ML25090A201
| ML25090A201 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 05/06/2025 |
| From: | Tyree C NRC/NRR/DNRL/NLRP |
| To: | Wilson C Constellation Energy Generation |
| References | |
| Download: ML25090A201 (1) | |
Text
Christopher D. Wilson Director, License Renewal Constellation Energy Generation, LLC 200 Energy Way Kennett Square, PA 19348
SUBJECT:
CLINTON POWER STATION, UNIT 1 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE LICENSE RENEWAL APPLICATION REVIEW
Dear Christopher Wilson:
By letter dated February 14,2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24045A024), as supplemented by letter dated November 27, 2024 (ML24332A050), December 20, 2024 (ML24355A050), January 30, 2025 (ML25030A182),
March 25, 2025 (ML25084A044), and April 10, 2025 (ML25100A083), Constellation Energy Generation, LLC (Constellation or CEG) applied for license renewal of Facility Operating License No. NPF-62 for Clinton Power Station (CPS), Unit 1, to the U.S. Nuclear Regulatory Commission (NRC). Constellation 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 license renewal.
The NRC staff completed its aging management audit from August 12, 2024 - February 11, 2025, in accordance with the audit plan (ML24163A325). The audit report is enclosed.
If you have any questions, please contact me by email at Christopher.Tyree@nrc.gov.
Sincerely, Chris S. Tyree, Project Manager License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket No. 50-461
Enclosure:
Audit Report cc w/encl: Listserv May 6, 2025 Signed by Tyree, Christopher on 05/06/25
C. Wilson
SUBJECT:
CLINTON POWER STATION, UNIT 1 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE LICENSE RENEWAL APPLICATION REVIEW DATED: MAY 6, 2024 DISTRIBUTION:
EMAIL:
PUBLIC RidsNrrDnrl Resource RidsACRS_MailCTR Resource RidsRgn3MailCenter Resource RidsRgn3Drp Resource RidsRgn3Drs Resource RidsRgn3Ora Resource RidsRgn3Opa Resource RidsNrrOd Resource RidsNrrPMClinton Resource CTyree, NRR/DNRL MYoo, NRR/DNRL AWaldron, NMSS/REFS SKoenick, NMSS/REFS MSampson, NRR/DNRL SLee, NRR/DNRL J.Paige NRR/DNRL BWetzel, NRR/DORL APatz, OEDO SMakor,OEDO SBurnell, HQ/OPA CWolf, OCA DRoth, OGC PChandrathil, RIII/OPA VMitlying, RIII/OPA HLogaras, RIII/FCO BBergeon, RIII/FCO JSteward, RIII/DORS RRuiz, RIII/DORS MDomke, RIII/DORS EMAIL:
christopher.wilson2@constellation.com lydia.dworakowski@constellation.com scott.kauffman@constellation.com kristin.meek@constellation.com iba.ellofletcher@constellation.com duane.avery@constellation.com ADAMS Accession Nos.: ML25090A201 Via Email NRR-106 OFFICE PM:NLRP:DNRL LA:NLRP:DNRL BC:NPHP:DNRL BC:ELTB:DEX NAME CTyree KBratcher MMitchell PKoch DATE 4/09/2025 04/04/2025 11/04/2024 2/7/2025 OFFICE BC:NCSG:DNRL BC:NVIB:DNRL BC:ESEB:DEX BC:SNSB:DSS NAME SBloom ABuford ITseng DMurdock DATE 2/27/2025 2/6/2025 3/5/2025 3/12/2025 OFFICE A/BC:NLRP:DNRL PM:NLRP:DNRL NAME MYoo CTyree DATE 5/5/2025 5/6/25
Enclosure Aging Management Audit Clinton Power Station, Unit 1 License Renewal Application August 12, 2024 - February 11, 2025 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:
50-461 License No:
NPF-62 Licensee:
Constellation Energy Generation, LLC Facility:
Clinton Power Station (CPS), Unit 1 Location:
Rockville, Maryland Clinton, Illinois Dates:
August 12, 2024 - February 11, 2025 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 Mark Yoo, Acting Chief License Renewal Projects Branch Division of New and Renewed Licenses Patrick Koch, Acting Chief Long Term Operations and Modernization Branch Division of Engineering and External Hazards Darell Murdock, Acting Chief Nuclear Systems Performance Branch Division of Safety Systems Matthew A. Mitchell, Chief Piping and Head Penetrations Branch Division of New and Renewed Licenses
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 Brian Correll Kenn Miller ELTB/DEX ELTB/DEX ELTB/DEX George Wang Structural, Civil, Geotech Engineering (ESEB)/DEX Si-Hwan Park ESEB/DEX Dan Hoang ESEB/DEX George Thomas ESEB/DEX Ata Istar Se-Kwon Jung Yi-Lun Chu ESEB/DEX ESEB/DEX 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 Miranda Ross Devendra Ray Tony Gardner NCSG/DNRL NCSG/DNRL NCSG/DNRL NCSG/DNRL NCSG/DNRL Ali Rezai Piping and Head Penetrations (NPHP)/DNRL Bart Fu NPHP/DNRL Varoujan Kalikian Seung Min Karen Sida NPHP/DNRL NPHP/DNRL NPHP/DNRL On Yee Vessels and Internals (NVIB)/DNRL Eric Palmer NVIB/DNRL David Dijamco Emma Haywood NVIB/DNRL NVIB/DNRL Michael Benson James Medoff Carol Moyer John Tsao NVIB/DNRL NVIB/DNRL NVIB/DNRL NVIB/DNRL
iv Brandon Wise Nuclear Methods and Fuel Analysis (SFNB)/Division of Safety Systems (DSS)
Angelo Stubbs Containment and Plant Systems (SCPB)/Division of Safety Systems (DSS)
Nageswara Karipineni SPCB/DSS Gordon Curran Nicholas Soliz Rob Atienza SCPB/DSS SCPB/DSS SCPB/DSS Fred Forsaty Santosh Bhatt Charley Peabody Nuclear Systems Performance (SNSB)/DSS SNSB/DSS SNSB/DSS Chris Tyree License Renewal Projects Branch (NLRP)/DNRL Bill Rogers NLRP/DNRL
v TABLE OF CONTENTS TABLE OF CONTENTS.....................................................................................................v ACRONYMS AND ABBREVIATIONS.............................................................................viii 1.
Introduction..............................................................................................................1 2.
Audit Activities.........................................................................................................2 LRA Section 2.1, Scoping and Screening Methodology....................................................2 LRA AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program.....................................................................................................................6 LRA AMP B.2.1.2, Water Chemistry..................................................................................7 LRA AMP B.2.1.3, Reactor Head Closure Stud Bolting Program......................................9 LRA AMP B.2.1.4, BWR Vessel ID Attachment Welds...................................................11 LRA AMP B.2.1.5, BWR Feedwater Nozzle....................................................................12 LRA AMP B.2.1.6, BWR Control Rod Drive Return Line (CRDRL) Nozzle.....................12 LRA AMP B.2.1.7, BWR Stress Corrosion Cracking Program........................................13 LRA AMP B.2.1.8, BWR Penetrations.............................................................................14 LRA AMP B.2.1.9, BWR Vessel Internals, and SLRA TLAA Section 4.2.11, Top Guide IASCC Analysis...............................................................................................................15 LRA AMP B.2.1.10, Flow-Accelerated Corrosion............................................................16 LRA AMP B.2.1.11 Bolting Integrity.................................................................................17 LRA AMP B.2.1.12, Open Cycle Cooling Water..............................................................19 LRA AMP B.2.1.13, Closed Treated Water Systems......................................................20 LRA AMP B.2.1.14 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems..........................................................................................21 LRA AMP B.2.1.15, Compressed Air Monitoring.............................................................23 LRA AMP B.2.1.16, Fire Protection Program..................................................................24 LRA AMP B.2.1.17, Fire Water System Program............................................................26 LRA AMP B.2.1.18, Aboveground Metallic Tanks...........................................................29 LRA AMP B.2.1.19, Fuel Oil Chemistry...........................................................................30 LRA AMP B.2.1.20, Reactor Vessel Surveillance...........................................................31 LRA AMP B.2.1.21, One-Time Inspection.......................................................................32 LRA AMP B.2.1.22, Selective Leaching..........................................................................33 LRA AMP B.2.1.23, One-time Inspection of ASME Code Class 1 Small-Bore Piping.....34 LRA AMP B.2.1.24, External Surfaces Monitoring of Mechanical Components..............35 LRA AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components....................................................................................................................36 LRA AMP B.2.1.26, Lubricating Oil Analysis...................................................................36 LRA AMP B.2.1.27, Monitoring of Neutron-Absorbing Materials Other than Boraflex.....37 LRA AMP B.2.1.28, Buried and Underground Piping and Tanks....................................39
vi LRA AMP B.2.1.29, ASME Section XI, Subsection IWE.................................................41 LRA AMP B.2.1.30, ASME Section XI, Subsection IWL..................................................43 LRA AMP B.2.1.31, ASME Section XI, Subsection IWF.................................................44 LRA AMP B.2.1.32, 10 CFR Part 50, Appendix J............................................................48 LRA AMP B.2.1.33 Masonry Walls..................................................................................49 LRA AMP B.2.1.34, Structures Monitoring......................................................................50 LRA AMP B.2.1.35, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants......................................................................................................52 LRA AMP B.2.1.36, Protective Coating Monitoring and Maintenance Program..............54 LRA AMP B.2.1.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.............................56 LRA AMP B.2.1.38, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits...................................................................................................57 LRA AMP B.2.1.39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.....................................................................59 LRA AMP B.2.1.40, Metal Enclosed Bus.........................................................................60 LRA AMP B.2.1.41, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.....................................................................62 LRA AMP B.2.1.42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks..........................................................................................63 LRA AMP B.3.1.1, Fatigue Monitoring.............................................................................64 LRA AMP B.3.1.2, Environmental Qualification (EQ) of Electric Components................66 LRA TLAA Section 4.1, Identification and Evaluation of Time-Limited Aging Analyses (TLAAS)...........................................................................................................................67 LRA TLAA Section 4.2.1, Reactor Pressure Vessel and Internals Neutron Fluence Analyses..........................................................................................................................69 LRA TLAA Sections 4.2.2 and 4.2.3 (Upper-Shelf Energy and Adjusted Reference Temperature)...................................................................................................................69 LRA TLAA Section 4.2.4, Reactor Pressure Vessel Pressure-Temperature (P-T) Limits
.........................................................................................................................................72 LRA TLAA Section 4.2.5, Reactor Pressure Vessel Circumferential Weld Failure Probability Analyses.......................................................................................................73 LRA TLAA Section 4.2.6, Reactor Pressure Vessel Axial Weld Failure Probability Analyses.........................................................................................................................74 LRA TLAA Section 4.2.8, Jet Pump Beam Bolts and Core Plate Bolts Preload Relaxation Analyses..........................................................................................................................75 LRA TLAA Section 4.2.9, Core Shroud Repair Stabilizer Assembly Bracket Preload Relaxation Analysis.........................................................................................................76 LRA TLAA Section 4.2.10, Reactor Pressure Vessel Core Support Structure Strain Evaluation........................................................................................................................77
vii LRA TLAA Section 4.3.1, Transient Cycle And Cumulative Usage Projections For 60 Years...............................................................................................................................79 LRA TLAA Section 4.3.2, ASME Section III, Class 1 and Environmentally Assisted Fatigue Analyses.............................................................................................................80 LRA TLAA Section 4.3.3, ASME Section III, Class 1 Components.................................81 LRA TLAA Section 4.3.4, ASME Section III, Class 1 Fatigue Exemptions......................83 LRA TLAA Section 4.3.5, ASME Section III, Class 2, Class 3, and ANSI B31.1 Allowable Stress Analyses and Related High-Energy Line Break (HELB) Selection Analyses.......84 LRA TLAA Section 4.3.6, High-Energy Line Break (HELB) Analyses Based On Cumulative Fatigue Usage..............................................................................................85 LRA TLAA Section 4.3.7, Reactor Vessel Internals........................................................86 LRA TLAA Section 4.4, Environmental Qualification of Electric and Mechanical Equipment.......................................................................................................................88 LRA TLAA Section 4.6, Primary Containment Fatigue Analyses....................................89 LRA TLAA Section 4.7.1, CPS Crane Cyclic Loading Analyses TLAA.........................93 LRA TLAA Section 4.7.2, Main Steam Line Flow Restrictor Erosion Analysis................94 LRA TLAA Section 4.7.3, Generic Letter 81-11 Crack Growth Analysis to Demonstrate Conformance to the Intent of NUREG-0619....................................................................95 LRA TLAA Section 4.7.4, Reactor Shield Wall Fluence..................................................96 LRA TLAA Section 4.7.5, Hydraulic Control Units...........................................................97 LRA TLAA Section 4.7.6, Fuel Pool Storage Rack Fatigue Analysis..............................98 LRA TLAA Section 4.7.7, Refueling Bulkhead Ring Flaw Evaluation..............................99 LRA TLAA Section 4.7.8, Fuel Pool Cleanup System, Flow Control Valves.................100 AMR Items Not Associated with an AMP......................................................................101 3.
