance testing when either test is used. In response to the staffs breakout questions, the applicant will revise the affected AMP elements including the Detection of Aging Effects and Acceptance Criteria elements in LRPY-AMP-XI.E5 to address the identified discrepancy between the Fuse Holders AMP and the GALL-LRReport AMP XI.E5. The applicant confirmed that the revised Fuse Holders AMP basis document will be consistent with GALL-LRReport AMP XI.E5 and will be addressed in Supplement 4 which is expected to be submitted on August 9, 2024.
The staff also audited the description of the LRA Fuse Holders provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR.
LRA AMP B.2.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program Summary of Information in the Application. The LRA states that AMP B.2.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M38, Inspection
35 of Internal Surfaces in Miscellaneous Piping and Ducting Components, as revised by LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M38 Aging Management Program Evaluation Results -
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program Revision 4 LRPY-MAMR-001 Material/Environment/Aging Effect Bases Report Revision 3 During the audit, the staff verified the applicants claim that the preventive actions, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
In addition, the staff found that for the scope of program, parameters monitored or inspected, and detection of aging effects program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.
The staff also audited the description of the LRA Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program provided in the UFSAR supplement.
The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program. The staff will consider issuing RAIs to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
LRA AMP B.2.26, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Program Summary of Information in the Application. The LRA states that AMP B.2.26, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing condition program that will be consistent with the program elements in GALL-LR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling)
Handling Systems. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA/LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
36 The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M23 AMP Management Program Evaluation Results -
Inspection of Overhead Heavy Load and Light Load (related to Refueling) Handling Systems Program Revision 3 CR-2010-77794 Bolt on bearing caps found loose.
06/04/2010 CR-2014-00793 Frayed strands on Polar Crane Aux. Hoist wire rope.
02/14/2014 CR-2014-12476 FHB Crane Main Hoist Overspeed switch shaft rotates without hoist drum shaft rotation.
07/31/2014 CR-2014-13952 Vibration and movement observed on bearing cap and indicator brackets of Fuel Handling Building Crane.
09/04/2014 CR-2014-12517 FHB Crane was used to perform a heavy load lift without reliable single-proof-protection features.
08/01/2014 CR-2015-05290 Walkdown and investigation area for improvement opportunity 02/15/2015 CR-2015-15519 Improvement opportunities identified Fuel Handling Building Crane Vandor during maintenance inspection 11/13/2015 CR-2016-08065 The Polar Crane will not trolley in the counterclockwise rotation. The clockwise rotation is operating normal. This issue will impact completion of numerous WOs.
06/23/2016 CR-2017-01858 IFTS Winch cables and associated alignment guides found degraded 02/20/2017 CR-2023-02294 Rated capacity of two Drywall Hoist exceeded.
03/25/2-23 CMAA, Specification, No.70 Specification for Electric Overhead Travelling Cranes 1975 NUREG-0554 Single-Failure Proof Cranes for Nuclear Power Plants May 1979 NUREG-0612 Control of Heavy Loads at Nuclear Power Plants July 1980 ASME NUM-1 Rules for Construction of Cranes, Monorails, and Hoists (With ridge or Trolley or Hoist of the Underhung Type) 2016 ASME NOG-1 Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder) 2015 ASME B30.2 Overhead and Gantry Cranes (Top Running Bridge, Single or Multiple Girder, Top Running Trolley Hoist) 2005 ASME B30.16 Overhead Hoists (Underhung) 2016 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program element(s) of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements.
The staff also audited the description of the LRA AMP provided in the FSAR supplement in section A.1.26, Inspection of Overhead Heavy Load and Light Load (Related to Refueling)
Handling Systems. The staff verified this description is consistent with the description provided in the SRP.
37 LRA AMP B.2.27, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program Summary of Information in the Application. The LRA states that AMP B.2.27, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, as added 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.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M42 Aging Management Program Evaluation Results - Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Revision 4 PAP-1933 Internal Coatings/Linings Program Revision 0 NQI-1806 Internal Coatings/Linings Condition Assessment Inspection Revision 0 CR-G202-2010-85703 Condition Report on Unsat Div II Fuel Oil Tank Internal Surface Coating Inspection 11/11/2010 CR-G202-2010-85629 Condition Report on Unsat Fuel Tank Coating Inspection 11/10/2010 CR-G202-2010-85665 Three Additional Areas Need Coating Rework for Div 2 EDG FO Tank 11/11/2010 CA-G202-2010-85665-1 Corrective Action 1 Rework of the Division 2 EDG Fuel Oil Storage Tank Coating 11/13/2010 WO-200358400 Inspection - PY1R45A0003A - Diesel Generator Fuel Oil Day Tank 10/1/2010 WO-200358401 Inspection - PY1R45A0005 - HPCS Fuel Oil Day Tank 9/9/2010 WO-200717749 Work Order - PY1R45A0002A -Fuel Oil Storage Tank 10/19/2021 WO-200717770 Work Order - PY1R45A0002B -Fuel Oil Storage Tank 10/18/2022 WO-200717771 Work Order - PY1R45A0004 - HPCS Fuel Oil Storage Tank 3/22/2022 WO-200861114 Inspection - PY1R45A0003B - Diesel Generator Fuel Oil Day Tank 10/18/2022 CR-G202-2007-12936 Condition Report on Condensate Storage Tank Does Not Meet Class B Cleanliness 1/18/2007 CR-G202-2005-07415 Condition Report on Condensate Storage Tank Did Not Meet Class B Cleanliness 11/2/2005 LRPY-OE-001 Operating Experience Review Revision 3 PYRM-ER-0002 One-Time Inspection Program Components Revision 1 During the audit, the staff verified the applicants claim that the scope of program and preventive actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
38 During the audit, the staff also identified exceptions associated with the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements.
In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.
The staff also audited the description of the LRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program provided in the UFSAR supplement.
The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program. The staff will consider issuing RAIs to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
LRA AMP B.2.28, Lubricating Oil Analysis Program Summary of Information in the Application. The LRA states that AMP B.2.28, Lubricating Oil Analysis, is an existing program with enhancement and exceptions that will be consistent with the program elements in GALL-LR Report AMP XI.M39, Lubricating Oil Analysis. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SE. The staff will address issues identified but not resolved in this audit report in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists the documents that were reviewed by the staff and were found relevant to the Lubricating Oil Analysis. These documents were provided by the applicants ePortal. The staff will document its review of relevant operating experience in the SE.
Document Title Revision/Date LRPY-AMP-XI.M39 Aging Management Program Evaluation Results Lubricating Oil Analysis Program Revision 3 Nuclear Operating Procedure NOP-ER-4001, FENOC Condition Monitoring Revision 5 Manual Test Oil Data Sight User Guide Version 2.5 Manual PNPP Lubrication Manual, Rev. 348 Revision 348 ASTM ASTM D 6224-09, Standard Practice for In-Service Monitoring of Lubricating Oil for Auxiliary Revision ?
CR CR 2013-07160 Revision ?
CR CR 2018- 09312 CR CR 2018-09313
39 During the audit, the staff verified Perrys claim that the scope of program preventive actions, parameters monitored or inspected, monitoring and trending, detection of aging effects, acceptance criteria, and corrective actions program elements of the LRA AMP is consistent with the corresponding elements of the GALL-LR Report AMP.
The staff also audited the description of the LRA AMP Lubricating Oil Analysis program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-LR Report.
LRA AMP B.2.29, Masonry Walls Monitoring Program Summary of Information in the Application. The LRA states that AMP B.2.29, Masonry Walls Monitoring Program, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.S5, Masonry Walls.
Audit Activities. During the audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.S5 Aging Management Programs Evaluation Results -
Masonry Walls Revision 0 LRPY-AMP-XI.S6 Aging Management Programs Evaluation Results -
Structures Monitoring Program Revision 6 LRPY-CAMR-BLD Aging Management Review (AMR) Report - Turbine Buildings and Associated Structure, Process Facilities, and Yard Structures Revision 9 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
During the audit, the staff made the following observation:
The Applicant claims there are no safety related masonry walls in the PNPP following initial construction and there are no safety related masonry walls that are near to, or having attachments from, safety-related systems or components. Therefore, PNPP does not have any safety-related masonry walls meeting the criteria of I.E. 80-11 or Information Notice (IN) 87-67.
The staff also audited the description of the LRA Masonry Walls program provided in the UFSAR supplement. There are no safety related masonry walls at PNPP meeting the requirements of I.E. 80-11 or IN 87-67. The masonry wall condition monitoring program is performed under the structures monitoring aging management program.
40 LRA AMP B.2.30, Monitoring of Neutron-Absorbing Materials Other Than Boraflex Program Summary of Information in the Application. The LRA states that AMP B.2.30, Monitoring of Neutron-Absorbing Materials other than Boraflex, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M40, Monitoring of Neutron-Absorbing Materials other than Boraflex. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date NOP-NF-3201 Spent Fuel Storage Rack Neutron Absorber Monitoring Program Revision 2 LRPY-AMP-XI.M40 Aging Management Program Evaluation Results-Monitoring of Neutron-Absorbing Materials other than Boraflex Program Revision 2 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
The staff also audited the description of the Monitoring of Neutron-Absorbing Materials other than Boraflex program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.31, Non-EQ Electrical Cable Connections Program Summary of Information in the Application. The LRA notes that AMP B.2.31, Non-EQ Electrical Cable Connections Program, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.
Audit Activities. An onsite audit was performed from October 24-25, 2023.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.E6 Aging Management Program Evaluation Results-Non-EQ Electrical Cable Connections Program Revision 4 WO 200410729 Interbus Transformer LH-1-A 04/04/2023
41 Document Title Revision/Date NOP-ER-3100 Cable Aging Management Program Revision 2 CR-2019-02862 Interbus transformer LH1A 13KV termination enclosure found rusty 04/15/2019 LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 NORM-ER-3112 Cable Monitoring Revision 2 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored/inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP will be consistent with the corresponding elements of the GALL-LR Report AMP.
The staff also audited the description of the LRA Non-EQ Electrical Cable Connections Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR.
The staff also conducted an onsite audit where the staff interviewed the applicants staff and performed walkdowns of the Perry Nuclear Power Plant. Specifically, the staff conducted onsite walkdowns of the switchyard related to SBO coping and recovery paths, examined conditions of cables and connections, cable raceways, and electrical penetrations. The staff did not have any observations to report from the walkdowns.
LRA AMP B.2.32, Non-EQ Inaccessible Power Cables Program Summary of Information in the Application. The LRA notes that AMP B.2.32, Non-EQ Inaccessible Power Cables Program, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.E3, Inaccessible Power Cables Not Subject to 10 CFR50.49. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the applicants basis document as well as the available current relevant procedures and referenced documents.
Audit Activities. An onsite audit was performed from October 24-25, 2023.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE as necessary.
Document Title Revision/Date LRPY-AMP-XI.E3 Aging Management Program Evaluation Results-Non-EQ Inaccessible Power Cables Program Revision 5 NOP-ER-3100 Cable Aging Management Program Revision 2 22-0026-000 Dewatering Pumps for Electrical Manholes Revision 0 NORM-ER-3112 Cable Monitoring Revision 2 NOP-ER-4002 Medium Voltage Shielded Cable Testing and Diagnostics Revision 0 ONI-ZZZ-1 Acts of Nature-Severe Weather Revision 33 CR-2013-11870 Deficiencies identified During Maintenance Rule Walkdown of Plant Manholes Per Order 200509750 02/05/2010 CR-2014-12127 Water Levels in Electrical Manhole 60 01/04/2014 CR-2015-07181 WO 200596774 unsat conditions for silt/sludge in electrical manholes 03/15/2015 CR-2016-00770 Calcium levels in underdrain manholes are unsat 05/13/2016 CR-2023-08352 Structural Support Members in Electrical Manhole #1 are Degraded 04/12/2022
42 Document Title Revision/Date CR-2024-00095 Degraded Component Identified During Manhole #1 and Manhole #2 Div.3 Inspection 03/27/2024 CR-2024-00210 Degraded Component Identified During Inspection for Division 3 Side of Electrical Manhole #2 03/27/2024 PYBP-LRP-0004 Electrical Scoping, Screening and Aging Management Review Revision 3 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored/inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP will be consistent with the corresponding elements of the GALL-LR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the LRA Non-EQ Inaccessible Power Cables Program provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in SRP-LR.
The staff conducted an onsite audit during which the staff interviewed the applicants staff and performed walkdowns of the Perry Nuclear Power Plant. Specifically, the staff observed in-scope cables, connections, and manholes associated with the LRA. During the onsite audit, the applicant provided explanation on the degradation of components and structural supports for manhole work orders that are within the scope of LR and further elaborated on the cable reliability program and explained the cause of the deficiencies for the manholes and underground vaults.
LRA AMP B.2.33, Non-EQ Instrumentation Circuits Program Summary of Information in the Application. The LRA notes that AMP B.2.33, Non-EQ Instrumentation Circuits Program, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.E2, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the applicants basis document as well as the available current relevant maintenance procedures.
Audit Activities. An onsite audit was performed from October 24-25, 2023.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.E2 Aging Management Program Evaluation Results-Non-EQ Instrumentation Circuits Program Revision 3 GEI-0048 Low Voltage Control Circuit Testing Revision 7 NOP-ER-3112 Cable Monitoring Revision 2 20-0089-001 Install Corrosion Rate Monitoring Equipment for the R35 Cathodic Protection System Revision 2 PTI-R35-P0001 Cathodic Protection Monthly Rectifier and Anode Terminal Box Check Revision 6 PTI-R35-P0002 Cathodic Protection Annual Survey Revision 9 CR-2013-08461 Anode Terminal Box #7 Heat Damage 05/24/2013 CR-2013-16629 Heated wire in a control rm panel 11/10/2013
43 Document Title Revision/Date CR-2015-05688 IRM A failed overlap data 02/15/2013 CR-2017-02456 IRM D indication is erratic 03/03/2013 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored/inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP will be consistent with the corresponding elements of the GALL-LR Report AMP.