Supplements to the LRA......................................................................................105 4.
Audit Questions Provided to CPS........................................................................105 5.
Applicant Personnel Contacted During Audit.......................................................107 6.
Exit Meeting.........................................................................................................108
viii ACRONYMS AND ABBREVIATIONS ADAMS Agencywide Documents Access and Management System AMP Aging Management Program AMR Aging Management Reviews ASME American Society of Mechanical Engineers BWR Boiling Water Reactor BWRVIP Boiling Water Reactor Vessel and Internals Project Program CEG Constellation Energy Generation, LLC CLB Current licensing basis CMTR Certified material test reports CPS Clinton Power Station CRDRL Control Rod Drive Return Line CUF Cumulative Usage Factor CWSH Circulating water screenhouse DBD design-basis documents DBE Design basis event DG Diesel Generator E&IC Electrical and instrumentation and control EAF Environmentally Assisted Fatigue EC Engineering Change ECCS Emergency core cooling system EMI Electromagnetic interference EPC Erosion in Piping and Components EPRI Electric Power Research Institute EQ Environmental Qualification ESF Engineered Safety Features FE Further evaluation FP Fire protection FSAR Final safety analysis report FW Feedwater FWST Firewater Storage Tank GALL Generic Aging Lessons Learned for License GEH General Electric Hitachi HELB High-Energy Line Break HSB High-strength bolting IPA Integrated plant assessment ISI Inservice inspection ISP Integrated surveillance program LAR License amendment request LR License renewal LRA License renewal application MC Metal containment MLC Check with Lydia crane leak MWPH Make-up Water Pump House NDE Nondestructive examination
ix NRC U.S. Nuclear Regulatory Commission OBE Operational basis earthquake OE Operating experience PBD Program basis document PCR Project change request PM Preventive maintenance PMMR PM Modification Request QA Quality assurance RAI Requests for additional information RCI Requests for confirmation of information RCIC Reactor Core Isolation Cooling RPV Reactor pressure vessel RR Reactor recirculation RTNDT nil-ductility reference temperature RVI Reactor vessel internal RWCU Reactor Water Cleanup SBO Station blackout SC Structures and the components SCC Reactor Water Cleanup SE Safety Evaluation SPD Single phase detection SR Safety-related SRM Source range monitor SRP standard review plan SRV Safety relief valve SSC Systems, structures, and components SSE Safe shutdown earthquake TLAA Time-Limited Aging Analysis UAT Unit auxiliary transformer USAR Updated Safety Analysis Report USE Upper-shelf energy UT Ultrasonic Testing WO Work order
1 Report for the Aging Management Audit Clinton Power Station, Unit 1 License Renewal Application
- 1. Introduction The U.S. Nuclear Regulatory Commission (NRC) staff conducted an aging management audit of Constellation Energy Generation, LLC (Constellation, CEG or 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 Facility Operating License No. NPF-62 for Clinton Power Station (CPS), 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. Constellation searched their OE database and provided the results for the associated AMPs and TLAAs for NRC staff 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 Constellations AMPs, AMR items, and TLAAs for CPS verify Constellations 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
2 application (LRA) the AMPs described in the GALL-LR Report. By referencing the GALL-LR 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 on-site.
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 CPS SSCs that are included within the scope of license renewal (LR).
3 10 CFR 54.21, Contents of Application - Technical Information, requires that each application for LR contain an integrated plant assessment (IPA), which lists, for SSCs within the scope of LR, the structures and the components (SCs) that are subject to an AMR. Section 10 CFR 54.4(a), Scope, provides the 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 on-site scoping and screening methodology audit, from September 4-5, 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 staff reviewed the methodology used by the applicant to identify mechanical, structural, and electrical SSCs within the scope of LR (scoping). In addition, the staff reviewed documentation pertinent to the scoping process. The staff 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 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 FSAR, 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.
The staff reviewed the implementing procedures and results 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,
4 external events, and natural phenomena) that were applicable to CPS. 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 FSAR 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, DBD, 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, DBD, 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 (E&IC) systems and initially included all E&IC systems, and E&IC components contained in mechanical systems, within the scope of LR by default.
B. Screening Methodology The staff 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 that were included within scope in accordance with 10 CFR 54.4(a)(2) and subject to AMR were also identified on the LR drawings.
Structural components that support intended functions (e.g., support, enclosure protection, fire barrier, flood barrier, pressure boundary) are included in the scope of LR.
Structural drawings are reviewed to identify passive, long-lived SCs.
Electrical and instrumentation and control components, which were included within the scope of renewal in accordance with the bounding method used for E&IC, were evaluated in accordance with the guidance contained in NEI 95-10 to identify the passive and long-lived components subject to AMR.
5 The staff 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 staff 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 plant drainage system. The staff reviewed applicable portions of the FSAR, scoping and screening reports, and LR drawings and performed walkdowns to confirm information contained in the LRA.
D. Aging Management Program Quality Assurance Attributes The staff 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.
LRA Section Appendix A.1.5 stated that the QA Program for CPS 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. CPS 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 CPS 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 CPS 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 staffs 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.
6 Documents Reviewed The documents 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 CL-SSBD-A1 10CFR 54.4(a)(1) Safety-Related Systems Scoping and Screening Basis Document Rev. 3 CL-SSBD-A2 10CFR 54.4(a)(2) Safety-Related Systems Scoping and Screening Basis Document Rev. 0 CL-SSBD-AOT Abnormal Operational Transients Scoping and Screening Basis Document Rev. 1 CL-SSBD-ATWS 10CFR 54.4(a)(3) ATWS Systems Scoping and Screening Basis Document Rev. 1 CL-SSBD-EQ 10CFR 54.4(a)(3) Environmental Qualification Systems Scoping and Screening Basis Document Rev. 4 CL-SSBD-FP 10CFR 54.4(a)(3) Fire Protection Scoping and Screening Basis Document Rev. 4 CL-SSBD-SBO 10CFR 54.4(a)(3) Station Blackout Systems Scoping and Screening Basis Document Rev. 3 CL-SSBD-SCRN Structures, Component, and Commodity Types, with Active, Passive Determinations, and Intended Functions Rev. 1 CL-SSBD-SSL License Renewal Systems and Structures Scoping and Screening Basis Document Rev. 3 CL-SSBD-TBA2 Evaluation of Safety-Related Components Located in Nonsafety-Related Structures Scoping and Screening Basis Document Rev. 1 LRA AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program Summary of Information in the Application LRA Section B.2.1.1 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.
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 experience (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.
7 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 CL-PBD-AMP-XI.M1 Clinton Power Station, Unit 1 License Renewal Project ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program Basis Document Rev. 1 02/06/2024 ER-CL-330-1001 Clinton Power Station Unit 1, ISI Program Plan, Fourth Ten-Year Inspection Interval (Constellation Proprietary)
Rev. 0 03/25/2020 C1R17-APR-02 GE Hitachi UT Examination Summary Sheet, Nozzle-to-Safe End N1B-W-1 05/23/2017 AR04012873 UT Indication in N1B-W-1 05/19/2017 CC-AA-309-1001 SIA-1700454.301 Recirculation Loop Weld N1B-W-1 Flaw Evaluation - 2017 (Constellation Proprietary)
Rev. 9 05/25/2017 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 FSAR Supplement. The staff verified that this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.2, Water Chemistry Summary of Information in the Application The LRA states that AMP B.2.1.2, Water Chemistry, is an existing program with one exception that is consistent with the program elements in GALL-LR 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 GALL-LRReport AMP in the SE.
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 CL-PBD-AMP-XI.M2 Clinton Power Station, Unit 1 License Renewal Project Water Chemistry Rev. 1 AR 04057349 System Dissolved Oxygen is Higher than Expected 09/29/2017 AR 04192481 Reactor Water Chlorides Above Action Level 1 AL-1 Post C1M23 11/7/2018
8 Document Title Revision / Date PI-AA-126-1001-F-01 Condensate Chemistry Self-Assessment (Constellation Proprietary)
Rev. 2 PI-AA-125-1001 4010.02, Chemistry Off-Normal entered (Sulfates >
AL1) (Constellation Proprietary) 11/10/2022 CY-AB-120-0001 Chemistry Action Level Impact Assessments, Engineering Evaluations and Cleanup Projections (Constellation Proprietary)
Rev. 3 CY-AB-120-1000 BWR Strategic Water Chemistry Plan (Constellation Proprietary)
Rev. 15 CY-AB-120-1000-F-02 Clinton Strategic Water Chemistry Plan Appendix (Constellation Proprietary)
Rev. 6 CY-AB-120-100 Reactor Water Chemistry (Constellation Proprietary)
Rev. 21 CY-AB-120-110 Condensate and Feedwater Chemistry (Constellation Proprietary)
Rev. 28 CY-AB-120-200 Storage Tanks Chemistry (Constellation Proprietary) Rev. 15 CY-AB-120-300 Spent Fuel Pool (Constellation Proprietary)
Rev. 20 CY-AB-120-310 Suppression Pool/Torus Chemistry (Constellation Proprietary)
Rev. 12 CY-AB-120-320 Control Rod Drive Water Chemistry (Constellation Proprietary)
Rev. 10 CY-AB-120-1100 Reactor Water Hydrogen Water Chemistry, Noble Chem and Zinc Injection (Constellation Proprietary)
Rev. 17 WO 04685556 Level Transient on MSDT 1A During Downpower 05/15/2018 EPRI-3002002623 BWRVIP-190: BWR Vessel and Internals Project:
BWR Water Chemistry Guidelines (Constellation Proprietary)
Rev. 1 N/A 2019 BWR Water Chemistry Guidelines Interim Guidance (Constellation Proprietary)
March 2019 EC 637343 Install Condensate Polishing Pre-Filters G, H and J Rev. 000 AR 04488488 FW Iron in Action Level 1 Greater than 96 Hours 03/30/2022 AR 04727170 Cycle 21 Feedwater Iron Above Cycle Average Goal 12/29/2023 LR-CPS-M05-1077 Sh.1 P&ID Standby Liquid Control (SC) Clinton Power Station Unit 1 Clinton, Illinois Rev. A 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-LR Report AMP.
9 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-LR Report AMP.
The staff also audited the description of the Water Chemistry program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.3, Reactor Head Closure Stud Bolting Program Summary of Information in the Application The LRA states that AMP B.2.1.3, Reactor Head Closure Stud Bolting Program, is an existing program that is 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 operating experience (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 SE.
Document Title Revision /
Date CL-PBD-AMP-XI.M3 Reactor Head Closure Stud Bolting Program Basis Document Rev. 3 GE 007N8539 Clinton Unit 1 License Renewal Top Head Closure CMTR Data Review (GE Hitachi Proprietary)
Rev. 0, 7/2023 N/A Purchase Order 00494962 Rev. 4 N/A Certification for Purchase Order 00494962 10/12/2013 N/A Inservice Inspection Summary Report - C1R13 03/21/2012 N/A Inservice Inspection Summary Report - C1R17 08/25/2017 N/A Inservice Inspection Summary Report - C1R19 01/14/2020 ER-CL-330-001 Clinton Power Station Unit 1 ISI Program Plan Fourth Ten-Year Inspection Interval (Constellation Proprietary)
Rev. 0 ER-AA-335-047 NonDestructive Examination (NDE) Procedure and Personnel Certification Review and Approval (Constellation Proprietary)
Rev. 8 ER-AA-330-009 ASME Section XI Repair/Replacement Program (Constellation Proprietary)
Rev. 18
10 Document Title Revision /
Date ML20255A211 Safety Evaluation by the Office of Nuclear Reactor Regulation Alternative Request I4R-07 Regarding Volumetric Examination of Reactor Pressure Vessel Threads in Flange 09/11/2020 During the audit, the staff verified the applicants claim that the scope of program, 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.
During the audit, the staff made the followingobservations:
The staff verified that the CPS reactor pressure vessel closure studs, nuts and washers are SA 540 Grade B24 and that the stud assemblies have a specified minimum yield strength of 130 ksi and a maximum ultimate tensile strength of 170 ksi (GE Report 007N8538).
The applicant stated the repair and replacement of reactor head closure stud material assures that any studs procured have measured yield strength of less than 150 ksi (ER-AA-330-009). The staff noted that CPS replaced a reactor head closure stud in 2013 and that the stud had a measured yield strength of less than 150 ksi.
The staff verified the Code of Record for CPS is the 2013 Edition, no Addenda of ASME Boiler & Pressure Vessel Section XI and that CPS is in the 4th in-service inspection interval with beginning and ending dates of July 1st, 2020, and June 30th, 2030, respectively.