The staff also audited the description of the LRA Non-EQ Instrumentation Circuits Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in SRP-LR.
The staff conducted an onsite audit where the staff interviewed the applicants staff and performed walkdowns of the Perry Nuclear Power Plant. Specifically, the staff conducted onsite walkdowns of the switchyard related to SBO coping and recovery paths, examined cables and connections, cable raceways, and electrical penetrations. The staff did not have any observations to report from the walkdowns.
LRA AMP B.2.34, Non-EQ Insulated Cables and Connections Program Summary of Information in the Application. The LRA notes that AMP B.2.34, Non-EQ Insulated Cables and Connections Program, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.E1, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the applicants basis document as well as the available current relevant procedures.
Audit Activities. An onsite audit was performed October 24-25, 2023.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.E1 Aging Management Program Evaluation Results-Non-EQ Insulated Cables and Connections Program Revision 4 NOBP-ER-3103 Plant Walkdown for Inspection of Potential Adverse Localized Environments for Electrical Cables and Connections Revision 0 NOP-ER-3100 Cable Aging Management Program Revision 2 NORM-ER-3112 Cable Monitoring Revision 2 4.0 PNPP Electrical License Renewal Electrical Aging Management Review Revision 3 LRPY-OE-0001 Operating Experience Review Results and Summary Revision 3 GEI-0048 Low Voltage Control Circuit Testing Revision 7 GEI-0012 Inspection and Cleaning of Electrical Equipment Revision 20 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored/inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP will
44 be consistent with the corresponding elements of the GALL-LR Report AMP after implementation of the identified enhancement.
The staff also audited the description of the LRA Non-EQ Insulated Cables and Connections Program provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in SRP-LR.
The staff conducted an onsite audit where the staff interviewed the applicants staff and performed walkdowns of the PNPP. Specifically, the staff conducted onsite walkdowns of the switchyard related to SBO coping and recovery paths, examined electrical manhole, conditions of cables and connections, cable raceways, and electrical penetrations. The staff did not have any observations to report from the walkdowns.
LRA AMP B.2.35, One-Time Inspection Program Summary of Information in the Application. The LRA states that AMP B.2.35, One-Time Inspection Program, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M32, One-Time Inspection. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M32 Aging Management Program Evaluation Results - One-Time Inspection Program Revision 3 LRPY-OE-001 Operating Experience Review Results and Summary Revision 1 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
The staff also audited the description of the LRA One-Time Inspection Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.36, One-Time Inspection of ASME Code Class 1 Small Bore-Piping Program Summary of Information in the Application. The LRA states that AMP B.2.36, One-Time Inspection of ASME Code Class 1 Small-Bore Piping, is a new program that is consistent with the program elements in GALL-LR Report AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. The staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.
45 The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M35 Aging Management Program Evaluation Results - One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program Revision 3 NOP-CC-2115 Socket Weld Vibration Fatigue Management Revision 2 10/12/2021 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
During the audit, the staff made the following observations:
LRA stated that the one-time inspection will be completed within the six-year period or not later than six months prior to the period of extended operation. The staff notes that Perrys current license expires on midnight of November 7, 2026. Based on past refueling outages, the expected dates of the next two refueling outages would be in 2025 and 2027. The staff interviewed the applicants staff to verify the status of completion of the one-time inspection of ASME Code Class 1 small-bore piping. The applicant responded that the required one-inspection is ongoing and will be completed not later than six months prior to the period of extended operation. No cracking was detected on the welds inspected so far.
The staff interviewed the applicants staff to verify the applicants review of NRC IN 2007-21, Supplement 1, Pipe Wear due to Interaction of Flow-Induced Vibration and Reflective Metal Insulation, dated December 11, 2020, for applicability and implementation into Perrys ISI program. The applicant responded that it has reviewed this IN and will provide the result of its review in ePortal.
The staff also audited the description of the LRA One-Time Inspection of ASME Code Class 1 Small-Bore Piping provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.37, Open-Cycle Cooling Water System Program Summary of Information in the Application. The LRA states that AMP B.2.37, Open-Cycle Cooling Water System Program, is an existing program that will be consistent with the program elements in GALL-LR Report AMP XI.M20, Open-Cycle Cooling Water System.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date PYRM-ER-0001 Perry Service Water Reliability (Generic Letter 89-13) Program Basis Document Revision 00 EMARP-0011 Emergency Service Water Monitoring Program Revision 9 EMARP-0008 Environmental Monitoring and Reporting Program Revision 8 NOP-ER-2006 Service Water Reliability Management Program Revision 6 ATL-2022-0277 System Trending Improvement Plan 03/13/2022
46 Document Title Revision/Date CR-2022-01183 Corrective Action document that notes the degrading trend of the Division III Diesel Generator Jacket Water heat exchanger over the last three consecutive performance tests that were performed between 12/01/2010 and 07/01/2019.
03/23/2022 CR-2019-10233 Triennial Heat Sink Inspection: Roll Up CR 12/09/2019 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. In addition, the staff found that for the monitoring and trending program element, sufficient information was not available to verify whether it was consistent with the corresponding program element of the GALL-LR Report AMP. The staff will consider issuing an RAI to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL-LR Report AMP.
The staff also audited the description of the LRA Open-Cycle Cooling Water System Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.38, Protective Coating Monitoring and Maintenance Program Summary of Information in the Application. The LRA states that AMP B2.2.38, Protective Coating Monitoring and Maintenance, is an existing program that, with enhancements, will be consistent with NUREG-1801,Section XI.S8, Protective Coating Monitoring and Maintenance.
To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. The table below lists the documents that were reviewed by the staff and were found relevant to the Protective Coating Monitoring and Maintenance Program. These documents were provided by the applicant and identified in the staffs search of the applicants operating experience database. The staff will document its review of this information in the SE.
Document Title Revision/Date CR-2015-05651 Condition Report 04/22/15 CR-2013-04105 Condition Report 03/20/13 CR-2013-04209 Condition Report 03/21/13 CR-2013-04453 Condition Report 03/25/13 CR-2013-04629 Condition Report 03/27/13 CR-2013-05423 Condition Report 04/09/13 CR-2013-05571 Condition Report 04/11/13 CR-2013-05769 Condition Report 04/14/13 CR-2013-08228 Condition Report 05/28/13 CR-2013-08233 Condition Report 05/28/13 CR-2013-18952 Condition Report 11/26/13 CR-2014-06360 Condition Report 04/05/14 CR-2014-17421 Condition Report 11/21/14 CR-2015-00976 Condition Report 01/23/15 CR-2015-03653 Condition Report 03/19/15 CR-2015-09425 Condition Report 07/11/15 CR-2015-12271 Condition Report 09/17/15 CR-2015-15918 Condition Report 11/24/15
47 Document Title Revision/Date CR-2016-08070 Condition Report 06/23/16 CR-2017-03270 Condition Report 04/01/17 CR-2017-11651 Condition Report 11/24/17 CR-2018-07989 Condition Report 07/10/18 CR-2019-02328 Condition Report 03/14/19 CR-2019-05737 Condition Report 07/05/19 CR-2019-08707 Condition Report 10/21/19 CR-2012-16821 Condition Report 10/24/12 CR-2012-17427 Condition Report 11/02/12 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
The staff also verified the applicants claim that aspects of the parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria, program element not associated with the enhancement identified in the LRA are consistent with the corresponding program element inthe GALL-LR Report AMP.
During the audit of the operating experience program element, the staff reviewed a search of results of the plant-specific database to identify any previously unknown or recurring aging effects. The staff will evaluate any identified plant-specific operating experience in the SER.
The staff also audited the description of the LRA AMP Protective Coating Monitoring and Maintenance program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-LR Report.
LRA AMP B.2.39, Reactor Head Closure Stud Bolting Program Summary of Information in the Application. The LRA states that AMP B.2.39, Reactor Head Closure Stud Bolting Program, is an existing program with enhancements and exceptions that will be consistent with the program elements in GALL-LR Report AMP XI.M3, Reactor Head Closure Stud Bolting.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SER.
Document Title Revision/Date LRPY-OE-001 Operating Experience Review 09/07/2023 LRPY-AMP-XI.M3 Aging Management Program Evaluation Results -
Reactor Head Closure Stud Bolting Program Revision 4, 05/23/2023 NOP-CC-5710 ASME Section XI Inservice Inspection (ISI) Program Revision 5, 05/17/2019 UT-11-E012 RPV Closure Head Studs 04/21/2011 UT-11-E013 RPV Shell, Threads in Flange Area 04/22/2011 PNP-002710 RPV Closure Head Nut 03/06/2023
48 Document Title Revision/Date PNP-002750 RPV Closure Head Washer 03/06/2023 PNP-005110 RPV Closure Head Nut 03/18/2019 PNP-005150 RPV Closure Head Washer 03/18/2019 UT-17-E005 RPV Closure Head Studs 03/08/2017 UT-17-E006 RPV Shell, Threads in Flange Area 03/08/2017 1R15 Washer Nuts (E).PDF RPV Closure Head Nut (9)
RPV Closure Head Washer (9) 03/18/2015 PNPP Drawing 305-0006-00112 PNPP RPV Closure Stud Holes 11/17/1988 During the audit, the staff verified the applicants claim that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. The staff also verified the applicants claim that aspects of the preventive actions program element not associated with the exception identified in the LRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-LR Report AMP.
During the audit, the staff made the followingobservations:
The applicant stated the PNPP stud assembly material is SA 540 Grade B23 or B24 carbon steel, Class 3 and that the stud assemblies are assumed to have an actual yield strength of greater than 150 ksi. This value is above the recommended yield strength in NUREG-1801 to reduce the potential for stress corrosion cracking or intergranular stress corrosion cracking.
The applicant stated the purchasing requirements for reactor head closure stud material will be revised to assure that any studs procured in the future will have measured yield strength of less than 150 ksi.
The staff verified the Code of Record for PNPP is the 2013 Edition, no Addenda of ASME Boiler & Pressure Vessel Section XI and that PNPP is in the 4th ISI interval with beginning and ending dates of May 18, 2019, and May 17, 2029, respectively.
The staff requested verification of statement from LRA Section B.2.39, The Refueling Outage 18 (RFO18) ISI Summary Report identified no unacceptable reactor head closure studs, threads in flange, nuts, or washers. The applicant verified this statement was not correct and will be revised.
The staff verified in the examination results of the most recent ASME Code Section XI ISI performed that there were no unacceptable indications for any reactor head closure studs, threads in flange, nuts, or washers.
The staff confirmed the PNPP RPV closure stud holes (i.e., flange threads) do not have the bushing design.
The staff noted a phosphate coating is applied to threaded areas of the studs, nuts, and bearing areas of the nuts and washers to act as a rust inhibitor and to assist in retaining lubricant on these surfaces.
The staff also audited the description of the LRA Reactor Head Closure Stud Bolting Program provided in the UFSAR supplement. The staff verified this descriptionisconsistent with the description provided in the SRP-LR Report.
49 LRA AMP B.2.40, Reactor Vessel Surveillance Program Summary of Information in the Application. The LRA states that AMP XI.M31, Reactor Vessel Surveillance, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M31, Reactor Vessel Surveillance.
Audit Activities. For the OE review, the applicant made a presentation on the process used to identify and evaluation the pertinent OE. Afterward, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date N/A Perry License Renewal Application 07/2023 N/A BWRVIP-86 Rev 1-A During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
During the audit, the staff made the following observations:
PNPP is a participating plant in the BWRVIP-86 Integrated Surveillance Program, with the PNPP 183° surveillance capsule being the designated capsule. The capsule is scheduled for withdraw and testing during the period of extended operation at approximately 40 effective full-power years (EFPY).
The staff also audited the description of the LRA AMP Reactor Vessel Surveillance Program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.41, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program Summary of Information in the Application. The LRA states that AMP B.2.41, Inspection of Water-Control Structures Associated with Nuclear Power Plants, is an existing program with enhancements that will be consistent with the program elements in GALLLR Report AMP XI.S7, Inspection of Water-Control Structures Associated with Nuclear Power Plants. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff also reviewed the enhancements associated with this AMP. The staff will document its review of the enhancements in the SE.
Audit Activities. During its audit, the NRC staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.
50 The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date EMARP-0011 Emergency Service Water System Monitoring Program Revision 9 CR 02-01985 Calculation: NOP-CC-3002-01 Rev. 01 (Calculation No.
2:09:000) for Initiating Document CR-02-01985 Inspection Program of PNPP Cooling Water Structures per EMARP-0011 and compliance with RG1.127 Revision 1 CR 0551 1/8 crack approx. 100 foot long at the Y section to the ESWPH 05/26/1000 CR-G202-2005-04764 Small cracks with minor offsets in concrete lining of normal ESW tunnel [this crack was evaluated in CR 99-2157].
06/10/2005 CR-2014-13676 ESW intake and Common Intake Diving Inspection 08/28/2014 CR-2017-011560 Assessment of degraded Service Water Intake Structure floor slab at elevation at Elevation 796-0 due to concrete spalling 10/27/2017 Calculation No. CSB-057 Service Water Intake Structure - slab and beam design at elevation 796-0 Revision 0 CR-2014-010585 2014 SSI annual inspection recommendations for additional maintenance actions 09/30/2014 During the audit, the staff verified the applicants claim that the preventative actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP or will be consistent after implementation of the identified enhancements.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement in Section A.1.36, Inspection of Water-Control Structures Associated with Nuclear Power Plants.
The staff verified this description is consistent with the description provided in the GALL-LR.
LRA AMP B.2.42, Selective Leaching Program Summary of Information in the Application. The LRA states that AMP B.2.42, Selective Leaching Program, is a new program with an exception that will be consistent with the program elements in GALL-LR Report AMP XI.M33, Selective Leaching, as revised by LR-ISG-2011-03, Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program (AMP) XI.M41, Buried and Underground Piping and Tanks, and LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations.
At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.M33 Aging Management Program Evaluation Results -
Selective Leaching Program Revision 5 CR-2014-10691 Unplanned Fire Impairment for Leak in Underground Fire Piping Near Hydrant #37 06/19/2014
51 Document Title Revision/Date M14339 BETA Laboratory Failure Analysis Report: Buried Fire Protection Piping 11/20/2014 During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP. In addition, the staff found that for the scope of program and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.
The staff also audited the description of the LRA Selective Leaching Program provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA Selective Leaching Program. The staff will consider issuing RAIs to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
LRA AMP B.2.43, Structures Monitoring Program Summary of Information in the Application. The LRA states that AMP B.2.43, Structures Monitoring, is an existing condition monitoring program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.S6, Structures Monitoring.
Audit Activities. In addition to the OE documentation contained in the LRA and ePortal, the staff observed the applicants search of its operating experience database using keywords. An onsite audit was performed from October 24-25, 2023. The staff participated in an onsite audit at PNPP to gain a general overview of current conditions of the structures and components compared to the provided OE and an understanding on the scope of the Structures Monitoring program, potential erosion of cement from porous concrete sub-foundations and its impact on the building settlement, and aging management of the plant underdrain system and plant storm drain piping.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-XI.S6 Aging Management Program Evaluation Results - Structures Monitoring Program Revision 6 TAI-0513 Monitoring the effectiveness of Maintenance Structure Monitoring Program Revision 7 EMARP-003 Piezometer Monitoring & Groundwater Measurement Revision 3 EMARP-0006 Monitoring the Settlement or Rebound of Safety Class Structures Revision 3 PMI-0113 Plant Underdrain System Maintenance and Inspection Procedure Revision 4 PTI-P72-P0005 Plant Underdrain Ground water level Reading Revision 6 LRPY-CS-SCP-001 Civil/Structural Scoping Methodology Report Revision 10 LRPY-MSCP-001 Scoping Methodology Report Revision 7 USAR PNNP USAR Revision 23 LRAP-OE-001 Operating Experience Review Results and Summary Revision 3
52 Document Title Revision/Date CR-2019-02584 Perry Unit 1, Turbine Building Roof Leaks 03/21/2019 CR-2013-01457 Water Intrusion - Intermediate Building 654 Elevation 01/30/2013 CR-2016-09351 Radwaste Building Roof Leak 07/29/2016 CR-2019-05086 Standing Water on Fuel Handling Roof 06/10/2019 CR-2022-00531 Standing Water on Floor Discovered in Condensate Backwash Receiver Tank Room 01/24/2022 CR-2018-05480 Containment Upper Pool Leak Detection Through Drains Plugged 06/03/2018 CR-2017-09139 Unit 2 Turbine Building Roof Deteriorated 09/05/2017 CR-2014-07308 Concrete Spall at Face of IB-8 Wall Under Fuel Handling Building Roof Girder 04/22/2014 CR-2014-17958 Unit 2 Turbine Building Roof Conditions Severely Degraded 12/04/2014 CR-2015-13962 Ceiling /Roof Degraded for Winter Weather 10/05/2015 CR-2019-03765 Water Leaking from Electric Penetration 04/23/2019 CR-2020-04955 Concrete Spalling and Leakage in Emergency Service Water Pump House, 586 elevation 06/09/2020 CR-2022-07274 Multiple Leaks identified in Heating Bay 09/07/2022 During the audit, the staff verified the applicants claim that the monitoring and trending, and corrective actions program elements of the LRA AMP are consistent with the corresponding element of the GALL--LR Report AMP. In addition, the staff found that for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.
During the audit, the staff made the following observations:
For the Scope of Program program element, the staff noted that several structures and components identified in the LRA as within the scope of the AMP are not clearly identified in the scope of current procedures or as an enhancement.
For the Preventive Actions program element, the staff noted that AMP does not include preventive action for storage, lubricants, and stress corrosion cracking potential discussed in Section 2 of RCSC publication.
For the Parameters Monitored or Inspected and Acceptance Criteria program elements, the staff noted that a representative sample of high strength (actual measured yield strength 150 ksi or 1,034 MPa) structural bolts greater than 1 inch (25 millimeters) in diameter are monitored for stress corrosion cracking at least once every 10 years, which exceeds the 5-year periodicity recommended by the GALL report.
For the plant-specific plant underdrain system and plant storm drain piping, the applicant is requested to follow the branch technical positions described in Appendix A of SRP-LR for the aging management.
The staff noted that LRA Table 3.5.1 lists many Table 1 AMR items that do not have Table 2 AMR items associated with them, and LRA Table 3.5.1 does not explicitly state whether these Table 1 AMR items are applicable, not applicable, or not used.
The staff also noted that aging effects of many structural components in LRA Tables 3.5.2-2, 3.5.2-3, and 3.5.2-4 are managed by the Structures Monitoring program, citing
53 Note H. The applicant is requested to ensure that all the applicable aging effects are identified and managed by the Structures Monitoring program.
During the onsite audit, the staff performed walkdowns of portions of the Reactor Building, Auxiliary Building, Fuel Handling Building, Intermediate Building, Diesel Generator Buildings, Auxiliary Boiler Building, Offgas Building, Circulating Water Pumphouse, Service Water Pump House, discharge Tunnel Entrance Structure, Radioactive Waste Building, Service Building, and Yard Structures. The staff made the following observations during walkdowns:
The staff observed standing water, dirt, and vegetation on roofs of the Fuel Handling Building and the Intermediate Building.
The staff observed concrete spalling of two roof beam seats in the Fuel Handling Building.
The staff observed that High Mast Light 7 lacks a drain hole through the grout between the High Mast base and foundation.
During the walkdown of the structures and components within the scope of license renewal, the staff noted the degradations observed during the walkdowns were found to be consistent with the OE for which the GALL-LR Report program was evaluated.
The staff also audited the description of the LRA Structures Monitoring program provided in the USAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the USAR supplement was an adequate description of the LRA Structures Monitoring Program. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the USAR supplement program description.
LRA AMP B.2.44, Water Chemistry Program Summary of Information in the Application. The LRA states that AMP B.2.44, Water Chemistry, is an existing program with one exception that is consistent with the program elements in GALL Report AMP XI.M2, Water Chemistry. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff also reviewed the exception associated with this AMP. The staff will document its review of the exception to the GALLReport AMP in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date REC-0104 Chemistry Specifications Revision 49 PYPM-OC-0001 Strategic Chemistry Plan Revision 5 EPRI-3002002623 EPRI Proprietary. BWRVIP-190: BWR Vessel and Internals Project: BWR Water Chemistry Guidelines Revision 1 N/A EPRI Proprietary. 2019 BWR Water Chemistry Guidelines Interim Guidance 03/2019
54 Document Title Revision/Date LRPY-AMP-XI.M2 Aging Management Program Evaluation Results-Water Chemistry Program Revision 3 CR-2014-15410 This report documents Reactor Water Chlorides exceeding the Action Level 1 limit following the removal of the RWCU system.
10/7/2014 CR-2015-10131 This report documents the zinc injection skid flow not being stable.
07/28/2015 CR-2015-10812 2015 INPO BWRVIP Visit Recommendation Number 5: Reactor Water Chemistry Impacted by Equipment Issues 08/13/2015 CR-2015-12857 Monitoring and Trending Indicate Main Condenser In-Leakage 09/28/2015 CR-2015-14103 Reactor Water Chemistry Elevated Due to Controller Acting Erratically 10/18/2015 CR-2016-02149 HWC Tripped During Feed Pump Shifting 02/13/2016 CR-2016-03007 RPO-09A HWC Availability Performance Indicator is Red for January and February 2016 03/03/2016 CR-2017-00478 Elevated Reactor Water Sulfates 01/14/2017 CR-2018-05909 OLNC Skid Pressure Increase During 2018 Application 06/28/2018 CR-2018-06692 Feedwater Conductivity Excursion Caused by Steam Leak Sealant Injection for Extraction Steam to 1st Stage Reheater B Drain Valve 07/26/2018 CR-2019-06346 Hotwell Dissolved Oxygen Exceeded Fuel Warranty Limits Following Reactor Trip 07/28/2019 CR-2020-04754 Low Level Trends in Reactor Water Chemistry Indicate a Small Feed of Impurities 06/2/2020 CR-2021-02014 Online Noble Chemistry Internal Inspection (OLNC) for Platinum Buildup WO 200790600 Shows Blockage on B Loop 03/19/2021 CR-2021-02711 Elevated Chlorides and Sulfates Above CEI Threshold During Startup 1R18 04/09/2021 SP-0637-4549-00 Specification For Design, Fabrication and Delivery of Fuel Pool Gates Perry Nuclear Power Plant Units 1 and 2 Revision 10 During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
The staff also verified the applicants claim that aspects of the scope of program, program element not associated with the exception identified in the LRA during the audit are consistent with the corresponding program elements inthe GALL Report AMP.
The staff also audited the description of the Water Chemistry program provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.1, Time-Limited Aging Analyses Summary of Information in the Application. LRA section 4.1, Time-Limited Aging Analyses, discusses the methodology for the identifying of TLAAs in the LRA. To verify the implementation of the applicants methodology to identify TLAAs in accordance with 10 CFR Part 54, the staff performed an audit. Issues identified but not resolved in this report will be addressed in the SE.
55 Audit Activities. During its audit, the staff reviewed documentation contained in the LRA and provided by the applicant via the ePortal. The table below lists a document that was reviewed by the staff and was found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-TLAA-001 TLAA and Exemption Evaluation Results Revision 5 LRPY-TLAA-002 TLAA - Metal Fatigue Revision 6 Perry License Renewal Time Limited Aging Analyses (TLAA) Assessment Revision 1 During the audit, the staff verified that the applicant has provided its basis and methodology for identifying TLAAs in accordance with disposition of 10 CFR 54.21(c).
During the audit, the staff made the following observations:
The staff reviewed Perry License Renewal TLAA Assessment and LRPY-TLAA-01 and confirmed that current licensing basis and design basis documentation were searched to identify potential TLAAs. The staff noted that specific key words were used during this search that would reasonably identify potential TLAAs. The staff confirmed that the applicant performed further reviews of the design calculations if an analysis was deemed a potential candidate for a TLAA during this search with specific key words.
The staff reviewed Perry License Renewal TLAA Assessment and LRPY-TLAA-01 and confirmed that each potential TLAA was reviewed against the six criteria of 10 CFR 54.3(a) and that those that met all six criteria were identified as TLAAs, which require evaluation for the subsequent period of extended operation.
The staff reviewed Perry License Renewal TLAA Assessment and LRPY-TLAA-01, and confirmed that a search of docketed licensing correspondence, the operating license, and the UFSAR identified exemptions granted pursuant to 10 CFR 50.12. Additionally, the staff noted that Perry License Renewal TLAA Assessment and LRPY-TLAA-01 identifies the exemptions currently in effect that were granted pursuant to 10 CFR 50.12.
The staff reviewed Perry License Renewal TLAA Assessment and LRPY-TLAA-01 and confirmed that these active exemptions were then reviewed to determine whether the exemptions granted pursuant to 10 CFR 50.12 were based on a TLAA. The staff one that an exemption granted in accordance with 10 CFR 50.12 is associated with the TLAA for pressure-temperature (P-T) limits and will be further addressed in the SER.
Additionally, during its audit, the staff noted that the TLAA discussed in LRA Section 4.6.12, RPV Annealing, may not meet the six criteria of a TLAA as defined in 10 CFR 54.3. The staff will consider issuing an RAI to obtain the necessary information.
LRA TLAA Section 4.2.1, Neutron Fluence Projections Summary of Information in the Application. LRA Section 4.2.1, Neutron Fluence Projections, discusses the analysis for the neutron fluence in the reactor pressure vessel (RPV) as an input to other reactor pressure vessel neutron embrittlement analyses. The applicant dispositioned the TLAA (time-limited aging analysis) in accordance with 10 CFR 54.21(c)(1)(ii). To verify that the applicant provided an acceptable basis to support its disposition of the TLAA, the staff audited the TLAA.
56 Audit Activities. The staff asked the licensee to discuss the use of RAMA code and BUGLE-96 cross-section library and explain why they adhere to RG 1.190 for the duration of the PNPP requested license renewal application and to discuss any RAMA methodology benchmarking that is applicable to the PNPP LRA related analyses. This information was provided by the applicant on their secure ePortal and were reviewed by the NRC staff as part of the audit.
In addition, to prepare for the audit the NRC staff reviewed the use of RAMA fluence methodology for BWR RPV, and internal components of BWR plants including the following SERs:
- 2. NRC SER for BWRVIP-145, BWR Vessel and Internals Project During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). The staff determined that as part of his audit no request for additional information (RAI) is necessary. The staff will discuss the details of the audit as necessary in its SER.