The staff verified in the examination results of the most recent ASME Code Section XI in-service inspection summary reports, listed in the table above, that there were no unacceptable indications for any reactor head closure studs, threads in flange, nuts, or washers.
The staff confirmed the CPS closure stud holes (i.e., flange threads) do not have the bushing design (CL-PBD-AMP-XI.M3).
The staff verified that a phosphate coating was 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 Reactor Head Closure Stud Bolting Program provided in the FSAR supplement. The staff verified this descriptionisconsistent with the description provided in the SRP-LR Report.
11 LRA AMP B.2.1.4, BWR Vessel ID Attachment Welds Summary of Information in the Application The LRA states that AMP B.2.1.4, BWR Vessel ID Attachment Welds, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M4, BWR Vessel ID Attachment Welds.
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: (cracking, stress corrosion).
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 CL-PBD-AMP-XI.M4 Program Basis Document - BWR Vessel ID Attachment Welds Rev. 1 EC619862 Evaluation of In Vessel Visual Inspection Notification Reports C1R17 05/2017 Clinton Power Station - ISI IN VESSEL INSPECTION PROGRAM 07/25/ 2022 ER-AB-331-1001 Boiling Water Reactor (BWR) Internals Program (Constellation Proprietary)
Rev. 10 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 is consistent with the corresponding elements of the GALL-LR Report AMP.
During the audit, the staff made the following observations:
The staff noted that LRA Section B.2.1.4 indicated that the AMP substitutes the inspection and evaluation recommendations within BWRVIP-48-A for the requirements within ASME Code,Section XI. However, LRA Section A.2.1.4 describes the AMP as including the inspection and evaluation recommendations within BWRVIP-48-A and requirements within ASME Code,Section XI. The staff will consider issuing an RAI in order to obtain the information necessary to address the inconsistency between LRA Section B.2.1.4 and LRA Section A.2.1.4 and whether the AMP will be adequate to manage the effects of aging of the reactor vessel attachment welds.
The staff also audited the description of the LRA AMP provided in the FSAR supplement. As described above, the staff noted a discrepancy in the description of the AMP and whether the AMP will be adequate to manage the effects of aging of the reactor vessel attachment welds.
12 The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.
LRA AMP B.2.1.5, BWR Feedwater Nozzle Summary of Information in the Application The LRA states that AMP B.2.1.5, BWR Feedwater Nozzle, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M5, BWR Feedwater Nozzle.
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: (cracking).
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 CL-PBD-AMP-XI.M5 Program Basis Document - BWR Feedwater Nozzle Rev. 1 Updated Safety Analysis Report - Section 5.2 and 5.3 Rev. 21 GE Hitachi Examination Summary Sheet - C1R20 -
ASME Item B3.90 - Nozzle to Shell (N4 Nozzle) 10/2021 NUREG-0619 BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking: Resolution of Generic Technical Activity A-10 (Technical Report)
Rev. 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 element(s) 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 provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.6, BWR Control Rod Drive Return Line (CRDRL) Nozzle Summary of Information in the Application The LRA states that AMP B.2.1.6, BWR Control Rod Drive Return Line (CRDRL) Nozzle, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M6, BWR Control Rod Drive Return Line (CRDRL) Nozzle.
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: (cracking).
13 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 CL-PBD-AMP-XI.M6 Program Basis Document - BWR Control Rod Drive Return Line Nozzle Rev. 1 Updated Safety Analysis Report - Section 5.2 and 5.3 Rev. 21 GE Hitachi Examination Summary Sheet - C1R19 -
ASME Item B3.90 - Nozzle to Shell - N10 Nozzle 09/2019 NUREG-0619 BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking: Resolution of Generic Technical Activity A-10 (Technical Report)
Rev. 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 element(s) 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 provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.7, BWR Stress Corrosion Cracking Program Summary of Information in the Application The LRA states that AMP B.2.1.7, BWR Stress Corrosion Cracking is an existing condition monitoring and mitigative 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 operating experience (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 evaluated 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 CL-PBD-AMP-XI.M7 Clinton Power Station Unit 1, License Renewal Project: BWR Stress Corrosion Cracking Program Rev. 1 02/06/2024
14 Document Title Revision / Date ER-AA-330 Conduct of lnservice Inspection Activities (Constellation Proprietary)
Rev. 19 AR 04012873 UT Indication in N1B-W1 05/19/2017 ER-AB-331-1001 Exelon Generation, Boiling Water Reactor (BWR)
Internals Program (Constellation Proprietary)
Rev. 10 CL-C1R20-ISI Summary Report Clinton Power Station Unit 1, Post Outage 90-Day lnservice Inspection (ISI) Summary Report -
Jan 2022 Inspection Results Rev. 0 01/2022 During the audit, the staff verified applicants claim that portions of 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 AMP provided in the FSAR Supplement. The staff verified that this description is consistent with the description provided in the SRP-LR Report.
LRA AMP B.2.1.8, BWR Penetrations Summary of Information in the Application The LRA states that AMP B.2.1.8, BWR Penetrations, is an existing program that is 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 operating experience (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.
Document Title Revision /
Date CL-PBD-AMP-XI.M8 Program Basis Document - BWR Penetrations Rev. 1 /
07/17/2023 N/A In-Vessel Inspection (IVI) Program Plan Rev. 10 /
07/25/2022 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 LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
15 The staff also audited the description of the LRA BWR Penetrations provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-LR Report.
LRA AMP B.2.1.9, BWR Vessel Internals, and SLRA TLAA Section 4.2.11, Top Guide IASCC Analysis Summary of Information in the Application The LRA states that AMP B.2.1.9, BWR Vessel Internals, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.M9, BWR Vessel Internals.
SLRA section 4.2.11 Top Guide IASCC Analysis, discusses the fluence projections on the RPV top guide and the applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(iii).
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 CL-PBD-AMP-XI.M9 Program Basis Document - BWR Vessel Internals Rev.1 IR 4284830 In Vessel Inspection Results and Disposition IR 201906 Steam Dryer Support Brackets As-Found Condition N/A Clinton Power Station In-Vessel Inspection Program Plan Rev. 10 EPRI Letter 2021-030 Potential Non-Conservatism in EPRI Report, BWRVIP-100 Rev. 1-A, 3002008388 and Impacted BWRVIP Reports 03/22/2021 IR 1299448 Relevant Indication on Core Shroud Weld V11 12/08/2011 IR 4406225 EPRI BWRVIP-235 DLL Potential Non-Conservatism 03/03/2021 IR 4410934 BWRVIP-235 and Other Impacted EPRI Docs 03/23/2021 EC 634131 Potential Part 21 for BWRVIP-235 & Other Core Shroud Documents 04/29/2021 EC 386910 Evaluation of GE INRs C1R13 Rev. 0 EPRI Letter 2021-028 Status Update on Potential Non-Conservatism in EPRI Report, BWRVIP-100 Rev. 1-A, 3002008388 and EPRI Software, BWRVIP-235, 1018251 (appended to BWRVIP-76, Revision 1-A) (EPRI Proprietary) 03/19/2021 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
16 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 staff reviewed the applicants response to EPRI Letter 2021-030.
The staff reviewed the applicant's disposition of a flaw in core shroud weld V11 and reevaluation as a result of EPRI Letter 2021-030.
LRA AMP B.2.1.10, Flow-Accelerated Corrosion Summary of Information in the Application The LRA states that AMP B.2.1.10, Flow-Accelerated Corrosion, is an existing program that, with an exception, is consistent with the program elements in GALL-LR Report AMP XI.M17, Flow-Accelerated Corrosion, as modified 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 CL-PBD-AMP-XI.M17 Flow-Accelerated Corrosion Program Basis Document Rev. 01 ER-AA-430 Conduct of Flow-Accelerated Corrosion Activities (Constellation Proprietary)
Rev. 10 ER-AA-430-1001 Guidelines for Flow-Accelerated Corrosion Activities (Constellation Proprietary)
Rev. 15 ER-AA-430-1004 Erosion in Piping and Components (EPC) Guide (Constellation Proprietary)
Rev. 5 14-0358-TR-001 Altran - Erosion in Piping and Components Program Basis Document Rev. 0 LR-CPS-M05-1074 Drawing - Piping and Instrument Diagram for High Pressure Core Spray System Rev. A AR04280463 Low Pressure Core Spray Piping Below Minimum Wall Thickness Between 1E21-D001 and 1E21-F011 09/19/2019 AR04424407 1CC48AA Ultrasonic Test Results Below Acceptance Criteria 05/18/2021 CL-AMPBD-CTW Closed Treated Water System Inspection Sample Basis Document, Attachment 7, Erosion Sample Population, Selection and Inspection Rev. 1
17 Document Title Revision / Date ER-AA-5400-1001 Raw Water Piping Integrity Management Guidance,, Corrosion Rate and Remaining Life Evaluation (Constellation Proprietary)
Rev. 12 AR04296225 Residual Heat Removal C Room Cooler Leakage Due to Erosion Corrosion 11/11/2019 AR04352219 Residual Heat Removal 1A Room Cooler Pin Hole Leak Due to Erosion Corrosion 06/24/2020 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 verified the applicants claim that aspects of the scope of program, detection of aging effects, monitoring and trending, and acceptance criteria program elements, not associated with the exception identified in the LRA, are consistent with the corresponding program elements inthe GALL-LR Report AMP.
The staff also audited the description of the Flow-Accelerated Corrosion program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.11 Bolting Integrity Summary of Information in the Application The LRA states that AMP B.2.1.11, Bolting Integrity, is an existing program with enhancement(s) that will be consistent with the program elements in GALL-LR Report AMP XI.M18, Bolting Integrity. 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 and provided by the applicant via the ePortal.
For the operating experience (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 program. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-PBD-AMP-XI.M18 AMP Basis Document: CPS, Unit 1, License Renewal Project - Bolting Integrity Rev. 1 FSAR CPS Final Safety Analysis Report Rev. 23
18 Document Title Revision / Date CC-AA-102 Design input and Configuration Change Impact Screening (Constellation Proprietary)
Rev. 34 ER-AA-2030 Conduct of equipment reliability manual (Constellation Proprietary)
Rev. 28 MA-AA-410 Bolting integrity aging management program (Constellation Proprietary)
Rev. 3 MA-AA-736-600 Torquing and tightening of bolted connections (Constellation Proprietary)
Rev. 13 MA-CL-736-6001 Tightening of flange connections (Constellation Proprietary)
Rev. 1 PES-S-010 Fasteners, Exelon Standard (Constellation Proprietary)
Rev. 5 PES-S-003 In-storage maintenance of nuclear material (Constellation Proprietary)
Rev. 3 AR 4104823 0WE050 valve bonnet bolt found broken off 02/16/2018 AR 4136734 Drivers bolt inspection locates loose jam nut on ECCS strainer 05/11/2018 AR 4136970 Drivers found 6 loose jam nuts on 1E12D331 ECCS strainer 05/12/2018 AR 4187378 Division 2 DG 12 cyl fuel pump bolt found loose 10/24/2018 AR 4184866 Division 2 DG 12 cyl fuel pump bolt found loose 10/18/2018 AR 04308427 WO 4989167-02 found oil leak at oil filter housing bolt 01/07/2020 AR 03960667 EOID: OACO1T Tank-Piping degradation - flange and bolts, a small pile of acid residue 01/08/2017 AR 04309402 Evaluate safety related bolting 01/10/2020 AR 02611436 Seismic Test for SPD relay panel, not tested per requirement - Verify bolting torque 01/12/2016 WO 01765922 Divers inspect/clean screenhouse structure 12/12/2016 EPRI NP-5769 Degradation and Failure of Boiling in Nuclear Power Plants 04/1988 EPRI TR-104213 Bolted Joint Maintenance & Application Guide 12/1995 NUREG-1339 Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants 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.
During the audit the staff made the following observation:
The Fire Pump closure bolting was not considered in Enhancement 1.
AMP XI.M18 program was considered for the Table 1 Item: 3.3.2-17 (GALL #s:
V.D2.EP-73) with Note E,1 from XI.M2, Water Chemistry, AMP Program.
19 AMP XI.M18 program was considered for the Table 1 Item: 3.3.1-64 (GALL #s: VII.G.A-
- 33) with Note E,1 from XI.M27, Fire Water System, AMP Program.
In Table 3.3.2-12, Open Cycle Cooling System, Note H, 2, was used for the Component Type of bolting (closure), with Material of Carbon and Low Alloy Steel, under Environment of Raw Water (External), where no specific line-items were identified in the LR SRP (NUREG-1800) and GALL (NUREG-1801). In the LRA, H is defined as Aging effect not in NUREG-1801 for this component, material and environment combination, and 1 is defined as Consistent with operating experience contained in NUREG-2191 (Item VII.C1.A-787a), PVC piping components in a Raw Water environment are susceptible to Loss of Material. Components with this material and environment combination are managed by the Open-Cycle Cooling Water System AMP.