LRA TLAA Sections 4.2.2, Upper Shelf Energy and 4.2.3, Adjusted Reference Temperature Analyses Summary of Information in the Application. The staffs audit addresses the following TLAAs collectively due to their relationship in analyzing the reactor vessel neutron embrittlement:
LRA section 4.2.2, Upper Shelf Energy discusses the analysis for assessing the projected reduction in the upper-shelf energy (USE) properties of RPV base metal and weld components. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
LRA section 4.2.3, Adjusted Reference Temperature Analyses discusses the analyses for assessing the use of adjusted reference temperature (ART) to adjust the pressure temperature limit curves to account for irradiation effects. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. The staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date Certified Material Test Report for HEAT C2557-1 Certified Material Test Report for HEAT C2453-1 SHELL 3 Certified Material Test Report for HEAT C2448-2 SHELL 1 Certified Material Test Report for HEAT C2448-1 SHELL 1
57 Document Title Revision/Date Certified Material Test Report for HEAT C2432-2 SHELL 3 Certified Material Test Report for HEAT C2432-1 SHELL 3 Certified Material Test Report for HEAT B6270-1 Certified Material Test Report for HEAT A1155-1 Certified Material Test Report for HEAT A1068-1 SHELL 1 Certified Material Test Report for HEAT 627260 Certified Material Test Report for HEAT 627069 Certified Material Test Report for HEAT 626677 Certified Material Test Report for HEAT 624063 Certified Material Test Report for HEAT 5P6756 LOT 0342 WELD N1 AND N6 TO RPV Certified Material Test Report for PERRY HEAT 5P6214B LOT 0331 WELDS BA BB BC BG BJ BK Certified Material Test Report for PERRY HEAT 4P7216 LOT 0156 SINGLE-TANDEM CIRC WELD AB Certified Material Test Report for PERRY HEAT 492L4871 WELD AC Certified Material Test Report for PERRY HEAT 412L4711 WELD AC Certified Material Test Report for PERRY HEAT 05T776 WELD AC Certified Material Test Report for PERRY HEAT 04T931 WELD AC Calc No. B13-030 Perry RPV Beltline ART and USE Calculation Revision 1 LRPY-TLAA-001 TLAA and Exemption Evaluation Results Revision 5 DI-EA-0272 Design Input for calculation EA-0272, BWROG Pressure and Temperature Limits Revision 0 BWRVIP-135 Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations Revision 4 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii) for LRA Section 4.2.2 and 4.2.3. However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. As discussed below, following its audit, the applicant provided additional information that will be addressed in the SER.
During the audit, the staff made the following observations:
The staff verified that the material information (e.g., initial reference temperature nil ductility [RTNDT], %Cu, %Ni, initial USE, margin values) for the RPV materials contained in LRA Tables 4.2-2 and 4.2-3, except as noted below, are:
o consistent with the applicants current licensing basis (e.g., FSAR, license amendments associated with power uprates or pressure-temperature limits) or NRC-approved topical reports (i.e., BWRVIP-86, Rev 1-A) o based on information from certified material test reports or fabrication records for the specific material or weld type
%Cu and %Ni content values for Lower Shell Plate (Heat Nos C2448-1, C2448-2, and A1068-1) in LRA Tables 4.2-2 and 4.2-3 were inconsistent with the check values (i.e.,
measurements taken from the product form) documented in the CMTRs; thus, the staff
58 will consider issuing an RAI to obtain the information necessary to clarify this inconsistency o The staff verified that the initial values for RTNDT and USE are consistent with the CMTRs for the Lower Shell Plate (Heat Nos C2448-1, C2448-2, and A1068-1).
Material information for Heat No 5P6214B for several RPV materials in LRA Table Tables 4.2-2 and 4.2-3 were inconsistent; thus, the staff will consider issuing an RAI to obtain the information necessary to clarify this inconsistency.
Additionally, based on this verification describe above, the staff observed that the appropriate margin value consistent with Regulatory Guide 1.99, Revision 2, were applied for each reactor vessel material for the purposes of addressing and adjusted reference temperature.
The staff verified the applicants assessment of surveillance data from the Perry 3° and 177° surveillance capsules (contained in in BWRVIP-135, Revision 4) was performed in accordance and determined to be credible in accordance with RG 1.99, Revision 2, for the following reactor pressure vessel materials:
o Heat No. C2557-1 Lower-Intermediate Shell Plate 1-1 o Heat No. 5P6214B Upper-Intermediate Shell Axial Weld - BG, BJ, BK Lower Intermediate Shell Axial Weld - BD, BF Lower Intermediate Shell Axial Weld - BE Lower Shell Axial Weld - BA, BB, BC Additionally, the staff verified the applicants use of position 1.2 of RG 1.99, Rev 2 is conservative compared to position 2.2 of RG 1.99, Rev 2 (i.e., application of surveillance data from the Perry 3° and 177° surveillance capsules for C2557-1 and 5P6214B from BWRVIP-135, Revision 4).
The staff also audited the description of the USE and ART TLAAs in LRA Section A.2.2.2 and A.2.2.3, respectively, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.2.4, Pressure-Temperature Limits Summary of Information in the Application. LRASection 4.2.4, Pressure Temperature (P-T)
Limits, discusses the assessment of P-T limits for the RPV. The applicantdispositioned the TLAA in accordance with10 CFR54.21(c)(1)(iii).
To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SER.
Audit Activities. During its audit, the staff reviewed documentation contained in the LRA and provided by the applicant via the ePortal. The staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
59 The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-TLAA-001 TLAA and Exemption Evaluation Results Revision 5 ML1417A633 Request for Licensing Action to Amend Technical Specification 3.4.11, RCS Pressure and Temperature (P/T) Limits.
06/23/2014 ML5069A235 Response to Request for Additional Information Regarding a Request to Amend Technical Specification 3.4.11, RCS Pressure and Temperature (P/T) Limits 02/27/2015 ML15141A482 Perry Nuclear Power Plant, Unit No. 1 - Issuance of Amendment Concerning Changes to Pressure Temperature Curves 06/12/2015 During the audit of the TLAA, the staff verified that the applicant has provided itsbasis that supports its disposition of 10CFR54.21(c)(1)(iii).
During the audit, the staff made the followingobservations:
The staff noted by letter dated June 23, 2014, FENOC submitted LAR No. 168 to Technical Specification 3.4.11, RCS Pressure and Temperature (P-T) Limits, to address the water level instrumentation nozzle in the RPV beltline region and to address the RCS vacuum concerns. Additionally, P-T limits were developed and proposed in LAR No. 168 to be valid for 32 EFPYs.
NRC Safety Evaluation for LAR No. 168 (ML15141A482) stated that, The NRC staff performed independent evaluations and verified that the P-T limits were developed appropriately using approved methodologies, and proposed P-T limits valid for 32 EFPYs satisfy the requirements of Appendix G to Section XI of the ASME Code and Appendix G to 10 CFR Part 50.
The applicant stated in LRA Section 4.2.4, the P-T limits are in the Technical Specifications and are required to be updated through the 10 CFR 50.90 licensing process separate from the license renewal process. The staff noted that prior to entering the period of extended operation, the applicant will submit updated P-T limits as part of the 10 CFR 50.90 licensing process.
The staff also audited the description of the LRA TLAA for P-T limits provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA P-T Limits. The staff will consider issuing an RAI to obtain information necessary to verify the sufficiency of the UFSAR supplement program description.
LRA TLAA Section 4.2.5, RPV Shell Welds Failure Probability Assessment Analysis Summary of Information in the Application. LRASection 4.2.5, RPV Welds Failure Probability Assessment Analysis, discusses the analyses for the reactor pressure vessel beltline shell welds. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SE.
60 Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. The staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-TLAA-001 TLAA and Exemption Evaluation Results Revision 5 Calc No. B-13-030 Perry RPV Beltline ART and USE Calculation Revision 1 Calc No. B13-035 Assessment of Reliability of Reactor Pressure Vessel Beltline Axial and Circumferential Shell Welds for Extended Operating Time Limit of 60 Years Revision 0 BWRVIP-86 Updated BWR Integrated Surveillance Program (ISP)
Implementation Plan Revision 1-A BWRVIP-329-A Updated Probabilistic Fracture Mechanics Analyses for BWR RPV Welds to Address Extended Operations December 2021 During the audit of the TLAA, the staff verified that the applicant has provided itsbasis that supports its disposition of 10CFR54.21(c)(1)(ii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. As discussed below, following its audit, the applicant provided additional information that will be addressed in the SER.
During its audit, the staff assessed the plant-specific RPV dimensions and the plant-specific end-of-interval RTmax values to verify the applicants RPV is within the envelope of limiting RTmax values established in BWRVIP-329-A. The staff noted that the plant-specific end-of-interval RTmax values were calculated based on the material properties of the reactor vessel (e.g., initial RTNDT, weight % Cu, weight % Ni, and chemistry factor) based on 54 EFPY.
During the audit, the staff made the followingobservations:
The plant-specific dimensions of the applicants RPV are enveloped by the RPV dimensions assessed in the probabilistic fracture mechanics analyses in BWRVIP-329-A.
The plant-specific end-of-interval RTmax values for the limiting plate, circumferential weld, and axial weld were calculated based on plant-specific material properties of the reactor vessel based on 54 EFPY.
The plant-specific end-of-interval RTmax values were calculated consistent with BWRVIP-329-A; however, the staff noted that the applicant conservatively included an additional margin term to its plant-specific end-of-interval RTmax value. The staff will consider issuing an RCI to clarify whether the additional margin was intentional.
The plant-specific end-of-interval RTmax value for the limiting plate, circumferential weld, and axial weld, with the revision of removing the margin term, were less than the corresponding limiting RTmax value for plates and circumferential welds in BWRVIP-329-A.
61 The staff noted a discrepancy in the applicants selection of the limiting plate material; thus, the staff will consider issuing an RAI to obtain the information necessary to clarify this inconsistency.
The staff noted the applicant dispositioned the TLAA for RPV welds (i.e., axial weld and circumferential weld) failure probability assessment in accordance with 10 CFR 54.21(c)(1)(ii). The staff recognizes that for the elimination of ASME Code,Section XI examination requirements of RPV circumferential welds, consistent with the conclusion in the NRC staffs SE for BWRVIP-329-A, the applicant would be required to submit a proposed alternative in accordance with 10 CFR 50.55a(z)(1) during the period of extended operation.
The staff also audited the description of the LRA TLAA for RPV Welds Failure Probability Assessment Analysis in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.2.6, RPV Reflood Thermal Shock Summary of Information in the Application. LRA Section 4.2.6, RPV Reflood Thermal Shock, discusses the analysis for non-ductile failure of the reactor pressure vessel for all postulated plant conditions. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. The staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date N/A Perry License Renewal Application 07/2023 N/A Fracture Mechanics Evaluation of a Boiling Water Reactor Vessel Following a Postulated Loss of Coolant Accident 08/1979 GE Report No. NEDO-10029 An Analytical Study on Brittle Fracture of GE-BWR Vessels Subject to the Design Basis Accident 06/1969 CAT B-A ITEM B1.12 1R17.PDF Latest ISI examination results of the RPV longitudinal welds (Examination Category B-A, Item No. B1.12) 03/2019 N/A ASME Code Section XI 2013 Edition N/A Calculation DI-EA-0272 Rev 0 01/28/2016 N/A SA-336 Material Specification ASME 1974 N-A 1974 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 52.21(c)(1)(ii).
During the audit, the staff made the following observations:
The stress analysis of the analyzed transient is given at 0.052t, rather than the typical 0.25t flaw. The staff asked for an explanation of how this 0.052t flaw depth was adequate for the analysis, given that the maximum KI applied in the transient is
62 described as occurring at the 0.25t location in the 1979 Fracture Mechanics reference that was reviewed for this audit. The applicant responded that the 0.052t flaw is the largest allowable flaw under ASME Code,Section XI ISI requirements. The staff confirmed from the latest ASME Code,Section XI examination records for the RPV welds that there was only one recordable indication, an embedded indication, and that it was acceptable per there requirements of IWB-3500 of ASME Code,Section XI.
The application lacked fluence information about the LPCI N6 nozzles to verify that these nozzles are not projected to exceed 1.0E+17 n/cm2 fluence before 54 EFPY. Staff asked for more information about these nozzles and reviewed calculation documents that did verify these nozzles will experience fluence below the 1.0E+17 n/cm2 threshold.
The application noted that several water level instrument nozzles are projected to exceed the 1.0E+17 n/cm2 fluence threshold at the end of 54 EFPY but did not note the material type of these nozzles. The staff asked for more information about these nozzles. The applicant responded that the nozzles are a stainless-steel alloy and so the Appendix G fracture toughness evaluation of ferritic materials is not applicable.
The staff also audited the description of the LRA Reflood Thermal Shock Analysis of the RPV provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.3.1, Class 1 Fatigue Summary of Information in the Application. LRA Section 4.3.1, Class 1 Fatigue, discusses the fatigue TLAA for ASME Code Section III, Class 1 piping, and components. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and the ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the fatigue TLAA for ASME Code Section III, Class 1 piping, and components. The staff will document its review of this information in the SER.
Document Title Revision/Date LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 09/07/2023 PYBP-LRP-0006 Operating Experience Review Revision 3 09/07/2023 LRPY-TLAA-002 TLAA - Metal Fatigue Revision 6 05/16/2023 Calculation B13-029 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 0 11/10/2022 Structural Integrity Associates (SIA) 1000488.402 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 4 06/30/2021
63 Document Title Revision/Date Calculation B13-025 Fatigue Update for Perry Nuclear Power Plant from 10/1/16 to 4/13/2021 Revision 1 12/21/2022 SIA 2001140.301 Fatigue Update for Perry Nuclear Power Plant from 10/1/16 to 4/13/2021 Revision 3 10/25/2022 CR 202303889 NRC ID: 2023 CETI Inspection: NRC Identified HPCS Dissimilar Weld Not Evaluated for License Renewal 05/08/2023 Calculation B13-036 Cycle Based Fatigue Report for the Transient and Fatigue Monitoring System at the Perry Nuclear Power Plant Revision 4 11/10/2022 SIA FP-PERY-403 Cycle Based Fatigue Report for the Transient and Fatigue Monitoring System at the Perry Nuclear Power Plant Revision 4 08/31/2022 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
The staff also audited the description of the fatigue TLAA for the Class 1 piping and components provided in the UFSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR Section 4.3.2.2.
LRA TLAA Section 4.3.2, Non-Class 1 Fatigue Summary of Information in the Application. LRA Section 4.3.2, Non-Class 1 Fatigue, discusses the fatigue TLAA for ASME Code Section III, Class 2 and 3 and ANSI B31.1 piping systems (i.e., non-Class 1 piping systems). The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(i). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the fatigue TLAA for ASME Code Section III, Class 2 and 3 and ANSI B31.1 piping systems. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 09/07/2023 PYBP-LRP-0006 Operating Experience Review Revision 3 09/07/2023 LRPY-TLAA-002 TLAA - Metal Fatigue Revision 6 05/16/2023 Calculation B13-029 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant (Incorporation of SIA 1000488.402, Revision 4)
Revision 0 11/10/2022
64 Document Title Revision/Date Structural Integrity Associates (SIA) 1000488.402 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 4 06/30/2021 Calculation B13-036 Cycle Based Fatigue Report for the Transient and Fatigue Monitoring System at the Perry Nuclear Power Plant Revision 4 11/10/2022 SIA FP-PERY-403 Cycle Based Fatigue Report for the Transient and Fatigue Monitoring System at the Perry Nuclear Power Plant Revision 4 08/31/2022 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations.