The staff also audited the description of the LRA AMP provided in the FSAR supplement in Section A.2.1.11, Bolting Integrity. The staff verified this description is consistent with the description provided in the SRP.
LRA AMP B.2.1.12, Open Cycle Cooling Water Summary of Information in the Application LRA Section B.2.1.12 states that the Open Cycle Cooling Water System program is an existing program with enhancements that will be consistent with GALL-LR Report AMP XI.M20, Open Cycle Cooling Water System program, as modified by LR ISG 2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, and LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation.
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 CL-PBD-AMP-XI.M20 Open-Cycle Cooling Water System Rev. 3 1003.10 Clinton Power Station CPS Program for NRC Generic Letter 89-13 Markup (Constellation Proprietary)
Rev. 008 ER-AA-340 GL 89-13 Program Implementing Procedure (Constellation Proprietary)
Rev. 11 2602.01 Heat Exchanger Performance of Shutdown Service Water Coolers Covered by NRC Generic Letter 89-13 (Constellation Proprietary)
Rev. 019 2700.12 Division 1 SX System Flow Balance Verification (Constellation Proprietary)
Rev. 015
20 Document Title Revision / Date 2700.20 RHR A(B) Heat Exchanger, 1E12B001A(B) Thermal Performance Test Covered by NRC Generic Letter 89-13 (Constellation Proprietary)
Rev. 8a 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 Open Cycle Cooling Water AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.13, Closed Treated Water Systems Summary of Information in the Application The LRA states that AMP B.2.1.13, Closed Treated Water Systems, is an existing program with an enhancement and exceptions that will be consistent with the program elements in GALL-LR Report AMP XI.M21A, Closed Treated Water Systems, as modified by LR-ISG-2012-02 and LR-ISG-2013-01.
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 CL-PBD-AMP-XI.M21A Closed Treated Water Systems Program Basis Document Rev. 04 CY-AA-120-4000 Closed Cooling Water Chemistry Strategic Plan (Constellation Proprietary)
Rev. 011 CY-AA-120-400 Closed Cooling Water Chemistry (Constellation Proprietary)
Rev. 021 CY-AA-120-4200 Corrosion Monitoring Guidelines (Constellation Proprietary)
Rev. 006 MA-AA-716-010 Maintenance Planning (Constellation Proprietary)
Rev. 33 PM Modification Request PMMR PMRQ CTW AMP N/A PM Modification Request PMMR PMRQ CTW AMP - Erosion N/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 will
21 be consistent with the corresponding elements of the GALL-LR Report AMP after implementation of the identified enhancements.
The staff also verified the applicants claim that aspects of the scope of program, parameters monitored or inspected, and detection of aging effects program elements not associated with the exceptions identified in the LRA during the audit are consistent with the corresponding program elements inthe GALL-LR Report AMP.
The staff also audited the description of the Closed Treated Water Systems AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.14 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application The LRA states that AMP B.2.1.14, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing program with an enhancement 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 enhancement 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 and provided by the applicant via the ePortal.
For the operating experience (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 CL-PBD-AMP-XI.M23 AMP Basis Document: CPS, Unit 1, License Renewal Project - Inspection of Overhead Heavy Load and Light Load (related to Refueling) Handling Systems Program Rev. 2 FSAR CPS Final Safety Analysis Report Rev. 23 MA-AA-716-021 Rigging and Lifting Program (Constellation Proprietary)
Rev. 36 MA-AA-716-022 Control of Heavy Loads Program (Constellation Proprietary)
Rev. 15 AR 02436853 1HC02G: 1 loose bolt found during crane inspection 01/13/2015
22 Document Title Revision / Date AR 04282958 Minor discrepancies during refuel bridge (F15) walkdown 09/27/2019 ECR 417375 WO 1710259-01 inspection 1 loose bolt was found 01/14/2015 AR 03987841 Crane outage of MLC leaking oil 03/21/2017 AR 04209989 N and S TB overhead cranes safety mitigation 01/11/2019 AR 02436853 1HC02G: 1 loose bold found during crane inspection -
bolt is located on the west site. G-104 on the crane rail upper 01/13/2015 WO 04762983 Pre-outage auxiliary platform - 1F15E005 08/23/2019 WO 04776177 Perform Fuel handling platform test 03/06/2019 WO 04996023 1HC65G CRD CART jib crane periodic inspection 09/30/2021 WO 04978705 Transfer of irradiated component 10/10/2021 WO 05233950 1HC01G annual crane/rail inspection 03/02/2023 WO 05245155 1HCO&G crane mechanical annual inspection 04/20/2023 WO 01710259 1HC02G crane mechanical inspection 11/14/2014 WO 04805147 1F15E003 outage repair fuel platform 02/27/2020
- CMAA, Specification, No.70 Specification for Electric Overhead Traveling Cranes 1975 NUREG-0554 Single-Failure Proof Cranes for Nuclear Power Plants 05/1979 NUREG-0612 Control of Heavy Loads at Nuclear Power Plants 07/1980 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.
During the audit the staff made the following observation:
In LRA, AMP XI.M23 program was considered for the Table 1 Item: 3.3.1-25 (GALL #s:
VII.E4.AP-110 and -130) with Note E,1 from XI.M2, Water Chemistry, program.
The staff also audited the description of the LRA AMP provided in the FSAR supplement in Section A.2.1.14, 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.
23 LRA AMP B.2.1.15, Compressed Air Monitoring Summary of Information in the Application The LRA states that AMP B.2.1.15, Compressed Air Monitoring, is an existing program with enhancement and exception that will be consistent with the program elements in GALL-LR Report AMP XI.M15, Compressed Air Monitoring, as modified by LR-ISG-2013-01. 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 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 experience (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 program. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-PBD-AMP-XI.M24 Program XI.M24 Compressed Air Monitoring Rev. 2 ER-AA-700-405 Compressed Air Monitoring Aging Management Program (Constellation Proprietary)
Rev. 2 WO 01702778 Change Oil Replace Disc Filter, Clean Inspect 03/02/2015 WO 05076637-01 Inspect Dryer Desiccant/ Replace As Necessary 02/22/2022 CPS-1820 Periodic Blowdown of the IS/SA System (Constellation Proprietary) 04/22/1996 ER-AA-2030 Conduct of Equipment Reliability Manual (Constellation Proprietary)
Rev. 29 During the audit, the staff verified the applicants claim that the scope of the program, preventive actions, 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 after implementation of the identified enhancements.
The staff also verified the applicants claim that aspects of the monitoring and trending, 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 inthe GALL-LR Report AMP.
The staff also audited the description of the LRA AMP Compressed Air Monitoring program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
24 LRA AMP B.2.1.16, Fire Protection Program Summary of Information in the Application. The LRA) states that AMP B.2.1.16, 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 SLR-ISG-2021-02, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance, Interim Staff Guidance (ML20181A434), as part of operating experience. To verify this claim of consistency, the staff audited the LRA AMP. The staffs audit addressed the description of the enhancements in the LRA and the applicants basis document, and markups of program implementation documents.
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/Description Revision /
Date CL-PBD-AMP-XI.M26 Program Basis Document Revision 1 CPS 3822.05 Annual Halon System Functional Test (Constellation Proprietary)
Revision 8a CPS 3822.05C004 Aux Electrical Equipment Room Computer Panel Halon System (Constellation Proprietary)
Revision 1 CPS 9071.09 Fire Protection Diesel Generator Bay 1A CO2 System Auto Actuation Test (Constellation Proprietary)
Revision 37a CPS 9071.09P001 Fire Protection Diesel Generator Bay 1A CO2 System Puff Test (Constellation Proprietary)
Revision 0 CPS 9071.25 Fire Protection CO2 Weekly Operability Check (Constellation Proprietary)
Revision 026 CPS 9476.03 MCR Halon System Operability Test and Tank Weight/Pressure Verification (Constellation Proprietary)
Revision 39a CPS 9601.01 Fire Rated Assemblies and Penetration Sealing Devices (Constellation Proprietary)
Revision 29a CPS 9601.01C001 Fire Rated Assembly/Penetration Seal Inspections Checklist (Constellation Proprietary)
Revision 26c CPS 9601.01C002 Fire Damper Inspections Checklist (Constellation Proprietary)
Revision 28g CPS 9601.01C003 10% Per 18 Month Accessible Seal Inspections Checklist (Constellation Proprietary)
Revision 27b CPS 9601.01C005 Thermolag Cable Tray Wrap Inspections Checklist (Constellation Proprietary)
Revision 26 CPS 9601.01C006 Interam (3M) Cable Tray Wrap Inspections Checklist (Constellation Proprietary)
Revision 22a CPS 9601.01C009 12.5% Per 24 Month Inaccessible Seal Inspections Checklist (Constellation Proprietary)
Revision 0c CPS 9601.01C010 Fire Rated Barrier Intersections Inspection Checklist (Constellation Proprietary)
Revision 0a
25 Document Title/Description Revision /
Date CPS 9601.01C011 Structural Fireproofing Inspections Checklist (Constellation Proprietary)
Revision 0 CPS 9601.05 Visual Inspection of Closed Fire Doors (Constellation Proprietary)
Revision 25d CPS 9601.05C001 Closed Fire Door Inspection Checklist (Constellation Proprietary)
Revision 32d CPS 9601.06 Fire Door and Secondary Containment Doors Inspections (Constellation Proprietary)
Revision 29g CPS 9601.06C001 Semi-Annual Fire Door Operability Checklist (Constellation Proprietary)
Revision 31b CPS 9601.13C001 Fire damper drop test checklist (Constellation Proprietary)
Revision 20 AR02450515 Fire proofing determined degraded February 10, 2015 AR02729945 Fire door inspection failures October 19, 2016 AR04551278 Fire protection health red cornerstones / red overall January 30, 2023 WO01804340 Structural fireproofing degraded May 26, 2015 WO01930611 Fire door hardware inspections October 17, 2016 AR02443725 Structural fireproofing degraded January 28, 2015 AR01593901 Structural fireproofing concerns December 6, 2013 AR02489917 Degraded Fire Barrier Walls April 23, 2015 AR02595268 Turning vanes prevent complete inspection of fire damper December 3, 2015 AR02658452 Deficient fire/flood seal April 20, 2016 AR04288768 Fire seal not full depth in penetration October 17, 2019 AR04290966 Void in fire rated concrete block wall October 24, 2019 IR04301533 Fire Protection System and Program Health January 17, 2020 AR04475263 Grout degraded February 1, 2022 During the audit, the staff verified that for the program elements that the applicant declared were consistent, 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 the program and detection of aging effects program elements, sufficient information was not available to determine whether they are
26 consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order 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 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 the identified plant-specific operating experience in the SE.
The staff also audited the description of the LRA Fire Protection program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-LR Report.
LRA AMP B.2.1.17, Fire Water System Program Summary of Information in the Application The license renewal application (LRA) states that Aging Management Program (AMP) B.2.1.17, Fire Water System Program, is an existing program with exceptions and enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.M27, Fire Water System, modified by LR-ISG-2012-02 and LR-ISG-2013-01. To verify this claim of consistency, the staff audited the LRA AMP. The staffs audit addressed the description of the enhancements in the LRA and the applicants basis document, and markups of program implementation documents.