LRA Section 4.3.2 does not clearly describe the number of projected 60-year equivalent full temperature cycles determined in the implicit fatigue analysis for the following non-Class 1 piping systems and their technical basis: (1) control and computer room humidification piping; (2) reactor plant sampling piping; (3) fire protection piping; (4) auxiliary steam and drains piping; (5) hydrogen chemistry piping; (6) post-accident sampling piping; (7) division 1 and 2 standby diesel generator exhaust, intake and crankcase piping; and (8) emergency diesel generator piping.
The staff also audited the description of the fatigue TLAA for the non-Class 1 piping systems provided in the UFSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR Section 4.3.2.2.
LRA TLAA Section 4.3.3, Environmental Fatigue Summary of Information in the Application. LRA Section 4.3.3, Environmental Fatigue, discusses the environmentally assisted fatigue (also called environmental fatigue or EAF) TLAA for ASME Code Section III, Class 1 piping, and components. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the EAF TLAA for the ASME Code Section III, Class 1 piping, and components. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 09/07/2023
65 Document Title Revision/Date PYBP-LRP-0006 Operating Experience Review Revision 3 09/07/2023 LRPY-TLAA-002 TLAA - Metal Fatigue Revision 6 05/16/2023 Calculation B13-029 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 0 11/10/2022 Structural Integrity Associates (SIA) 1000488.402 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 4 06/30/2021 Calculation B13-025 Fatigue Update for Perry Nuclear Power Plant from 10/1/16 to 4/13/2021 Revision 1 12/21/2022 SIA 2001140.301 Fatigue Update for Perry Nuclear Power Plant from 10/1/16 to 4/13/2021 Revision 3 10/25/2022 Calculation B13-033 Methodology for Environmental Fatigue Evaluation Revision 0 09/07/2022 SIA 1300310.302 Methodology for Environmental Fatigue Evaluation Revision 0 03/19/2015 Calculation B13-039 Perry Environmentally Assisted Fatigue Screening Revision 0 01/06/2023 SIA 1300310.303 Perry Environmentally Assisted Fatigue Screening Revision 1 10/09/2015 SIA 2200940301.301 Review of Calculation Package for 1300310.303 for Consistency Revision 0 01/05/2023 Calculation B13-027 ASME Code NB-3200 Analysis of HPCS Piping Location Revision 0 02/15/2022 SIA 2101082.304 Environmentally Assisted Fatigue, HPCS Bounding Location, Perry Revision 0 01/17/2022 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations.
LRA Table 4.3-5 describes the limiting EAF locations, and their 60-year projected environmentally adjusted cumulative usage factor (CUFen) values. LRA Section 4.3.3 indicates that the EAF analysis includes the locations of NUREG/CR-6260 and other component locations that may be more limiting than the NUREG/CR-6260 locations in terms of EAF. However, LRA Table 4.3-5 does not clearly describe which locations are the plant-specific EAF locations that may be more limiting than the NUREG/CR-6260 locations.
LRA Section 4.3.3 addresses the EAF TLAA, including the EAF screening evaluation to determine the limiting EAF locations. However, the LRA does not clearly describe the following items related to the screening evaluation: (1) whether the screening evaluation was performed for each material type (e.g., stainless steel, nickel alloy and carbon steel); and (2) how the applicant determined thermal zones or sections that group certain components and piping lines for proper comparisons of the screening CUFen values considering the applicable transient conditions.
LRA Section 4.3.3 indicates that the EAF screening evaluation uses the bounding environmental fatigue correction factor (Fen) values. However, the LRA section does not
66 clearly discuss how the applicant determined the bounding Fen values in the screening evaluation. In addition, LRA Section 4.3.3 indicates that, after the screening evaluation, the applicant performed more detailed EAF evaluation to remove some conservatisms and determine the refined CUFen values for 60 years of operation, as described in LRA Table 4.3-5. However, the LRA does not clearly describe how the conservatisms associated with the screening CUFen values were removed to refine the 60-year projected CUFen values.
The staff also audited the description of the EAF TLAA for the Class 1 piping and components provided in the UFSAR supplement. The staff verified this description is consistent with the acceptance criteria provided in SRP-LR Section 4.3.2.2.
LRA TLAA Section 4.3.4, Reactor Vessel Internals Fatigue Summary of Information in the Application. LRA Section 4.3.4, Reactor Vessel Internals Fatigue, discusses the fatigue TLAA for the reactor vessel internals. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
The staff will address issues identified but not resolved in this audit report in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and the ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the fatigue TLAA for the reactor vessel internals. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 09/07/2023 PYBP-LRP-0006 Operating Experience Review Revision 3 09/07/2023 LRPY-TLAA-002 TLAA - Metal Fatigue Revision 6 05/16/2023 Calculation B13-029 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 0 11/10/2022 Structural Integrity Associates (SIA) 1000488.402 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 4 06/30/2021 Calculation B13-025 Fatigue Update for Perry Nuclear Power Plant from 10/1/16 to 4/13/2021 Revision 1 12/21/2022 SIA 2001140.301 Fatigue Update for Perry Nuclear Power Plant from 10/1/16 to 4/13/2021 Revision 3 10/25/2022 CR-2015-07022 1R15 Condition Monitoring Exam Results for Jet Pump 13 & 14 Problems Found in 1R12 05/15/2015 CR-2013-05609 1R14 Condition Monitoring Exams of Jet Pump 12 &
14 Problems First Found in 1R12 05/11/2013 GE Potential Issue Form (PIF) 96-2455 Perry Jet Pump Gaps 07/08/1996
67 Document Title Revision/Date Technical Assignment File (TAF) 81787 Jet Pump Set Screw Gap Acceptance Criteria and Evaluation Revision 4 04/05/2023 CA 09-54819-04 Corrective Action to Update TAF 81913 09/18/2009 TAF 81913 BWRVIP Basis Documents (reseating of inlet mixers to reduce the gaps or wedge tapping)
Revision 10 11/06/2023 Calculation B13-028 Jet Pump Fatigue Margin Assessment Revision 0 08/31/2022 GE Calculation 007N1361 Perry Jet Pump Fatigue Margin Assessment Revision 0 06/2022 GE Report GENE-B13-0190902 Perry Jet Pump Set Screw Gap Structural Evaluation 10/1997 GE Report 0000-0107-6595-R0 Perry 1 Jet Pump Set Screw Gap Vibration Analysis 12/2009 GE-NE-B13-2112-00 Perry Jet Pump Set Screw Gap Vibration Analysis Revision 0 06/2001 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
The staff also audited the description of the fatigue TLAA for the reactor vessel internals provided in the UFSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR Section 4.3.2.2.
LRA TLAA Section 4.3.5, Intermediate High-Energy Line Break (HELB) Location Determination Summary of Information in the Application. LRA Section 4.3.5, Intermediate High Energy Line Break (HELB) Location Determination, discusses the TLAA on HELB location postulation for ASME Code Section III, Class 1 piping systems. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the TLAA on HELB postulation. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 09/07/2023 PYBP-LRP-0006 Operating Experience Review Revision 3 09/07/2023 LRPY-TLAA-002 TLAA - Metal Fatigue Revision 6 05/16/2023
68 Document Title Revision/Date Calculation B13-029 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 0 11/10/2022 Structural Integrity Associates (SIA) 1000488.402 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 4 06/30/2021 UFSAR 3.6.2.1.5 Locations for Postulated Pipe Breaks Revision 12 01/2003 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations. In addition to the HELB location postulation for the Class 1 piping systems, UFSAR Section 3.6.2.1.5 addresses the HELB location postulation for Class 2 and 3 piping systems. Specifically, Item a.3 of the UFSAR section explains that the HELB breaks for the Class 2 and 3 piping are assumed in accordance with the criterion based on the allowable stress range for expansion stress (SA), consistent with the guidance in Branch Technical Position MEB 3-1 (ADAMS Accesso No. ML052340555).
However, LRA Section 4.3.5 does not identify the HELB analysis for the Class 2 and 3 piping as a TLAA based on the HELB location postulation that involves SA and the associated cycle-dependent stress range reduction factor.
The staff also audited the description of the TLAA on HELB location postulation provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the TLAA on HELB location postulation. The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement description in relation to the HELB analysis for the Class 2 and 3 piping discussed above.
LRA TLAA Section 4.4, Environmental Qualification of Electric Equipment Summary of Information in the Application. LRA Section 4.4, Environmental Qualification for Electrical Equipment, discusses the thermal, radiation, and cyclical aging analyses for the plant electrical and I&C components. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).
Audit Activities. An onsite audit was performed on October 24-25, 2023.
The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-AMP-X.E1 Aging Management Program Results -
Environmental Qualification (EQ) of Electrical Components Program Revision 4 NOP-CC-5301 Environmental Qualification Program Revision 4 NEI-0701 Environmental Qualification Process Revision 18
69 Document Title Revision/Date EQ-203 Qualified Life of Raychem (TE Connectivity) NMCK8 and NHVT electrical connection kits with reformulated BBIT-N material Revision 8 (Draft)
ATA-2023-21353 Verify References of EPRI-1558 in Environmental Qualification Calculations at Perry 12/14/2023 (date created) 01/11/2024 (date provided)
EQ-178 Qualified Life of NAMCO EC210 Series Connectors with cable Revision 1 (Draft)
EQ-016 Qualified Life of PYCO Temperature Elements Revision 5 (Draft)
GMI-0008 Pressure Relief Device Bench Testing Revision 24 During the audit of the TLAA, the staff verified the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
The staff also audited the description of the LRA Environmental Qualification of Electric Equipment provided in the USAR supplement. The staff verified this description is consistent with the descriptions provided in the SRP-LR.
LRA TLAA Section 4.5, Containment Vessel, Containment Piping Penetrations and Containment Piping Penetration Bellows LRA TLAA Section 4.5.1 Containment Vessel Summary of Information in the Application. LRA Section 4.5.1 Containment Vessel discusses the analysis of the containment structure composed of a free-standing steel cylinder with an ellipsoidal dome, secured to a steel-lined, reinforced concrete foundation mat associated with the TLAA. The applicant dispositioned the TLAAs for the steel containment vessel in accordance with 10 CFR 54.21(c)(1)(iii).
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal. In addition to the OE documentation contained in the LRA and ePortal, the staff observed the applicants search of its operating experience database using the phrase: Containment Vessel Fatigue.
The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date Calculation B13-038 Design Basis Fatigue Review and recommendation for a comprehensive transient and fatigue management program at the Perry Nuclear Power Plant, Revision 0 Calculation B13-036 Cycle Based Fatigue Report for the transient and Fatigue monitoring System at Perry Nuclear Power Plant Revision 0 Calculation B13-025 Fatigue Update for Perry Nuclear Power plant from 10/1/2016 to 4/13/2021 (Corrections to Structural integrity Associates Calculations issued as Perry Calculation B13-025 Revision 0)
Revision 1 N/A Perry License Renewal - Time Limited Aging Analyses (TLAA)
Assessment Revision 1
70 Document Title Revision/Date LRPY-TLAA-001 3.5 Containment Liner Plate, Metal Containments, and Penetration Fatigue Analysis (LRA Section 4.5) - PNPP TLAA and Exemption Evaluation Results -
Revision 5 LRPY-TLAA-002 7.0 Containment Liner Plate, Metal Containments, and Penetration Fatigue Analysis (LRA Section 4.5) - TLAA - Metal Fatigue Revision 6 During the audit of the TLAA, the staff verified that the applicant has provided itsbasis that supports its disposition of 10 CFR 54.21(c)(1)(iii) for the steel containment vessel.
The staff also audited the description of the LRA A.2.5.1 Containment Vessel provided in the UFSAR supplement. The staff verified this descriptionisconsistent with the description provided in the SRP-LR.
LRA Section 4.5.2 Containment Piping Penetrations Summary of Information in the Application. LRA Section 4.5.2 Containment Piping Penetrations discusses the analysis of the containment penetrations assemblies associated with the TLAA. The applicant dispositioned the TLAAs for the containment piping penetrations in accordance with 10 CFR 54.21(c)(1)(iii).
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal. In addition to the OE documentation contained in the LRA and ePortal, the staff observed the applicants search of its operating experience database using the phrase: Penetration Fatigue.
The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date B13-043 Cycle-Based Fatigue Development for Containment Penetration Locations for Perry Revision 0 EA-0268 Updated Containment Penetration Fatigue Calculations for ASME MC Penetrations for Safety Class2/3 Piping Systems Revision 0 EA-0270 Updated Containment Penetration Fatigue Calculations for ASME MC Penetrations for Safety Class 1 Piping Systems Revision 0 N/A Perry License Renewal - Time Limited Aging Analyses (TLAA) Assessment Revision 1 During the audit of the TLAA, the staff verified that the applicant has provided itsbasis that supports its disposition of 10 CFR 54.21(c)(1)(iii) for the containment piping penetrations.
The staff also audited the description of the LRA A.2.5.2 Containment Piping Penetrations provided in the UFSAR supplement. The staff verified that this descriptionisconsistent with the description provided in the SRP for TLAAs.
LRA Section 4.5.3 Containment Piping Penetrations Bellows
71 Summary of Information in the Application. LRA Section 4.5.3 Containment Piping Penetrations Bellows discusses the analysis of the containment piping penetration bellows associated with the TLAA. The applicant dispositioned the TLAAs for the steel containment vessel in accordance with 10 CFR 54.21(c)(1)(i).