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 CL-PD-AMP-XI.M27 Program Basis Document - Fire Water System Rev. 1 1893.01 CPS Administrative Requirements for Fire Protection (Constellation Proprietary)
Rev. 23 2400.01 Circulating Water Screenhouse (CWSH) Intake Structure Inspection (Constellation Proprietary)
Rev. 9 3830.01 Traveling Screen Agitation and Differential Pressure Test (Constellation Proprietary)
Rev. 6c 9071.02 Diesel Fire Pump Capacity Checks (Constellation Proprietary)
Rev. 45c 9071.04 Fire Protection Water System Flow Test (Constellation Proprietary)
Rev. 35 9071.12 Deluge Spray Nozzle Flow Test (Constellation Proprietary)
Rev. 27d 9071.15 Fire Protection Hose Station Valve Operability Test (Constellation Proprietary)
Rev. 23f 9071.22 Fire Protection Flow Check and Visual Inspection of Fire Hydrants (Constellation Proprietary)
Rev. 27e
27 Document Title Revision / Date 9071.22C001 Fire Protection Flow Check and Visual Inspection of Fire Hydrants for the Protected Area (Constellation Proprietary)
Rev. 26a 9071.28 Fire Protection Hose Station Low Point Flow/Flush (Constellation Proprietary)
Rev. 0c 9601.10 Visual Inspection of Spray and Sprinkler System Piping and Heads (Constellation Proprietary)
Rev. 22f NA New Procedure Internal Inspections - Wet Pipe Pre-action Sprinklers System Rev. 0 9071.22 PMID 00158954 PM Modification Request - One Minute Flow Duration Specification 3213.01P002 Fire Protection Valves/Deluge/WPS/APS/MPS/Sprinkler Systems (Constellation Proprietary)
Rev. 1e NA New Procedure 50 year Sample Testing of Fire Water System Sprinkler Heads Rev. 0 CC-AA-211 Fire Protection Program (Constellation Proprietary)
Rev. 9 AR 01588993 Fire Protection Piping Not Draining as Designed 11/22/2013 AR 02388125 Deluge Nozzles Clogged 09/30/2014 AR 02501642 Fire Protection Piping Degraded 05/16/2015 AR 04113292 Level 3 Operating Experience Review - Pre-Action Sprinkler System Rupture 03/09/2018 AR 04204764 Valve Internals Eroded Away 12/20/2018 AR 04480847 Fire Pump A Room Floor Covered in Water 02/26/2022 OPXR 04086744 Operating Experience Evaluation - Pre-Action Sprinkler Rupture 03/25/2019 AR 01682644 Fire Pump A Discharge Low Point Drain Clogged 07/16/2014 AR 01690868 Fire Protection Valve Could Not Be Cycled 08/09/2014 AR 02557198 Extent of Condition Walkdown of FP Piping and Hose Houses 09/18/2015 AR 02700365 Sprinkler Nozzle Obstruction 08/03/2016 AR 02720861 Hydrant Not Draining 09/27/2016 AR 03972582 Minor Damage on Traveling Screen E 02/10/2017 AR 04065373 Hydrant Valve Would Not Drain 10/21/2017 AR 04089595 Hydrant Broken Below Flange 01/03/2018
28 Document Title Revision / Date AR 04106736 Standing Water in Fire Pump B Room 02/21/2018 AR 04209479 Excessive Buildup Inside Pipe 01/09/2019 AR 04296850 Ice Formed Inside Exterior Hose Rack at Screen House 11/13/2019 AR 04297592 Clogged Traveling Screen Trough 11/15/2019 AR 04435752 Debris at Bar Racks Caused Autostart of Traveling Screens 07/19/2021 AR 04529881 Fire Pump A Coolant System Heating Up Faster than Expected 10/17/2022 AR 04675662 Fire Pump A cooling water strainer clogged 05/04/2023 AR 04684743 Ultrasonic Testing (UT) Reading Found Below Minimum Required Thickness 06/14/2023 AR 04686005 Low UT Readings 06/21/2023 AR 01613849 Fire Suppression System Leak 01/28/2014 AR 01625219 Assessment of Leaks Associated with Fire Pump A Room 02/24/2014 AR 01649150 As Left Inspection of Failed Fire Protection Piping 04/18/2014 AR 01680386 Engine Coolant Leak on Fire Pump A Water Manifold 07/10/2014 AR 2387881 Stem Leakage on Hydrant 26 09/29/2014 AR 02556073 Walk Down of Potential Fire Protection Piping Leak South of Fuel Building 09/16/2015 AR 04686005 Low UT Readings Obtained on 12 Fire Protection Piping 06/21/2023 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 exception and 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 in order to obtain the information necessary to verify whether the program elements are consistent with the corresponding program elements of the GALL-LR Report AMP.
29 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 the identified plant-specific OE in the SE.
The staff also audited the description of the LRA Fire Water System Program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the GALL-LR Report.
LRA AMP B.2.1.18, Aboveground Metallic Tanks Summary of Information in the Application The LRA states that AMP B.2.1.18, Aboveground Metallic Tanks, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M29, Aboveground Metallic Tanks, as modified by LR-ISG-2012-02 and LR-ISG-2013-01. 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 For the operating experience (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 Aboveground Metallic Tanks program. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-PBD-AMP-XI.29 Aboveground Metallics Tanks Rev. 1 ER-AA-5400-1002 Underground Piping and Tank Examination Guide (Constellation Proprietary)
Rev. 10 JN-D51749 29-11(1/4) Diameter 29-6 Hight Aluminum RCIC Storage Tank 12/17/1976 A28-1406 RCIC Storage Tank Valve Room Sections and Elevations Clinton Power Station Unit 1 Illinois Power Company Clinton, Illinois 10/04/1977 WO:01766587-01 UT Bottom of RCIC Storage Tank 1RI01T 11/27/2017 AR-04038740 Pre-Determine Next Schedule RCIC Tank Inspection Based on Wall Loss 09/29/2017 AR-01131148 Nuclear Event Report (NER) NC-10-056 01/31/2010 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.
30 The staff also audited the description of the LRA Aboveground Metallic Tanks program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR Report.
LRA AMP B.2.1.19, Fuel Oil Chemistry Summary of Information in the Application The LRA states that AMP B.2.1.19, 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, as modified by LR-ISG-2013-01. 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 During its audit, the staff reviewed documentation contained in the LRA and provided by the applicant via the ePortal.
For the operating experience (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. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-PBD-AMP-XI.M30 GALL Program XI.M30 Fuel Oil Chemistry Rev. 2 CL-PBD-AMP-XI.M32 Program Basis Document One Time Inspection Rev. 4 CY-AA-120-5000 Diesel Fuel Oil Program Guide (Constellation Proprietary)
Rev. 1 CY-CL-1937-01 Diesel Fuel Oil Testing Program (Constellation Proprietary)
Rev. 1 Clinton Power Station CR AR-01478359 CDBI FASA: EDG Fuel Oil Practices Procedures 07/18/2013 CY-CL-6423-02 Diesel Fuel Oil Water and Sediment Content (Constellation Proprietary)
Rev. 2 CY-CL-6423-04 Determination of Diesel Fuel Particulate Contamination by Laboratory Filtration (Constellation Proprietary)
Rev. 2 Drawing K-2842 Diesel Generator Oil Stg Tank 02/09/1982 Drawing DT-77-267 Diesel Generator Fuel Oil Day Tank Rev. 5 During the audit, the staff verified the applicants claim that the scope of program, acceptance criteria and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LRReport AMP.
31 During the audit, the staff verified applicants claim that the preventive actions, parameters monitored or inspected detection of aging effects and monitoring and trending program elements of the LRA AMP will be consistent after implementation of the 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 FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.20, Reactor Vessel Surveillance Summary of Information in the Application The LRA states that AMP B.2.1.20, Reactor Vessel Surveillance, is an existing program with an exception that is consistent with the program elements in GALL--LR Report AMP XI.M31, Reactor Vessel Surveillance.
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: embrittlement, fluence.
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 CPS-PBD-AMP-XI.M31 Program Basis Document - Reactor Vessel Surveillance Rev. 1 Final Safety Analysis Report - Section 5 Rev. 21 ER-AB-331-103 BWR VESSEL INTEGRATED SURVEILLANCE PROGRAM IMPLEMENTATION (Constellation Proprietary)
Markup of Rev 006 BWRVIP-86 UPDATED BWR INTEGRATED SURVEILLANCE PROGRAM (ISP) IMPLEMENTATION PLAN Rev. 1-A During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program element(s) of the LRA AMP is 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, 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 inthe GALL-LR Report AMP. The staffs review of the exception to the detection of aging effects, program element will be documented in the SE.
During the audit, the staff made the following observation:
FSAR Section 5.3.1.6.1, Compliance with "Reactor Vessel Material Surveillance Program Requirements" indicates in 2003, the NRC approved Clinton Power Stations
32 participation in the BWR Vessel and lnternals Project (BWRVIP) Integrated Surveillance Program (ISP) as described in BWRVIP-78 and BWRVIP-86. Additionally, the current withdrawal schedule is based on the latest NRC approved revision of BWRVIP-86, which is Revision 1-A.
The staff also audited the description of the LRA AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.21, One-Time Inspection Summary of Information in the Application The LRA states that AMP B.2.1.21, 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 Program. 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 CL-PBD-AMP-XI.M32 One-Time Inspection Rev 1 IR 04509371 Chemistry Off-Normal entered (Sulfates > AL1),
Condensate Polishing 07/05/2022 IR-04509371-07 (PI-AA-125-1001)
Root Cause Report Rev 6 IR- 04517759 (PI-AA-126-1001-F-01)
Self-Assessment-Aboveground and Underground Storage Tanks Rev 5 IR- 04552063 Clinton Tank Self-Assessment QTR 4 2022 02/02/2023 IR- 03971733 Need Oil Changed Based on Oil Condition of The Last Sample 02/08/2017 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 provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
33 LRA AMP B.2.1.22, Selective Leaching Summary of Information in the Application The LRA states that AMP B.2.1.22, Selective Leaching, 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 modified by LR-ISG-2011-03, LR-ISG-2015-01, and LR-ISG-2012-02. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
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 CL-PBD-AMP-XI.M33 Program Basis Document Selective Leaching, GALL Program XI.M33 - Selective Leaching Rev. 1 ER-AA-700-401 Selective Leaching Aging Management (Constellation Proprietary)
Rev. 3 LR-AA-1609 Aging Management Reviews (AMR) (Constellation Proprietary)
Rev.1 CL-AMPBD-SLI Selective Leaching Inspection Sample Basis Document Rev. 0 and 1 During the audit, the staff verified the applicants claim that the preventive actions, acceptance criteria, and corrective actions program elements of the LRA AMP will be 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, detection of aging effects, and monitoring and trending program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs in order 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:
The staff reviewed CL-AMPBD-SLI (Revision 0) and noted that it discusses performing metallurgical analysis of components in place of visual examinations and that the sample size can be reduced by a factor of three (i.e., 6.7 percent or a maximum of nine components) if the entire material and environment population is evaluated using metallurgical analysis in lieu of visual examinations.
The staff reviewed CL-AMPBD-SLI (Revision 1) and noted that the above discussion related to reducing sample size if metallurgical analyses are performed was removed.
The staff also audited the description of the LRA Selective Leaching program provided in the FSAR supplement. The staff found that sufficient information was not available to determine
34 whether the description provided in the FSAR supplement was an adequate description of the LRA Selective Leaching program. The staff will consider issuing RAIs in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.
LRA AMP B.2.1.23, One-time Inspection of ASME Code Class 1 Small-Bore Piping Summary of Information in the Application The LRA states that AMP B.2.1.23, One-time Inspection of ASME Code Class 1 Small-Bore Piping is a new condition monitoring 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 operating experience (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 evaluated 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 CL-PBD-AMP-XI.M35 Clinton Power Station Unit 1, License Renewal Project: One-time Inspection of ASME Code Class 1 Small-Bore Piping Rev. 1 02/29/2024 CL-C1R17-ISI Summary Report Clinton Power Station Unit 1, Post Outage 90-Day lnservice Inspection (ISI) Summary Report-Aug 2017 Inspection Results Rev. 0 08/2017 CL-C1R20-ISI Summary Report Clinton Power Station Unit 1, Post Outage 90-Day lnservice Inspection (ISI) Summary Report - Jan 2022 Inspection Results Rev. 0 01/2022 CL-C1R17-APR-02 GE Hitachi UT Examination Summary Sheet, Nozzle-to-Safe End N1B-W-1 05/23/2017 ER-AA-300 Conduct of lnservice Inspection Activities (Constellation Proprietary)
Rev. 19 AR 04012873 UT Indication in N1B-W1 05/19/2017 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 elements of the GALL-LR Report AMP.
35 The staff also audited the description of the LRA AMP One-time Inspection of ASME Code Class 1 Small-Bore Piping provided in the FSAR Supplement. The staff verified that this description is consistent with the description provided in the SRP-LR Report.
LRA AMP B.2.1.24, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application The LRA states that AMP B.2.1.24, External Surfaces Monitoring of Mechanical Components, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components, as modified by LR-ISG-2011-03 and LR-ISG-2012-02. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only 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 CL-PBD-AMP-XI.M36 External surfaces Monitoring of Mechanical Components Rev 1 AR-04281042 VP Insulation Walk Down Results 09/21/2019 AR 04352219 1VY03S RHR 1A Roomer Cooler thru leak 06/24/2020 AR 04408095 0WM118B through wall leak 03/11/2021 ER-AA-700-402 External Surfaces Monitoring of Mechanical Components Aging Management Program (Constellation Proprietary)
Rev 1 ER-CL-700-402 External Surfaces Monitoring of Mechanical Components Aging Management Program (Constellation Proprietary)
Rev 0 ER-AA-2030 Conduct of Equipment Reliability Manual (Constellation Proprietary)
Rev 27 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 Section A.2.1.24, External Surfaces Monitoring of Mechanical Components, provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
36 LRA AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application The LRA states that AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is a new program that will be consistent with the program elements in GALL-LR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, as modified by LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation, and 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 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 CL-PBD-AMP-XI.M38 Program Basis Document - Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Rev. 1 ER-AA-700-403 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Aging Management Program (Constellation Proprietary)
Rev. 3 ER-AA-2030 Conduct of Equipment Reliability Manual (Constellation Proprietary)
Rev. 29 MA-AA-716-010 Maintenance Planning (Constellation Proprietary)
Rev. 34 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 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.26, Lubricating Oil Analysis Summary of Information in the Application The LRA states that AMP B.2.1.26, Lubricating Oil Analysis, is an existing program with an enhancement that will be consistent with the program elements in GALL-LR Report AMP XI.M39, Lubricating Oil Analysis. 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.