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal. In addition to the OE documentation contained in the LRA and ePortal, the staff observed the applicants search of its operating experience database using the phrase: Bellows Fatigue.
The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date B13-043 Cycle-Based Fatigue Development for Containment Penetration Locations for Perry Revision 0 EA-0268 Updated Containment Penetration Fatigue Calculations for ASME MC Penetrations for Safety Class2/3 Piping Systems Revision 0 EA-0270 Updated Containment Penetration Fatigue Calculations for ASME MC Penetrations for Safety Class 1 Piping Systems Revision 0 PEN-15 Penetration Bellows Stress Evaluation Revision 0 N/A Perry License Renewal - Time Limited Aging Analyses (TLAA)
Assessment Revision 1 Report No.
70195Y-1 Calculations for Containment Penetration Bellows Expansion Joints Revision 2 During the audit of the TLAA, the staff verified that the applicant has provided itsbasis that supports its disposition of 10 CFR 54.21(c)(1)(i) for the containment piping penetration bellows.
However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition.
During the audit, the staff made the following observation:
The staff noted that the applicant credited the bellows fatigue usage as bounded by the fatigue usage of the penetrations, indicating that since the penetration fatigue does not exceed the allowable limits at 60-years neither would the bellows fatigue. However, the applicant dispositioned the containment piping penetration bellows TLAA under 10 CFR 54.21(c)(1)(i) rather than under 10 CFR 54.21(c)(1)(iii) as dispositioned for the penetrations. During the Audit the staff discussed with the applicant potential aging analyses and associated aging effects issues that could arise when coupling two distinctly different TLAA evaluations. PNPP plans to review and potentially redisposition the containment piping penetration bellows TLAA from 10 CFR 54.21(c)(1)(i) to 10 CFR 54.21(c)(1)(iii) indicating these bellows will be age-managed under the appropriate aging management program (X.M1, Fatigue Monitoring). The applicant plans to incorporate this change as a supplement which the staff will review and evaluate in the SE.
The staff also audited the description of the LRA A.2.5.3 Containment Piping Penetrations Bellows provided in the UFSAR supplement. The staff noted that although the information in the current UFSAR supplement descriptionisconsistent with the description provided in the
72 SRP-LR for TLAAs, it is insufficient to determine its adequacy and consistency to the proposed TLAA Section 4.5.3 revision. The applicant plans to review the content of the revised UFSAR supplement when available to ensure its content fully captures the content of the proposed TLAA Section 4.5.3 revision. The staff will consider issuing an RAI(s) to obtain the information necessary to verify the sufficiency of the revised (U)FSAR supplement.
LRA TLAA Section 4.6.1, Crane Load Cycles Summary of Information in the Application. The LRA Section 4.6.1, Crane Load Cycles discusses the analyses for the Reactor Building Crane (a.k.a. Containment Polar Crane), Fuel Handling Building Crane, Emergency Service and Water Pump House Crane. The applicant dispositioned the TLAAs in accordance with 10 CFR54.21(c)(1)(i).
To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and operating experience by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date DBD-ME-006 Control of Heavy Loads at Nuclear Plants Revision 40 LRPY-TLAA-001 TLAA and Exemption Evaluation Results Revision 5 LRPY-AMP-XI.M23 AMP Management Program Evaluation Results - Inspection of Overhead Heavy Load and Light Load (related to Refueling)
Handling Systems Program Revision 3 CR-2010-77794 Bolt on bearing caps found loose.
06/04/2010 CR-2014-00793 Frayed strands on Polar Crane Aux. Hoist wire rope.
02/14/2014 CR-2014-12476 FHB Crane Main Hoist Overspeed switch shaft rotates without hoist drum shaft rotation.
07/31/2014 CR-2014-13952 Vibration and movement observed on bearing cap and indicator brackets of Fuel Handling Building Crane.
09/04/2014 CR-2014-12517 FHB Crane was used to perform a heavy load lift without reliable single-proof-protection features.
08/01/2014 CR-2015-05290 Walkdown and investigation area for improvement opportunity 02/15/2015 CR-2015-15519 Improvement opportunities identified Fuel Handling Building Crane Vandor during maintenance inspection 11/13/2015 CR-2016-08065 The Polar Crane will not trolley in the counterclockwise rotation. The clockwise rotation is operating normal. This issue will impact completion of numerous WOs.
06/23/2016 CR-2017-01858 IFTS Winch cables and associated alignment guides found degraded 02/20/2017 CR-2023-02294 Rated capacity of two Drywall Hoist exceeded.
03/25/2-23 NUREG-0554 Single-Failure Proof Cranes for Nuclear Power Plants 05/1979 NUREG-0612 Control of Heavy Loads at Nuclear Power Plants 07/1980 CMAA, Specification, No.70 Specification for Electric Overhead Travelling Cranes 1975
73 Document Title Revision/Date NUREG-0554 Single-Failure Proof Cranes for Nuclear Power Plants 05/1979 NUREG-0612 Control of Heavy Loads at Nuclear Power Plants 07/980 ASME NUM-1 Rules for Construction of Cranes, Monorails, and Hoists (With ridge or Trolley or Hoist of the Underhung Type) 2016 ASME NOG-1 Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder) 2015 ASME B30.2 Overhead and Gantry Cranes (Top Running Bridge, Single or Multiple Girder, Top Running Trolley Hoist) 2005 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).
The staff also audited the description of the LRA provided in the FSAR supplement in section A.2.6.1, Crane Load Cycles. The staff verified this description is consistent with the description provided in the SRP for TLAAs.
LRA TLAA Section 4.6.2, Main Steam Line Flow Restrictors Erosion Analysis Summary of Information in the Application. LRA Section 4.6.2 Main Steam Line Flow Restrictors Erosion Analysis, discusses the analysis for erosion of the main steam line flow restrictors. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii).
Audit Activities.
The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-TLAA-001 TLAA and Exemption Evaluation Results Revision 5 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
The staff also audited the description of the LRA Main Steam Line Flow Restrictors Erosion Analysis provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.6.3, Reduction of Fracture Toughness for the Reactor Vessel Internals Summary of Information in the Application. LRA Section 4.6.3, Reduction of Fracture Toughness for the Reactor Vessel Internals, discusses the analysis for the reactor vessel internals. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii).
Audit Activities. The staff took note of the OE documentation contained in the LRA and the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
74 Document Title Revision/Date BWRVIP-26-A BWR Top Guide Inspection and Flaw Evaluation Guidelines 11/2004 BWRVIP-38 BWR Shroud Support Inspection and Flaw Evaluation Guidelines 09/1997 BWRVIP-41, Revision 4-A BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines 12/2018 BWRVIP-48-A Vessel ID Attachment Weld Inspection and Flaw Evaluation Guidelines 11/2004 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
During the audit, the staff made the following observations:
The BWRVIP reports referenced by the applicant have been approved by the NRC through the topical report process.
The BWRVIP reports referenced by the applicant address reduction in fracture toughness of the internals through examination programs that determine whether flaws are present.
The staff also audited the description of the LRA section A.2.6.3, Reduction of Fracture Toughness for the Reactor Vessel Internals provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.6.4, Fatigue Analysis - Earthquake Cyclic Loading Summary of Information in the Application. The LRA Section 4.6.4, Fatigue Analysis -
Earthquake Cyclic Loading discusses the earthquake cycles input into the fatigue analyses constitute a TLAA. The applicant dispositioned the TLAAs in accordance with 10 CFR54.21(c)(1)(i).
To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities. During its audit, the staff reviewed documentation contained in the LRA and provided by the applicant via the ePortal and performed independent document search in the web-based NRC ADAMS. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-TLAA-001 TLAA and Exemption Evaluation Results Revision 5 UFSAR Subsection 3.7.4.4.2, The Earthquake of January 31, 1986 Revision 23 Report No. 2632 The Cleveland Electric Illuminating Company, Perry Power Plant, Confirmatory Program of the January 31, 1986, Ohio Earthquake Effect, Docket Nos. 50-440; 50-441, Gilbert/Commonwealth. (ADAMS #: ML20199D098) 06/16/1986
75 Document Title Revision/Date ACRS Reactor Safeguards Report ACRS Report on the Perry Nuclear Power Plant, Unit 1 (ADAMS #: ML16316A012) 311th meeting 03/13-15/1986 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i).
The staff also audited the description of the LRA provided in the FSAR supplement in Section A.2.6.14 Fatigue Analysis - Earthquake Cyclic Loading. The staff verified this description is consistent with the description provided in the SRP for TLAAs.
LRA TLAA Section 4.6.5, Fatigue due to Partial Feedwater Heating Summary of Information in the Application. LRA Section 4.6.5, Fatigue Due To Partial Feedwater Heating, discusses the fatigue analysis for the feedwater nozzles. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii).
Audit Activities. The staff took note of the OE documentation contained in the LRA and the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date ML22006A167 Perry Nuclear Power Plant, Unit No. 1 - Authorization and Safety Evaluation for Alternative Request IR-063 (EPID L-2022-LLR-0005) 11/30/2022 First Energy Calculation No.
B13-025, Rev. 1 Fatigue Evaluation Update for Perry Nuclear Power Plant from 10/1/2016 to 4/13/2021 Revision 1 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
During the audit, the staff made the following observations:
Although the applicant will manage the effect of partial feedwater heating on the feedwater nozzles during the period of extended operations by the BWR Feedwater Nozzle Program, the applicant also provided a cumulative fatigue analysis which demonstrates the total fatigue usage at the end of the period of extended operations will be below the design basis limit.
LRA Section 4.6.5 discusses an evaluation of the of the effect of partial feedwater heating on the feedwater spargers. The spargers are not in scope for license renewal and so are not considered as part of this TLAA.
The staff also audited the description of the LRA section A.2.6.5, Fatigue Due To Partial Feedwater Heating provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.6.6, Fatigue due to Single Recirculation Loop Operation Summary of Information in the Application. LRA Section 4.6.6, Fatigue due to Single Recirculation Loop Operation, discusses the fatigue TLAA due to the vibratory loading
76 of the single recirculation loop operation (also called single loop operation or SLO) for the reactor vessel internals. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and the ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the fatigue TLAA due to the SLO for the reactor vessel internals. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 09/07/2023 PYBP-LRP-0006 Operating Experience Review Revision 3 09/07/2023 LRPY-TLAA-002 TLAA - Metal Fatigue Revision 6 05/16/2023 Calculation B13-029 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant (Incorporation of SIA 1000488.402, Revision 4)
Revision 0 11/10/2022 Structural Integrity Associates (SIA) 1000488.402 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 4 06/30/2021 Calculation B13-025 Fatigue Update for Perry Nuclear Power Plant from 10/1/16 to 4/13/2021 (Incorporation of SIA 2001140.301)
Revision 1 12/21/2022 SIA 2001140.301 Fatigue Update for Perry Nuclear Power Plant from 10/1/16 to 4/13/2021 Revision 3 10/25/2022 UFSAR 15F.7.3 Vessel Internals Vibration Revision 12 01/2003 GE Report NEDE-31567-P-Addendum Perry 1 Reactor Internals Vibration Measurements 01/30/1991 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
The staff also audited the description of the fatigue TLAA due to the vibratory loading of the SLO for the reactor vessel internals provided in the UFSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR Section 4.3.2.2.
LRA TLAA Section 4.6.7, Steam Piping Erosion Summary of Information in the Application. LRA Section 4.6.7 Steam Piping Erosion, discusses the analysis for steam erosion of various systems and components and whether such erosion could prevent safe shutdown of the plant. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii).
77 Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-TLAA-001 TLAA and Exemption Evaluation Results Revision 5 PY-CEI/NRR-0069L ASLB Issue Number 15 Steam Erosion 08/31/1983 PY-CEI/NRR-0109L ASLB Issue Number 15 Steam Erosion 05/15/1984 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
The staff also audited the description of the Steam Piping Erosion TLAA provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.6.8, Silicone Sealant in Engineered Safety Features (ESF) Heating, Ventilation, and Air Conditioning (HVAC)
Summary of Information in the Application. LRA Section 4.6.8 Silicone Sealant in Engineered Safety Features (ESF) HVAC Ductwork, discusses the analysis for the HVAC Ductwork. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii).
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-TLAA-001 TLAA and Exemption Evaluation Results Revision 5 PY-CEI/NRR-0505 Environmental Qualification of Silicon Sealants FSAR App. IB, Item 17 SSER 8, 6.5 07/30/1983 PY-CWI/NRR-0703L License Commitment 17, Silicone Sealant 08/27/1987 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing an RAI.
The staff also audited the description of the Silicone Sealant in Engineered Safety Features (ESF) HVAC Ductwork TLAA provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.6.9, Top Guide Grid Beam Neutron Fluence Summary of Information in the Application. LRA Section 4.6.9, Top Guide Grid Beam Fluence, discusses the analysis for the top guide grid beam. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii).
Audit Activities. The staff took note of the OE documentation contained in the LRA and the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date BWRVIP-26-A BWR Top Guide Inspection and Flaw Evaluation Guidelines 11/2004
78 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
During the audit, the staff made the following observations:
The BWRVIP report referenced by the applicant has been approved by the NRC through the topical report process.
The BWRVIP report referenced by the applicant addresses reduction in fracture toughness of the top guide grid beam through examination programs that determine whether flaws are present.
The staff also audited the description of the LRA section A.2.6.9, Top Guide Grid Beam Neutron Fluence provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.6.10, Jet Pump Fatigue Analysis Summary of Information in the Application, LRA Section 4.6.10, Jet Pump Fatigue Analysis, discusses the analysis for the jet pump assembly. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii).
Audit Activities. The staff took note of the OE documentation contained in the LRA and the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Document Title Revision/Date BWRVIP-41, Rev. 4-A BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines 12/2018 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
During the audit, the staff made the following observations:
The BWRVIP report referenced by the applicant has been approved by the NRC through the topical report process.