37 Activities During its audit, the staff reviewed documentation contained in the LRA and provided by the applicant via the ePortal. For the operating experience (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 the documents that were reviewed by the staff and were found relevant to the Lubricating Oil Analysis Program. The staff will document its review of relevant operating experience in the SE.
Document Title Revision / Date CL-PBD-AMP.XI.M39 Lubricating Oil Analysis Program Basis Document Rev. 1 Procedure CPS-8902.01 Oil Sampling 06/20/2012 Procedure MA-AA-716-230 Predictive Maintenance (Constellation Proprietary)Rev. 12 Procedure MA-AA-716-230-1001 Oil Analysis Interpretation Guidelines (Constellation Proprietary)
Rev. 22 Procedure MA-AA-716-230-1004 Lubricating Sampling Guideline (Constellation Proprietary)
Rev. 5 NESD-S-MS-03.00 Oil Sampling and Analysis (Constellation Proprietary)
Rev. 33 WO 00157029 PMSR, Sample and Change Pump Bearing Oil 1E22C003, E:1E22C003, PMPA, P30 10/20/2020 IR-04284958 Elevated Cooper in 1B33C001B Motor Level Bearing Oil 11/03/2019 AR-0397133 Report Need Oil Changed Based on Oil Condition of the Last Sample 03/10/2017 During the audit, the staff verified the applicants claim that the scope of program, 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 applicants claim that the preventive actions, parameters monitored or inspected and detection of aging effects 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 AMP Lubricating Oil Analysis Program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR Report.
LRA AMP B.2.1.27, Monitoring of Neutron-Absorbing Materials Other than Boraflex Summary of Information in the Application The LRA states that AMP B.2.1.27, Monitoring of Neutron-Absorbing Materials Other than Boraflex, is an existing program with one enhancement that will be consistent with the program
38 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 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 CL-PBD-AMP-XI.M40 Clinton Power Station Unit 1 License Renewal Project Monitoring of Neutron-Absorbing Materials Other Than Boraflex Rev.1 AR 00866262 Fuel Rack Coupon Tree Lessons Learned 01/13/2009 CPS 8118.01 Metamic Coupon Sampling and Testing Program(Constellation Proprietary)
Rev. 0c NF-AA-600 Spent Fuel Management (Constellation Proprietary)
Rev. 9 NF-AA-610 On-Site Wet Storage of Spent Nuclear Fuel (Constellation Proprietary)
Rev. 16 WO 01046694 00179843-01, TSPR, Spent Fuel Metamic Coupon Sampling Program, W: Spent Fuel Coupons 01/30/2009 WO 01306257 00182114-02, TS, Perform Fuel Rack Coupon Sampling & Testing (2011, 1FH09J-03, E: 1FH09J, N/
A,)
11/8/2011 WO 01708913 00182114-03, TS, Perform Fuel Rack Coupon Sampling & Testing (2015, 1FH09J-05, E: 1FH09J, N/
A,)
10/20/2015 NET-28064-020-01 Inspection and Testing of Metamic Surveillance Coupons from Clinton Nuclear Power (Constellation Proprietary) 10/16/2019 N/A Item #8 (TRP-15) Enhancement #1 Additional Information 10/17/2024 EPRI 1021052 Overview of BORAL Performance Based Upon Surveillance Coupon Measurements 12/2010 EPRI 1025204 Strategy for Managing the Long-Term Use of BORAL in Spent Fuel Storage Pools 07/2012 EPRI 3002018496 Handbook of Neutron Absorber Materials for Spent Nuclear Fuel Storage and Transportation Applications, Revision 1 03/2022 HI-2033135 Criticality Safety Analysis for Clinton (Holtec Proprietary)
Rev. 5 During the audit, the staff verified the applicants claim that the preventive actions, and corrective actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL-LR Report AMP.
39 In addition, the staff found that for the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria, program elements, sufficient information was not available to determine whether they will be consistent with the corresponding program elements of the GALL-LR Report AMP after implementation of the identified enhancements. The staff will consider issuing RAIs in order to obtain the information necessary to verify whether these program elements will be consistent with the corresponding program elements of the GALL-LR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the Monitoring of Neutron-Absorbing Materials Other than Boraflex program provided in the FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the Monitoring of Neutron-Absorbing Materials Other than Boraflex program. The staff will consider issuing RAIs in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.
LRA AMP B.2.1.28, Buried and Underground Piping and Tanks Summary of Information in the Application The LRA states that AMP B.2.1.28, Buried and Underground Piping and Tanks, is an existing program with enhancements and an exception that will be consistent with the program elements in GALL-LR Report AMP XI.M41, Buried and Underground Piping and Tanks, as modified by LR-ISG-2015-01, Changes in 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 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 CL-PBD-AMP-XI.M41 Program Basis Document, Buried and Underground Piping and Tanks, GALL Program XI.M41 - Buried and Underground Piping and Tanks Rev. 3 ER-AA-5400-1004 Cathodic Protection System Management Guide (Constellation Proprietary)
Rev. 2 ER-AA-5400-1002 Underground Piping and Tank Examination Guide (Constellation Proprietary)
Rev. 10 SA-AA-117 Excavation, Trenching, and Shoring (Constellation Proprietary)
Rev. 25 AR 04470591 Guided Wave Work not performed in Work Week 2201 01/04/2022 AR 01659501 UT Identifies Moderate Localized Corrosion on 1SX02AA-30 05/01/2014
40 Document Title Revision / Date AR 04245827 1SX02AA: 100% UT Scan Needed Per BPRWCP 05/02/2019 WO 04978534 1SX02AA: 100% UT Scan Needed per BPRWCP 05/21/2020 AR 04554484 Annual Survey Report (2022) Recommendations 02/14/2023 2000604.401 CPS InTellusASTM 2021 Annual Survey Report 03/02/2022 2200490.401 CPS InTellusASTM 2022 Annual Survey Report 02/10/2023 ER-AA-5400 Buried Piping and Raw Water Integrity Management Programs (Constellation Proprietary)
Rev. 13 Form 276-C Standard Specification for Protective Coatings for Buried Piping 01/20/1994 K-2942 Earthwork Clinton Power Station - Units 1 and 2 -
Illinois Power Company Amendment 10 S03-1140 Safety Related Backfill Clinton Power Station Illinois Power Company Rev. P CPS 3213.01 Fire Detection and Protection (Constellation Proprietary)
Rev. 33 CPS 9071.04 Fire Protection Water System Flow Test (Constellation Proprietary)
Rev. 35a 1893.01 CPS Administrative Requirements for Fire Protection (Constellation Proprietary)
Rev. 24 During the audit, the staff verified the applicants claim that the scope of program and monitoring and trending 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. In addition, the staff found that for the preventive actions, parameters monitored or inspected, detection of aging effects, 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 in order 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 FSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA Buried and Underground Piping and Tanks program. The staff will consider issuing RAIs in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.
41 LRA AMP B.2.1.29, ASME Section XI, Subsection IWE Summary of Information in the Application The LRA states that AMP B.2.1.29, ASME Section XI, Subsection IWE, is an existing program which, with one enhancement, will be consistent with the program elements in GALL Report AMP XI.S1, ASME Section XI, Subsection IWE.
Audit Activities During its audit, the staff reviewed documentation contained in the LRA and provided by the applicant via the ePortal.
For the operating experience (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 CL-PBD-AMP-XI.S1 CPS Unit 1 License Renewal Project, Program Basis Document, ASME Section XI, Subsection IWE (GALL Program XI.S1)
Rev. 1 CL-AMRBD-MEAE License Renewal Project - Materials, Environments, and Aging Effects - Aging Management Review Basis Document Rev. 2 N/A CPS License Renewal Application - Operating Experience Review Process Presentation 08/12/2024 N/A Keyword Searches 04/4/2024 LR-AA-1609 Instruction - Aging Management Reviews (AMR),
CPS License Renewal Project (Constellation Proprietary)
Rev. 1 LR-AA-1611 T&RM - Aging Management Program Basis Documents, CPS License Renewal Project (Constellation Proprietary)
Rev. 1 ER-AA-335-018 Procedure - Visual Examination of ASME IWE Class MC and Metallic Liners of Class CC Components (Constellation Proprietary)
Rev. 17 ER-AA-335-004 Procedure - Ultrasonic (UT) Measurement of Material Thickness and Interfering Conditions (Constellation Proprietary)
Rev. 10 ER-AA-380 Procedure - Primary Containment Leakrate Testing Program (Constellation Proprietary)
Rev. 18
42 Document Title Revision / Date PI-AA-125 Corrective Action Program Procedure (Constellation Proprietary)
Rev. 9 PI-AA-120 Issue Identification and Screening Process (Constellation Proprietary)
Rev. 13 ER-AA-330 Procedure - Conduct of Inservice Inspection Activities (Constellation Proprietary)
Rev. 19 ER-AA-330-007 Procedure - Visual Examination of Section XI Class MC and Metallic Liners of Class CC Components (Constellation Proprietary)
Rev. 15 ER-AA-330-009 Procedure - ASME Section XI Repair/Replacement Program (Constellation Proprietary)
Rev. 18 ER-CL-330-001 Procedure - Containment IWE and IWL Inspection Acceptance Criteria (Constellation Proprietary)
Rev. 1 ISI-IWE/IWL CNTMNT INSP PROGRM Containment Inservice Inspection (CISI) Program Plan - Third Ten-year Containment Inspection Interval, Clinton Power Station Unit 1 (09/10/18 to 09/09/28)
Rev. 8 (11/20/2018)
MA-AA-736-600 Procedure - Torquing and Tightening of Bolted Connections(Constellation Proprietary)
Rev. 14 MA-CL-736-6001 T&RM - Tightening of Flanged Connections (Constellation Proprietary)
Rev. 1 PES-S-003 Standard - In-Storage Maintenance of Nuclear Material (Constellation Proprietary)
Rev. 15 PES-S-010 Standard - Fasteners (Constellation Proprietary)
Rev. 5 AR02502259 Containment Wall Penetration Inspection Results 05/18/2015 AR02671728 NRC ISI: C1R15 Primary Containment Liner Corrosion 05/19/2016 AR 01040325 Containment Penetrations - Liner / Wall Degradation 03/09/2010 AR 02706215 NRC NCV 2016002-05 Lack of Acceptance Criteria for Containment Visual Examination 08/19/2016 AR 04077439 Evaluation of Containment Visual Inspection Indications Identified in C1R17 11/22/2017 C1R21-IWE-500A, -
500B ASME IWE (Class MC) Containment and IWL (Class CC) Metallic Liners Visual Examination NDE Report 09/21/2023 C1R21-IWE-501B, -
502A, -503A, -510A,
-520B, -527 ASME IWE (Class MC) Containment and IWL (Class CC) Metallic Liners Visual Examination NDE Report 09/24/2023 C1R21-IWE-502A, -
503A, -508A, -509B,
-512A, -513B, -
ASME IWE (Class MC) Containment and IWL (Class CC) Metallic Liners Visual Examination NDE Report 09/23/2023
43 Document Title Revision / Date 523A, -523B, -524B,
-528 C1R21-IWE-504, -
505, -506, -507A, -
509A,-514B, -516, -
517A, -518, 519A, -
520, -521, -522, -525 ASME IWE (Class MC) Containment and IWL (Class CC) Metallic Liners Visual Examination NDE Report 09/22/2023 C1R21-IWE-514B ASME IWE (Class MC) Containment and IWL (Class CC) Metallic Liners Visual Examination NDE Report 09/27/2023 C1R21-IWE-530 ASME IWE (Class MC) Containment and IWL (Class CC) Metallic Liners Visual Examination NDE Report 10/03/2023 C1R21-IWE-531 ASME IWE (Class MC) Containment and IWL (Class CC) Metallic Liners Visual Examination NDE Report 10/04/2023 C1R19 ISI DOCS BOOK 3 Part 1, Part 2 & Part 3 ASME IWE (Class MC) Containment and IWL (Class CC) Metallic Liners Visual Examination NDE Reports for Outage C1R19 09/25/2019 -
10/14/2019 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, and acceptance criteria and corrective actions program elements of the LRA AMP are consistent, or with enhancement will be consistent, with the corresponding elements of the GALL Report AMP.
During the audit, the staff made the following observation:
The staff reviewed Procedure ER-AA-335-018, Revision 17, Attachment 3 ASME IWE Class MC Containment and Metallic Liners of Class CC Components Visual Examination NDE Report and noted that it included arc strikes as an attribute inspected for.
However, element 3 in the program basis document (PBD) CL-PBD-AMP-XI.S1, Revision 1, did not appear to include arc strikes as a parameter monitored.
The staff may consider issuing RAI(s) or use a voluntary update to the PBD offered by the applicant to address the above observation.
The staff also audited the description of the LRA AMP ASME Section XI, Subsection IWE provided in the FSAR supplement A.2.1.29. The staff verified this description is consistent with the description provided in the SRP-SLR.