The BWRVIP report referenced by the applicant addresses fatigue damage of the jet pump assembly through examination programs that determine whether flaws are present.
The staff also audited the description of the LRA section A.2.6.10, Jet Pump Fatigue Analysis provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.6.11, Allowable Stress Analysis of BOP ASME Code Class 1, 2 and 2 Components Summary of Information in the Application. LRA Section 4.6.11, Allowable Stress Analysis of Balance-of-Plant (BOP) ASME Code Class 1, 2 and 3 Components, discusses the allowable stress TLAA for BOP ASME Code Section III, Class 1, 2 and 3 components. The
79 applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(i). To verify that the applicant provided a basis to support its disposition of the TLAA, the staff audited the TLAA. The staff will address issues identified but not resolved in this audit report in the SE.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the OE review, the applicant made a presentation on the process used to identify and evaluate the pertinent OE. Afterwards, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the LRA and the ePortal.
The table below lists documents that were reviewed by the staff and were found relevant to the allowable stress TLAA for the BOP ASME Code Section III, Class 1, 2 and 3 components. The staff will document its review of this information in the SE.
Document Title Revision/Date LRPY-OE-001 Operating Experience Review Results and Summary Revision 3 09/07/2023 PYBP-LRP-0006 Operating Experience Review Revision 3 09/07/2023 LRPY-TLAA-002 TLAA - Metal Fatigue Revision 6 05/16/2023 Calculation B13-029 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 0 11/10/2022 Structural Integrity Associates (SIA) 1000488.402 Cycle Counting Methodology Report for the Transient and Fatigue Monitoring System for the Perry Nuclear Power Plant Revision 4 06/30/2021 N/A Perry License Renewal Time-Limited Aging Analysis (TLAA) Assessment Revision 1 05/04/2023 UFSAR Table 3.9-16 NSSS Compliance with Regulatory Guide 1.48 Revision 12 01/2003 UFSAR Table 3.9-18 Maximum Pressure Limits for Active and Nonactive ASME Code Class Valves Revision 12 01/2003 UFSAR Table 3.9-19 Stress Limits for Active ASME Code Class 2 and 3 Pumps Revision 12 01/2003 UFSAR Table 3.9-20 Stress Limits for ASME Code Class 2 and 3 Vessels Revision 12 01/2003 UFSAR Table 3.9-21 BOP Design Loading Combinations of ASME Code Class 1, 2 and 3 Piping Revision 12 01/2003 UFSAR Section 3.9.3 ASME Code Class 1, 2 and 3 Components, Component Supports and Core Support Structures Revision 12 01/2003 UFSAR Section 3.9.3.1.2 Load Combinations, Design Transients and Stress Limits for Balance of Plant Components and Supports Revision 12 01/2003 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations. The allowable stress TLAA for the non-Class 1 piping systems is already addressed in LRA Section 4.3.2. Therefore, the allowable stress TLAA for the non-Class piping systems discussed in LRA Section 4.6.11 is redundant to that discussed in LRA Section 4.3.2. The applicant also indicated that the allowable stress TLAA
80 for the Class 1 components is based on the time-dependent allowable stress criteria specified in UFSAR Tables 3.9-19, 3.9-20 and 3.9-20. However, these UFSAR tables and the related discussion in UFSAR Section 3.9.3.1.2 do not identify any time-dependent allowable stress criteria for the Class 1 components. In addition, the explicit fatigue analysis, which involves cumulative usage factor calculations for the Class 1 components, is already addressed in LRA Section 4.3.1.
The staff also audited the description of the allowable stress TLAA for the BOP ASME Code Class 1, 2 and 3 components provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the allowable stress TLAA and its technical basis.
The staff will consider issuing an RAI to obtain the information necessary to verify the sufficiency of the UFSAR supplement description.
LRA TLAA Section 4.6.12, RV Annealing During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(i). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. To obtain the necessary information, the staff will consider issuing RAIs.
AMR Items Not Associated with an AMP LRA Section 2.3.3, Auxiliary System Summary of Information in the Application. During the audit, the staff reviewed plant scoping and screening documentation associated with the following LRA sections:
2.3.3.25 Floor and Equipment Drains (P68) 2.3.3.26 Fuel Handling Area Ventilation (M40) 2.3.3.29 Inclined Fuel Transfer System (F42) 2.3.3.32 Leak Detection (E31) 2.3.3.33 Liquid Radwaste Disposal (G50) 2.3.3.34 Liquid Radwaste Sumps (G61) 2.3.3.35 MCC Switchgear and Misc. Electrical Area HVAC, and Battery Room (M23 &
M24) 2.3.3.36 Miscellaneous Area Ventilation (M46) 2.3.3.37 Miscellaneous Electrical Areas Smoke Ventilation (M49) 2.3.3.40 Nuclear Closed Cooling (P43) 2.3.3.41 Offgas Building Ventilation (M36) 2.3.3.44 Plant Foundation Underdrain (P72) 2.3.3.47 Potable Water Supply (P71)
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to LRA Section 2.3.3. The staff will document its review of this information in the SE.
81 Document Title / Description Revision/Date Updated Final Safety Analysis Report (UFSAR)*
Chapter 1.0 Introduction And General Description Of Plant Chapter 2.0 Site Characteristics Chapter 6.0 Engineered Safety Features Chapter 7.0 Instrumentation And Controls Systems Chapter 9.0 Auxiliary Systems Chapter 11.0 Radioactive Waste Management Chapter 15 Accident Analyses
- Sections Reviewed as listed in the LRA Sections Listed Above ML23303A132 Revision 23 License Renewal Drawings Drawing Numbers as listed in the LRA Sections Reviewed Above and posted to the OpentextTMlAppEnhancer Curtis-Wright electronic portal.
Various - As Posted for Relevance by the Applicant Scoping Reports System Scoping reports for the LRA Sections Reviewed Above and posted to the OpentextTMlAppEnhancer Curtis-Wright electronic portal.
Various - as Posted for Relevance by the Applicant Screening Reports System Screening reports for the LRA Sections listed Above and posted to the OpentextTMlAppEnhancer Curtis-Wright electronic portal.
Various - as Posted for Relevance by the Applicant On-Site Audits-Inspections / JAN 2024 AUDIT Applicant WRITTEN RESPONSES FOR DISCUSSION as posted to the OpentextTMlAppEnhancer Curtis-Wright electronic portal. - Applicant posts on the electronic portal were in response to the multitude of Breakout issues presented from the Staffs audit review of the LRA sections listed above.
Various dates - as the Applicant made the responses available for review.
During the audit, the Staff presented twenty-three Breakout Session issues to the Applicant for the thirteen LRA sections listed above. The Applicants written responses to these issues furthered the Staffs understanding of the scoping methodologies employed and eliminated any perception of inconsistency in the LRAs substance. The written responses were of good quality (i.e., comprehensive, and sufficient) that follow-up discussions were not necessary to resolve any issue. As the audit closed of the twenty-three issues presented, ten issues remain as Open Items pending the Applicants issuing an LRA Supplement. The Applicant for these ten Open Items intends to make these changes in a future supplement to the Perry LRA but no later than the first annual update.
A brief synopsis of the resolution (i.e. LRA Supplement) of Open Items is as follows:
- 1. LRA Section 2.3.3.25 Floor and Equipment Drains (P68) - Question #2 [Item 722]
LRA Table 2.3.3 For Component Type Valve Body the Intended Function will be changed to Leakage Boundary, Pressure Boundary LRA Table 3.3.2 New rows will be added for Component Type Valve Body to duplicate Rows 35 through 37 with the exception that the Intended function will be Pressure Boundary rather than Leakage Boundary.
System Scoping Drawing 911-0617 - The valves to the drain header as color coded Red rather than Blue.
- 2. LRA Section 2.3.3.25 Floor and Equipment Drains (P68) - Question #2 [Item 723]
82 LRA Section 2.3.2.25 - The subsection, Systems Functions (and scoping criteria, if intended function), will be updated to include the following intended function: Control Room subfloor drains and normally closed isolation valves provide a boundary for the control room envelope and prevent loss of carbon dioxide for the fire protection system
[10 CFR 54.4(a)(2), 10 CFR 54.4(a)(3) - FP].
LRA Table 2.3.3 The intended function for Component Type Valve Body will be changed from Leakage Boundary to Leakage boundary, Pressure Boundary.
LRA Table 3.3.2 New rows will be inserted for Component Type Valve Body that duplicate Rows 40 & 41 with the exception that the Intended Function will be Pressure boundary.
Scoping Boundary Drawing 911-0617 - The floor drain piping from the Control Room concrete floor elevation 653-6 up to and including the normally closed drain valves 1P68-F500A, 1P68-F500B, 2P68-F500A and 2P68-F500B shown on Scoping Drawing 911-0671(sic) (Coordinates E-8 through E-12) will be changed from Blue color coding to Red color coding indicating these components are performing a pressure boundary function.
- 3. LRA Section 2.3.3.26 Fuel Handling Area Ventilation (M40) - Question #1 [ITEM 724]
LRA Table 3.3.2 Add the following row before row 23:
Component Type: Flow element Intended Function: Pressure boundary Material: Aluminum Environment: Air - indoor, uncontrolled (Ext)
Aging Effect Requiring Management: None Aging Management Program: None NUREG-1801 Item: VII.J.AP-135
- 4. LRA Section 2.3.3.25 MCC Switchgear and Miscellaneous Electrical Area HVAC, and Battery Room Exhaust - Question #1 [ITEM 749]
LRA Table 3.3.2 Add the following row before row 15:
Component Type: Flow element Intended Function: Pressure boundary Material: Aluminum Environment: Air - indoor, uncontrolled (Ext)
Aging Effect Requiring Management: None Aging Management Program: None NUREG-1801 Item: VII.J.AP-135 Table 1 Item: 3.3.1-113 Notes: C
- 5. LRA Section 2.3.3.41 Off Gas Building Ventilation system (M36) - Question #1 [ITEM 779]
LRA Table 3.3.2 Add the following before row 20 Component Type: Flow element Intended Function: Pressure boundary Material: Aluminum Environment: Air - indoor, uncontrolled (Ext)
Aging Effect Requiring Management: None Aging Management Program: None NUREG-1801 Item: VII.J.AP-135
83 Table 1 Item: 3.3.1-113 Notes: C
- 6. LRA Section 2.3.3.26 Fuel Handling Area Ventilation (M40) - Question #3 [ITEM 726]
No Changes to LRA A Note to be added to LRPY-MAMR-M40 for component IDs PY0M40F0575 and PY0M40F0576 which states that portions of the damper housing exposed to Air-outdoor (Int) environment is addressed under component ID PY-M40DuctOutsideAir.
- 7. LRA Section 2.3.3.40 Nuclear Closed Cooling (P43) - Question #1 [ITEM 735]
No Changes to LRA Boundary drawings 302-0612 and 352-0612 to be changed.
- 8. LRA Section 2.3.3.40 Nuclear Closed Cooling (P43) - Question #3 [ITEM 737]
LRA Table 3.3.2 Add the following rows for the glass subcomponents after Row 29:
Component Type: Piping Intended Function: Leakage boundary Material: Glass Environment: Air - indoor, uncontrolled (Ext)
Aging Effect Requiring Management: None Aging Management Program: None NUREG-1801 Item: VII.J.AP-14 Table 1 Item: 3.3.1-117 Notes: A, Custom note number (TBD)
Component Type: Piping Intended Function: Leakage boundary Material: Glass Environment: Treated Water (Int)
Aging Effect Requiring Management: None Aging Management Program: None NUREG-1801 Item: VII.J.AP-51 Table 1 Item: 3.3.1-117 Notes: A, Custom note number (TBD)
The custom note (TBD) will read, The component type is the glass sight glass in Level gauge installed for local indication of the water level in the Nuclear Closed Cooling Water Surge Tank. The steek parts are included in the component type Bolting and Piping LRA Table 3.3.1 - During review of the discussion text for Table 1 item 3.3.1-117, the last sentence reads There are no nickel allow components subject to aging management review in the Auxiliary system. This sentence was inadvertently copied and added from Item number 3.3.1-118. The Discussion text for Table 1 Item 3.3.1-117 will read as follows: Consistent with NUREG-1801 with the following clarifications: Glass components in the Auxiliary systems in various environments are addressed in Item 3.3.1-117.
- 9. LRA Section 2.3.3.41 Offgas Building Ventilation (M36) - Question #2 [ITEM 741]
84 LRA Table 2.3.3 The Intended function for Component Type Piping will be changed from Leakage boundary to Leakage boundary, Pressure Boundary. Also, the Intended function for Component Type Valve body will be changed from Leakage boundary to Leakage boundary, Pressure Boundary.
LRA Table 3.3.2 New Rows will be inserted after Rows 22 and 23 that duplicate existing Rows 22 and 23 for the same Component Type, Materia, Environment, Aging Effects Requiring Management, NUREG-1801 Item, Table 1 Item, and Notes. However, the Intended function will be Pressure Boundary instead of Leakage Boundary.
Rows 24 and 25 for Component Type Valve Body will be updated to reflect an Intended function of Pressure boundary instead of Leakage boundary.
M36 System Scoping Boundary Drawing 912-0612 - The Blue highlighting currently shown on the charcoal plenum drain lines at drawing coordinates D-4 and D-6 will be changed to Red highlighting from the exhaust plenum up to and including the solenoid operated drain valves F111A and F111B.
- 10. LRA Section 2.3.3.41Offgas Building Ventilation (M36) - Question #4 [ITEM 743]
LRA Table 3.3.2 Two new rows will be inserted before Row 9 as follows (similar to LRA Table 3.3.2-26 Rows 8 and 9).