LRA AMP B.2.1.30, ASME Section XI, Subsection IWL Summary of Information in the Application The LRA states that AMP B.2.1.30, ASME Section XI, Subsection IWL, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.S2, ASME Section XI, Subsection IWL.
44 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 keywords.
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 CL-PBD-AMP-XI.S2 Program Basis Document - ASME Section XI, Subsection IWL Rev. 1 ER-AA-330-001 Containment IWE and IWL Inspection Acceptance Criteria (Constellation Proprietary)
Rev. 1 ER-AA-330-005 Visual Examination of Section XI Class CC Concrete Containment Structures (Constellation Proprietary)
Rev. 16 ER-AA-335-019 Visual Examination of ASME IWL Class CC Containment Components (Constellation Proprietary)
Rev. 3 WO 01703749 Need WO for C1R15 CISI Inspections 10/26/2015 AR 02502259 Containment Wall Penetration Inspections Results 05/18/2015 WO 01588367 Complete CISI Inspection Documentation Reviews 03/27/2014 WO 04835791 Perform Containment dbr Inspections 05/29/2019 AR 04175323 Containment Walkdown Deficiencies Identified 09/20/2018 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 AMP ASME Section XI, Subsection IWL program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.31, ASME Section XI, Subsection IWF Summary of Information in the Application The LRA states that AMP B.2.1.31 ASME Section XI, Subsection IWF, is an existing program, with enhancements when implemented, will be consistent with the program elements in GALL-LR Report, Revision 2, AMP XI.S3, ASME Section XI, Subsection IWF.
Audit Activities During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the LRA and ePortal.
45 For the operating experience (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 program. The staff will document its review of this information in the SE.
Document Title Revision/Date CL-PBD-AMP-XI.S3 CPS Unit 1 License Renewal Project, Program Basis Document, ASME Section XI, Subsection IWF (GALL Program XI.S3)
Rev. 1 N/A CPS License Renewal Application - Operating Experience Review Process Presentation 08/12/2024 N/A Keyword Searches 04/04/2024 ER-AA-335-016 Procedure - VT-3 Visual Examination of Component Supports, Attachments and Interiors of Reactor Vessels (Constellation Proprietary)
Rev. 14 ER-AA-330 Procedure - Conduct of Inservice Inspection Activities (Constellation Proprietary)
Rev. 19_markup ER-AA-330-003 Procedure - Inservice Inspection of Section XI Component Supports (Constellation Proprietary)
Rev. 17_markup ER-CL-330-1001 ISI Program Plan - Fourth Ten-Year Inspection Interval (07/01/2020 to 06/30/2030), Clinton Power Station, Unit 1 (Constellation Proprietary)
Rev. 0_markup (06/01/2020)
ER-CL-330-1003 ISI Selection Document, Fourth Ten-Year Inspection Interval, Clinton Power Station, Unit 1 (Constellation Proprietary)
Rev. 1_markup (05/17/2023)
MA-AA-736-600 Procedure - Torquing and Tightening of Bolted Connections (Constellation Proprietary)
Rev. 14_markup MA-CL-736-6001 T&RM - Tightening of Flanged Connections (Constellation Proprietary)
Rev. 1_markup CC-AA-102 Design Input and Configuration Change Impact (Constellation Proprietary)
Rev. 34_markup PES-S-003 Standard - In-Storage Maintenance of Nuclear Material (Constellation Proprietary)
Rev. 15_markup PES-S-010 Standard - Fasteners (Constellation Proprietary)
Rev. 5_markup AR 2741864 CIA (EN) Pre-NRC ISIS IP 71111.08G Inspection 11/16/2016 AR 2741874 Self Assessment - ISI Program Preparedness to C1R18 NRC Inspection 03/20/2018 AR 04283253 VT-3 Identified a Loose Locknut/Jam Nut on 1SX09019R 09/29/2019 AR 044492263 VT-3 Identified a Loose Jam Nut on Variable Spring Support 1H101C(A) 09/29/2021 WO 01353486 C1R13 - Perform ISI Examinations 04/26/2011
46 Document Title Revision/Date WO 1353486-03 &
WO 1353486 Supplement RPV Support Skirt Support Components -
Examination Summary, C1R13 Outage 12/06/2011 WO 05103978 C1R20 ISI Contingency Repair/Replacement/Hanger Adjustments (Tighten Jam Nut) 10/26/2022 AR 04450991 C1R20 - Hangers Setting Not Meeting Acceptance Criteria (MS Variable Component Supports 1H101A(A), 1H101C(A), 1H01C(B), 1H02C 10/05/2021 EC 0000635266 C1R20 Evaluation of VT-3 As-Found Setting for Spring Hangers (MS System 1H101A(A),
1H101C(A), 1H01C(B), 1H02C and RR System 1H305A and 1H306A 10/28/2021 AR 04451767 C1R20 -Hanger, 1SX20001V Setting Not Meeting the Criteria (Shutdown Service Water System) 10/08/2021 AR 04451783 C1R20 Hanger, 1RH07084V Setting Not Meeting the Criteria 10/08/2021 EC 0000635274 C1R20 Evaluation of VT-3 As-Found Setting for Spring Hangers 1RH07084V and 1SX20001V 10/28/2021 EC 0000639807 C1R21 Evaluation of VT-3 As-Found Setting for Spring Hangers (MS system 1H101B(B); RR system:
1H305B and 1H306B) 10/23/2023 During the audit, the staff verified the applicants claim that the parameters monitored or inspected, detection of aging effects, acceptance criteria, and corrective actions program elements of the LRA AMP are or will be consistent with the corresponding elements of the GALL-LR Report AMP XI.S3 after implementation of the identified enhancements.
In addition, the staff found that for the scope of program (e.g., elastomeric vibration isolation elements), preventive actions, and monitoring and trending program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAIs or use a voluntary LRA supplement to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL-LR Report.
The staff also audited the AMR line items related to the ASME Section XI, Subsection IWF AMP.
During the audit, the staff made the following observations:
The staff reviewed Engineering Change (EC) 0000635266, EC 0000635274 and EC 0000639807, and noted these ECs evaluated as-found setting of variable support spring hangers not meeting the specified tolerance criteria (5%) and determined that the as-found settings were within the working range limits specified in the manufacturers catalog, and therefore the associated piping stress would remain within acceptable limits. The as-found setting was thus accepted without requiring corrective measures. Of the ARs reviewed, the staff did not find any instance where scope expansion was performed based on conditions found.
47 The staff reviewed the IWF AMP PBD CL-PBD-AMP-XI.S3, and implementing procedures CC-AA-102 and MA-AA-736-600 and noted that high-strength bolting (HSB) in sizes greater than 1-inch nominal diameter is not and will not be used in IWF supports in the future. The staff also noted from the PBD that plant-specific OE has not identified cracking due to SCC for HSB.
The staff reviewed implementing procedures CC-AA-102, MA-AA-736-600 and references therein and noted that the limit sulfur in chemicals such as lubricants in the plant, so that lubricants with sulfur as an ingredient are not used. However, a statement from the PBD may be needed in the LRA that structural bolting is procured with a light residual coating of oil and installed without lubricant, and that additional thread lubricant (including MoS2) is not used for IWF support structural bolting.
The staff reviewed LRA Table 3.5.1, AMR item 3.5.1-57 and corresponding Table 2 items, and noted a lack of clarity with regard to components for the item using note E.
The staff noted from review of the LRA that regarding Table 3.5.1 AMR line item 3.5.1-83 and corresponding Table 2 item for structural bolting of Class 2 and 3 component supports bolting in a water-flowing environment, sufficient information was not provided of whether the component and environment is included in the selected inspection sample of the IWFAMP.
The staff noted from review of the LRA that regarding Table 3.5.1 AMR line item 3.5.1-84 and corresponding Table 2 item for stainless steel drywell head closure bolting with generic note E, sufficient information was not provided to justify the adequacy of the alternate One-Time Inspection AMP being used in lieu of the GALL-LR recommended AMP.
The staff reviewed LRA Table 3.5.1, AMR item 3.5.1-94 and noted lack of clarity regarding consistency claim given that based on the PBD, there are no vibration isolation elements in CPS IWF supports.
The staff reviewed LRA Table 3.5.1, AMR item 3.5.1-74 (TRP 89) and noted the non-applicability claim for the item was not adequately justified or not appropriate.
The staff will consider issuing RAIs or use a voluntary LRA supplement to obtain the information necessary to make its finding regarding the issues in the latter three observations above.
The staff also audited the description of the LRA AMP ASME Section XI, Subsection IWF provided in the FSAR supplement Section A.2.1.31. The staff found that sufficient information was not available to determine whether the description provided in the FSAR supplement was an adequate description of the LRA AMP ASME Section XI, Subsection IWF. The staff will consider issuing an RAI or use a voluntary LRA supplement in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program description.
48 LRA AMP B.2.1.32, 10 CFR Part 50, Appendix J Summary of Information in the Application The LRA states that AMP B.2.1.32, 10 CFR Part 50, Appendix J, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.S4, 10 CFR Part 50, Appendix J.
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: (leak, equipment hatch, pressures boundary, and penetration.)
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 CL-PBD-AMP-XI.S4 Clinton Power Station, Unit 1 License Renewal Project 10 CFR Part 50, Appendix J Rev. 1 AR 04473677-07 Clinton Power Station Appendix J FASA Rev. 7 IR 2501534 (PSU) LLRT 1VQ006A-B AND 1VQ00A-B EXCESSIVE LEAKAGE MC102 05/12/2015 IR 4280979 C1R19 CP DELAY MSIV LEAKAGE HIGHER THAN EXPECTED 09/20/2019 ER-AA-380 Primary Containment Leakrate Testing Program (Constellation Proprietary)
Rev. 17 EC 402151 Evaluation of VQ LLRT Exceeds Evaluation Limit 05/20/2015 CPS 1305.01 Primary Containment Leak Rate Testing Program (Constellation Proprietary) 08/15/2019 CPS 9861.01 Integrated Leak Rate Test (Constellation Proprietary) 08/18/2023 CPS 9861.02 Local Leak Rate Testing Requirements and Type C(Air) Local Leak Rate Testing (Constellation Proprietary) 07/09/2012 CPS 9861.03 Type B Local Leak Rate Testing (Constellation Proprietary) 07/09/2012 CPS 9861.04 MSIV Local Leak Rate Testing (Constellation Proprietary) 07/09/2012 CPS 9861.05 Water Local Leak Rate Testing (Constellation Proprietary) 07/09/2012 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
49 trending, acceptance criteria, and corrective actions program elements of the LRA AMP are consistent with the corresponding element of the GALL-LR Report AMP.
The staff also audited the description of the LRA AMP A.2.1.32, 10 CFR Part 50, Appendix J provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.33 Masonry Walls Summary of Information in the Application The LRA states that AMP B.2.1.33, Masonry Walls, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.S5, Masonry Walls.
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 keywords: (gap, crack, grout, CMU, block, and mortar.)
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. An on-site audit was performed September 10, 2024 to September 12, 2024.
Document Title Revision / Date CL-PBD-AMP-XI.S5 PROGRAM BASIS DOCUMENT, CL-PBD-AMP-XI.S5 - Masonry Walls Rev. 2 ER-AA-450 STRUCTURES MONITORING (Constellation Proprietary)
Rev. 11 ER-CL-450-1006 CLINTON STRUCTURES MONTORING INSTRUCTIONS (Constellation Proprietary)
Rev. 2 AR 4162907 10 CFR 50.65 (a)(3) Periodic Assessment of Maintenance Rule Program 05/21/2018 AR 04287793 NOS ID GAP IDd in wall in the Aux Electrical Equipment Room 10/14/2019 AR 00764743 EARTHQUAKE OFF-NORMAL ENTRY 04/18/2008 WO 04974611 NOS ID GAP IDD IN WALL IN AUX ELECTRICAL EQUIPMENT ROOM 11/12/2019 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.
The staff also audited the description of the LRA A.2.1.33, Masonry Walls, in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
50 LRA AMP B.2.1.34, Structures Monitoring Summary of Information in the Application The LRA states that AMP B.2.1.34, Structures Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-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 the keywords. An on-site audit was performed from September 10, 2024 to September 12, 2024.