Component Type: Duct Intended Function: Pressure boundary Material: Aluminum Environment: Air - indoor, uncontrolled (Ext)
Aging Effect Requiring Management: None Aging Management Program: None Table 1 Item: 3.3.1-113 Notes: C Component Type: Duct Intended Function: Pressure boundary Material: Aluminum Environment: Air - indoor, uncontrolled (Int)
Aging Effect Requiring Management: None Aging Management Program: None Table 1 Item: 3.3.1-113 Notes: C
- 11. LRA Section 2.3.3.41Offgas Building Ventilation (M36) - Question #6 [ITEM 745]
The SCPB technical reviewers believe that LRA Section 2.3.3.63 Turbine Building Ventilation (M35) subsection System Functions (and scoping criteria, if intended function) should be amended to include the function - Prevent the accumulation of combustible gas in the Off Gas Building. [10 CFR 54.4(a)(1), (a)(3) - FP].
Succinctly, the scope of Turbine Building Ventilation system components Subject to Aging Management Review (AMR) may need to be re-evaluated by the Applicant since this system supplies air to the Safety Related Off Gas Building and helps to maintain hydrogen levels throughout the Off Gas Building at less than 4%. Reference UFSAR 9A.4.13.2 Analysis.
85 Request for Additional Information # RAI-10192-R1 has been entered into the eRAI App to push this issue towards resolution.
LRA AMR Evaluation 3.6.2.2.2, Reduced Insulation Resistance due to Presence of Any Salt Deposits and Surface Contamination, and Loss of Material due to Mechanical Wear Caused by Wind Blowing on Transmission Conductors.
Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the AMR discussed in LRA Section 3.6.2.2.2 and the following:
LRA Table 3.6.1, Summary of Aging Management Evaluations for the Electrical Components Evaluated in Chapter VI of NUREG-1801, Item Numbers 3.6.1-2, High-voltage insulators composed of porcelain; galvanized steel; cement exposed to air -
outdoor, and 3.6.1-3, High-voltage insulators composed of porcelain; galvanized steel; cement exposed to air - outdoor.
The LRA states that high-voltage insulators within the license renewal scope are the station post insulators associated with the startup transformers, and the high-voltage insulators (post and suspension insulators) associated with the 345-kilovolt switchyard.
Audit Activities. An onsite audit was performed from October 24-25, 2023.
The table below lists documents that were reviewed by the staff and were found relevant to the AMR evaluation in LRA Section 3.6.2.2.2. The staff will document its review of this information in the SE.
Document Title Revision/Date 4.0 Electrical Aging Management Review Revision 3 WO 200355694 General Maintenance BOP Interbus XFMR LH-2-A 08/24/2011 WO 200410729 Perform General Maintenance of BOP Interbus Transformer LH-1-A 08/17/2012 CR-2019-02862 Interbus Transformer LH1A 13KV Termination Enclosure Found Rusty 03/26/2019 CR-2015-04831 LH-2-A Oil Seepage on 13KV Bushing 04/8/2015 Perry Transmission Yard Memo of Understanding 06/04/2023 ONI-SPI F-1 Off-Site Power Restoration Revision 7 5.15 Perry Switchyard Questionnaire - FE Response 03/08/2022 During the audit, the staff made the following observation:
During the onsite audit, the staff performed a walkdown from the switchyard to the startup transformers of the plant. While visually assessing the conditions of the high-voltage insulator, the staff noted some of the transmission line insulators showed corrosion (rust) at the connection portion between the transmission conductor and the high-voltage insulator. GALL includes an item for managing the aging effects for high-voltage insulators, such as loss of material. PNPPs LRA notes that no aging management program will be created due to no significant aging mechanism affecting high-voltage insulators. Since it observed signs of age-related degradation, the staff requested the applicant to explain how the observed aging effects for high-voltage insulators is managed.
In response to the staffs question, the applicant noted that the disconnect switches (where the corrosion was observed) are supplied with high-voltage insulators as an integral part of the
86 component. The disconnect switches are active components; and therefore, do not require an aging management program. Nonetheless, the applicant noted that they perform periodic cleaning and inspections of the high-Voltage insulators at PNPP to manage the material condition of the disconnect switches.
Corrosion-Material Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:
Further Evaluation (FE) Section 3.2.2.2.5, Loss of Material due to General Corrosion and Fouling that Leads to Corrosion.
LRA Table 3.3.2-32, Leakage Detection System, citing Table 1 Item 3.2.1-048 for loss of material for a stainless-steel valve body exposed internally to condensation.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to FE Section 3.2.2.2.5 and Item 3.2.1-48. The staff will document its review of this information in the SE.
Document Title Revision/Date 302-0642 Residual Heat Removal Revision 0 SOI-E12 Section 7.36 Residual Heat Removal System Instruction Revision 79 304-0649-00101 304-0650-00101 Piping Isometric, Residual Heat Removal System Piping Isometric, Residual Heat Removal System Revision K Revision B 304-0661-0000 Containment Spray - Reactor Building, Plans and Sections (West)
Revision L LRA Sections 3.2.2.2.3.2, 3.2.2.2.6, 3.2.2.2.8, 3.3.2.2.3, 3.3.2.2.5, 3.4.2.2.2, 3.4.2.2.3; AMR Items 3.1.1-107, 3.2.1-063. 3.3.1-120 and 3.4.1-058 Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:
Further Evaluation Section 3.2.2.2.3.2, Loss of Material due to Pitting and Crevice Corrosion.
Further Evaluation Section 3.2.2.2.6, Cracking due to Stress Corrosion Cracking.
Further Evaluation Section 3.3.2.2.3, Cracking due to Stress Corrosion Cracking.
Further Evaluation Section 3.3.2.2.5, Loss of Material due to Pitting and Crevice Corrosion.
Further Evaluation Section 3.4.2.2.2, Cracking due to Stress Corrosion Cracking.
Further Evaluation Section 3.4.2.2.3, Loss of Material due to Pitting and Crevice Corrosion.
AMR Item 3.1.1-107, for stainless steel piping and piping components exposed to air or concrete in the reactor coolant system.
AMR Item 3.2.1-063, for stainless steel piping and piping components exposed to air in engineered safety features systems.
87 AMR Item 3.3.1-120, for stainless steel piping and piping components exposed to air in auxiliary systems.
AMR Item 3.4.1-058, for stainless steel piping and piping components exposed to air in steam and power conversion systems.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the topics listed above. The staff will document its review of this information in the SE.
Document Title Revision/Date Drawing 302-0661 Containment Spray (System E15)
Revision 0 Drawing 302-0691 Standby Liquid Control (System C41)
Revision 0 Drawing 302-0692 Standby Liquid Control (System C41)
Revision 0 LRA Items Associated with Steel-Other Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:
Steel containment vessel electrical penetrations in the Containment Structure.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the topic listed above. The staff will document its review of this information in the SE.
Document Title Revision/Date Spec. No. E-40047 Electrical Penetration Print 03/24/1983 LRA Items Associated with Non-Metallics Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the following:
The polymer sight glass in the Fire Protection System; polymer tank (condensate receiver/separator) in the Safety-Related Instrument Air System; and polymer piping, sight glass (body), strainer body, and valve body in the Service Water and Emergency Service Water Chlorination System.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the topic listed above. The staff will document its review of this information in the SE.
Document Title Revision/Date N/A Vendor Cut Sheet Clean Resource Model DC-202 N/A N/A A0004 Photo N/A Drawing No. 302-0271 Safety Related Instrument Air Revision 0 Drawing No. 8, Sheet No. 0-11 Specification 68-4549-00 N/A During the audit, the staff made the following observations:
The polymer sight glass in the Fire Protection System is Acrylic.
88 The polymer tank (condensate receiver/separator) in the Safety-Related Instrument Air System is polyvinyl chloride (PVC).
The polymer components in the Service Water and Emergency Service Water Chlorination System are as follows:
o Piping - PVC and polyvinylidene fluoride (PVDF) o Sight glass (body) - PVDF o Strainer body - PVC o Valve body - PVDF LRA AMR 3.6.2.2.3, Loss of Material due to Wind-Induced Abrasion, Loss of Conductor Strength due to Corrosion, and Increased Resistance of Connection due to Oxidation or Loss of Pre-load Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the AMR discussed in LRA Section 3.6.2.2.3 and the following:
LRA Table 3.6.1, Summary of Aging Management Evaluations for the Electrical Components Evaluated in Chapter VI of NUREG-1801, Item Numbers 3.6.1-4, Transmission conductors composed of Aluminum; steel exposed to air - outdoor, 3.6.1-5, Transmission connectors composed of aluminum; steel exposed to air - outdoor, 3.6.1-6, Switchyard bus and connections composed of aluminum; stainless steel; galvanized steel exposed to air - outdoor, and 3.6.1-7, Transmission conductors composed of aluminum; steel exposed to air - outdoor.
Audit Activities. An onsite audit was performed from October 24-25, 2023.
The table below lists documents that were reviewed by the staff and were found relevant to the AMR evaluation in LRA Section 3.6.2.2.3. The staff will document its review of this information in the SE.
Document Title Revision/Date 4.0 Electrical Aging Management Review Revision 3 WO 200355694 General Maintenance BOP Interbus XFMR LH-2-A 08/24/2011 WO 200410729 Perform LH-1-A General Maintenance of BOP Interbus Transformer LH-1-A 08/17/2012 Perry Transmission Yard Memo of Understanding 06/04/2023 5.15 Perry Switchyard Questionnaire - FE Response 03/08/2022 ONI-SPI F-1 Off-Site Power Restoration Revision 7 During the audit, the staff made the following observation:
During the onsite audit, the staff performed a walkdown from the switchyard to the startup transformers of the plant. The staff observed transmission conductors, transmission connections, and switchyard buses and connections. The conditions of the in-scope equipment that was observed did not show significant signs of age-related degradation.
89
- 3.
Supplements to the LRA By letters dated August 7, 2024 (ML24220A270), June 27, 2024 (ML24180A010), and July 24, 2024 (ML24206A150), PNPP voluntarily submitted Supplements 1, 2 and 3 to the LRA resulting from discussions held during the audit.
- 4.
Audit Questions Provided to PNPP Over the course of the audit, the NRC staff provided audit questions to PNPP to facilitate the audit discussions (ML24156A154 and ML24156A153), for the non-proprietary and proprietary versions, respectively.
Subject Area Meeting Date Breakout Session: Elastomers 11/20/2023 Breakout Session: One-Time Inspection of ASME Code Class 1 Small-Bore Piping 11/20/2023 Breakout Session: Monitoring of Neutron-Absorbing Materials Other Than Boraflex 11/28/2023 01/02/2024 Breakout Session: Internal Coatings 11/28/2023 01/05/2024 Breakout Session: Selective Leaching 11/29/2023 Breakout Session: ASME XI - ISI (IWB,IWC,IWD) 11/29/2023 Breakout Session: Buried and Underground Piping and Tanks 11/30/2023 01/04/2024 04/16/2024 Breakout Session: Inspection of Internal Surfaces in Misc Piping and Ducting Components 11/30/2023 Breakout Session: Fatigue Monitoring Program 12/04/2023 Breakout Session: Identification of Time-Limited Aging Analyses, TLAA 4.1 12/04/2023 Breakout Session: Fire Protection S/S 12/06/2023 Breakout Session: Water Chemistry 12/06/2023 01/02/2024 03/11/2024 Breakout Session: Stainless Steel 12/07/2023 Breakout Session: Reactor Head Closure Studs Bolting 12/07/2023 Breakout Session: LRA Section 4.6.6 - Fatigue due to Single Recirculation Loop Operation 12/07/2023 Breakout Session: LRA Section 4.6.11 - Allowable Stress Analysis of BOP ASME Code Class 1, 2 and 3 Components 12/07/2023 Breakout Session: Steel-other 12/08/2023 Breakout Session: EQ Analyses of Electrical Equipment, TLAA 4.4 12/13/2023 Breakout Session: Corrosion-Material 12/13/2023 Breakout Session: Non-metallic 12/15/2023 Breakout Session: Steam Generators 12/15/2023 Breakout Session: Open Cycle Cooling Water System 12/15/2023 Breakout Session: External Surfaces Monitoring of Mechanical Components 01/03/2024 Breakout Session: Flow-Accelerated Corrosion 01/04/2024 Breakout Session: Reactor Pressure Vessel Neutron Embrittlement Analyses, TLAA 4.2.X [RARB to Specify Sub-TRPs 59.X]
01/04/2024 Breakout Session: LRA Section 4.2.2 - Upper Shelf 01/04/2024 Breakout Session: LRA Section 4.2.3 - ART 01/04/2024 Breakout Session: Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis, TLAA 4.6 01/19/2024 Breakout Session: Supports 01/19/2024
90 Subject Area Meeting Date Breakout Session: Settlement 01/19/2024 Breakout Session: Fire Protection 02/16/2024 04/10/2024 Breakout Session: Fire Water System 02/16/2024 04/17/2024 Breakout Session: Concrete 02/16/2024 04/19/2024 Breakout Session: Corrosion-Structural 02/16/2024 04/19/2024 Breakout Session: Inaccessible Areas 03/01/2024 04/19/2024 Breakout Session: Scoping and Screening LRA 04/17/2024 Breakout Session: Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis, TLAA 4.6 04/17/2024 04/19/2024 Breakout Session: Bolting Integrity 04/18/2024 Breakout Session: SME Section XI, Subsection IWE 04/18/2024 Breakout Session: ASME Section XI, Subsection IWL 04/18/2024 Breakout Session: ASME Section XI, Subsection IWF 04/18/2024 Breakout Session: Structures Monitoring Program Many Sessions from May through April 2024
- 5.
Applicant Personnel Contacted During Audit Name Affiliation Ted Hilston PNPP Mohammed Alvi PNPP Barry Schneidman PNPP Mark Bensi PNPP George Kyle PNPP Stuart Thickman PNPP Paul Roney PNPP John Grimm PNPP Patrick Saueressig PNPP Ben Spiesman PNPP Justin Truxall PNPP Jacob Zbiegien PNPP Judith Pristov PNPP
- 6.
Exit Meeting An exit meeting was held with the applicant on April 19, 2024, to discuss the results of the regulatory audit. The staff is considering the issuance of RAIs and RCIs to support the completion of the staffs LRA review.