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 CL-PBD-AMP-XI.S6 Program Basis Document, GALL Program XI.S6 -
Structures Monitoring Rev. 2 AR 4162907-10 10 CFR 50.65(a)(3) Periodic Assessment of Maintenance Rule Program, Clinton Power Station, 5/30/2017 through 5/21/2018 07/18/2018 ATI 1297234-04 NRC IN 2011-20, Significance Level 3 OPEX Evaluation, Concrete Degradation by Alkali-Silica Reaction 02/14/2012 IR 0888041 Stairways Handrail Post Are Rusted at Connect &
Weld Missing 03/03/2009 IR 1197979 IER - Flood Seals Do Not Have Periodic Inspection Program 04/05/2011 IR 1197979-02 Engineering Response for the Flood Seal Inspection Requirements 09/15/2011 IR 2404234 Trees Grown Near Diesel Generator (DG) Building Wall (Outside of DG Building) 10/31/2014 IR 3973954 NRC NCV 2016004-01 Failed to Ensure Flood Seals Controlled 02/14/2017 ER-AA-450 Structures Monitoring Procedure (Constellation Proprietary)
Rev. 11 ER-CL-450-100 Clinton Structures Monitoring Program (Constellation Proprietary)
Rev. DRAFT ER-CL-450-1006 Clinton Structures Monitoring Instructions (Constellation Proprietary)
Rev. 1 MA-AA-736-600 Torquing and Tightening of Bolted Connections (Constellation Proprietary)
Rev. 14 PM-N/A Ground Water Analysis and Assessment Impact of Changes on Below Grade Structures N/A PM 178804-01 Modify Structures Monitoring Outage PM License Renewal N/A PM 178804-02 Modify Structures Monitoring Online PM for License Renewal N/A
51 Document Title Revision / Date WO 983870-01 Perform Structures Monitoring Inspections During Plant Online 03/18/2009 Letter Y-109621 Maintenance Rule Program - Structures Monitoring Assessment 02/03/2009 WO 04829184-01 Perform Plant Structures Monitoring Inspections Online 04/26/2019 Letter Y-109831 Maintenance Rule Program - Structures Monitoring Assessment 04/26/2019 AR 04234366 ICM076 Support Members Uncoated and Rusts Observed 03/29/2019 AR 04239727 Efflorescence Built-Up on Screen House Tunnel West Wall 04/15/2019 AR 04239985 Efflorescence and Rusts Observed on Embed Plate at Fuel Building 04/16/2019 AR 04240000 Outdoor-Concrete Spalling from Foundation of Make-up Water Pump House (MWPH) Tank 04/16/2019 WO 05307812-01 Maintenance Rule Program - Structures Monitoring Assessment 04/26/2024 AR 04779087 Concrete Spalling from Firewater Storage Tank (FWST) at MWPH 06/06/2024 AR 04779092 Concrete Spalling at Exterior Screen House Deck 06/06/2024 AR 04779408 Concrete Spalling Turbine Building 781 06/07/2024 AR 04779807 Support Corrosion 06/10/2024 WO 5114395-01 Visual Inspection of Cable Trays and Supports at Vault (OSHC-1 D)
N/A During the audit, the staff verified the applicants claim that 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. In addition, the staff found that for the scope of program, parameters monitored or inspected, detection of aging effect, 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 in order 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:
The staff noted in Enhancement No. 2 to the Scope of Program program element that several SCs identified in the LRA as within the scope of the AMP (for instance as metal decking) were not clearly identified in the Structural Commodity Group (Section 2.4.11),
Table 2.4-11, and Table 3.5.2-11.
The staff noted in Enhancements 6 and 7 to the Acceptance Criteria program element that the applicant did not include acceptance criteria for accessible sliding surfaces and elastomeric vibration isolators.
52 The staff noted in Enhancement 8 to the Acceptance Criteria program element that the wording not subject to stress corrosion cracking used for defining high strength bolts is inconsistent with the GALL-LR XI.S6 AMP.
During the on-site audit, the staff performed walkdowns of the primary containment, control building, auxiliary building, fuel building, turbine building, screen house and yard structures. The staff made the following observations during walkdowns:
During the walkdown of the Turbine Building and Auxiliary Building, the staff noted some vertical cracks on the inside of exterior reinforced concrete walls.
During the walkdown of the cable tray supports within vaults, the staff noted that large amount of corrosion on the cable tray supports within vault C.
The staff also audited the description of the LRA Structures Monitoring program provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.35, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Summary of Information in the Application The LRA states that AMP B.2.1.35, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, is an existing program with enhancements that will be consistent with the program elements in GALL-LR Report AMP XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants.
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 keywords. An on-site audit was performed from September 10, 2024, to September 12, 2024.
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 CL-PBD-AMP-XI.S7 Program Basis Document, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Rev. 2 ML24092A344 Clinton Power Station Final Safety Analysis Report Rev. 23 AR 02405990 Clinton Ultimate Heat Sink Issue Report In Response to Braidwood Generating Station Ultimate Heat Sink Issue-Tracking Purpose 11/03/2014 AR 02446783 Technical Specification Compliance Issue Regarding Heat Sink Level 02/03/2015
53 Document Title Revision / Date CC-AA-102 Design Input and Configuration Change Impact Screening (Constellation Proprietary)
Rev. 34 ER-AA-450 Structures Monitoring (Constellation Proprietary)
Rev. 11 ER-CL-450-100 Clinton Structures Monitoring Program (Constellation Proprietary)
Rev. DRAFT ER-CL-450-1006 Clinton Structures Monitoring Instructions (Constellation Proprietary)
Rev. 2 ER-CL-450-2002 Ultimate Heat Sink Monitoring (Constellation Proprietary)
Rev. 1 MA-AA-736-600 Torquing and Tightening of Bolted Connections (Constellation Proprietary)
Rev. 14 PES-S-003 In-Storage of Maintenance of Nuclear Material (Constellation Proprietary)
Rev. 15 PES-S-010 Fasteners (Constellation Proprietary)
Rev. 5 WO 05011184-01 Verify Ultimate Heat Sink Monitoring Report Review 02/04/2021 WO 05130047-01 Verify Ultimate Heat Sink Monitoring Report Review 02/09/2022 S04-1094 Ultimate Heat Sink Plan Rev. F S04-1095 Ultimate Heat Sink Sections Rev. D S04-1101 Ultimate Heat Sink Dam Abutments Plan & Sections Rev. G S20-1117 Ultimate Heat Sink Discharge Structure Plan &
Sections Rev. C S22-1001 Circulating Water Screen House Foundation Plan Rev. M S22-1012 Circulating Water Screen House Section & Details -
Sheet 4 Rev. Y C99-UHS-23(02-10)
Y-109903 Submittal of 2022 Records for Ultimate Heat Sink Monitoring Program 2022 C99-UHS-24(06-13)
Y-109917 Submittal of 2023 Records for Ultimate Heat Sink Monitoring Program 2023 CPS 2400.01 Circulating Water Screenhouse (CWSH) Intake Structure Inspection (Constellation Proprietary)
Rev. 9 CPS 9801.01 Ultimate Heat Sink Monitoring Report Review (Constellation Proprietary)
Rev. 24 EN-AA-405 Dike and Dam Maintenance (Constellation Proprietary)
Rev. 2 IR 04779092 Concrete Spalling at Exterior Screen House Deck 06/06/2024 IR 04239727 Efflorescence Built-Up on Screen House Tunnel West Wall 04/15/2019
54 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, and corrective actions program element(s) of the LRA AMP are consistent with the corresponding element(s) of the GALL-LR Report AMP. In addition, the staff found that for the parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-LR Report AMP. The staff will consider issuing RAI(s) in order 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:
The staff noted in LRA Section B.2.1.35 that inspection frequencies for the Water-Control Structures are not clearly specified.
The staff noted in Enhancement 3 to the Acceptance Criteria program element that acceptance criteria for the cooling lake baffle dike are not clearly stated.
The staff noted that it is not clarified whether Enhancement 8 in LRA Section B.2.1.34 is also applicable to the Water-Control Structures.
The staff noted that the environments specified in Discussion for LRA Table 3.5.1, AMR item 3.5.1-83 are not consistent with those associated with Table 2 AMR items.
The staff made the following observations during walkdowns:
During the walkdown of the Screen House, the staff did not find any significant degradations of the structure. During the discussion with Clinton Power Station (CPS) personnel after the walkdown, the staff noted that, for inspections of underwater structures, CPS ceased to employ divers and instead started using multi-beam sonar equipment in 2020. The staff reviewed color images of the underwater structures (which were generated from the multi-beam sonar inspection data) in 2023 Records for Ultimate Heat Sink Monitoring Program.
The staff also audited the description of the LRA RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program provided in the FSAR supplement.
The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.36, Protective Coating Monitoring and Maintenance Program Summary of Information in the Application The LRA states that AMP B.2.1.36, Protective Coating Monitoring and Maintenance Program, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.S8, Protective Coating Monitoring and Maintenance Program.
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.
55 Document Title Revision / Date CL-PBD-AMP-XI.S8 Program Basis Document Rev 1 AR 04556773 Action Request: Updated Cumulative Dose Values 02/23/23 AR 4026605-04 Coatings Program Check-In Self-Assessment Rev 2 EC 639604 Containment Coatings ECCS Margin Rev 0 ER-AA-330-003 Inservice Inspection of Section XI Component (Constellation Proprietary)Supports Rev 17 ER-AA-335-001 Qualification and Certification of Nondestructive Examination (NDE) Personnel (Constellation Proprietary)
Rev 13 Y-109802 Unqualified & Degraded Field Walkdown Coatings List 05/09/17 CC-AA-205 Control of Undocumented/Unqualified Coatings Inside the Containment (Constellation Proprietary)
Rev 13 ER-AA-330-008 Safety-Related (Service Level I) Protective Coatings (Constellation Proprietary)
Rev 16 1080.01 CPS Protective Coating Program (Constellation Proprietary) 09/05/2014 8901.08 Field Coatings (Constellation Proprietary)
Rev 13A PM 00158471-15 Containment Coatings To Be Inspected (FSAR)
N/A PM 00158471-17 Drywell Coatings Inspection After Each Operating Cycle (FSAR)
N/A WO 01556791 Degraded Coatings/Rusts On Liner Plates Inside Containment 12/02/2013 WO 01871985 Inspect Containment Coatings Each Operating Cycle 05/22/2017 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 Protective Coating Monitoring and Maintenance AMP provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
56 LRA AMP B.2.1.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application.
The LRA notes that AMP B.2.1.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-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 new program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.
Audit Activities.
An on-site audit was performed September 10 to September 12, 2024.
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 CL-PBD-AMP-XI.E1 Program Basis Document Revision 1 Markup MA-AA-723-500 Inspection of Non EQ cables and Connections For Managing Adverse Localized Environments (Constellation Proprietary)
Revision 13 Markup MA-AA-723-500 Bounding Plant Location Temperature Values Table 7 (Clinton) (Constellation Proprietary) not available AR 1569643 IPB5199 Opened and Cables Found with Insulation Cracked 10/08/2013 (event date)
OP-AA-106-101-1006 Attachment B Issue Resolution Documentation Form (associated with IR #: 1569643) (Constellation Proprietary) 10/10/2013 (Revision 12)
NE-22-15-02 Non-EQ Insulated Cable and Connection Inspection Report Revision 0 NE-22-15-1 Clinton Power Station Unit 1 XI.E1 Non-EQ Cable and Connection Program Preliminary Non-Outage Report Revision 0 Enercon Cable Tray White Paper 8-14-2017 Enercon Cable Tray White Paper - Outage 8-14-2017 WO 01657442 Part 1
Clinton Cable Inspection 9/10/2013 WO 01657442 Part 2
Record Content Notification not available
57 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:
During its review of CPS LRA AMP B.2.1.37, the staff identified that the program description of the AMP was not consistent with the corresponding element in GALL-SLRReport AMP XI.E5. Specifically, the program description element for AMP B.2.1.37 did not include an integrated approach for identifying adverse localized environments (ALE) at CPS. In response to the staffs breakout questions, the applicant provided a markup of the program description of LRA AMP B.2.1.37 to include CPS integrated approach for identifying ALE. The applicant will submit the revised program description of LRA AMP B.2.1.37 for consistency with GALL-LRReport AMP XI.E1 in a future supplement.
The staff also audited the description of the LRA Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.38, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Summary of Information in the Application The LRA notes that AMP B.2.1.38, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, 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, available procedures, and referenced documents.
Audit Activities An on-site audit was performed September 10 to September 12, 2024.
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.
58 Document Title Revision / Date CL-PBD-AMP-XI.E2 Program Basis Document Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Rev. 1 ER-AA-300-150 Cable Condition Monitoring Program (Markup)
(Constellation Proprietary)
Rev. 8 CPS 8731.12 Neutron Monitoring Detector Testing (Markup)
(Constellation Proprietary)
Rev. 11 CPS 9437.60A Main Control Room Air Intake Radiation 1RIX-PR009A Channel Calibration (Markup)
(Constellation Proprietary)
Rev.0c CPS 9437.60B Main Control Room Air Intake Radiation 1RIX-PR009B Channel Calibration (Markup)
(Constellation Proprietary)
Rev.0e CPS 9437.60C Main Control Room Air Intake Radiation 1RIX-PR009C Channel Calibration (Markup)
(Constellation Proprietary)
Rev. 0e CPS 9437.60D Main Control Room Air Intake Radiation 1RIX-PR009D Channel Calibration (Markup)
(Constellation Proprietary)
Rev. 0e CPS 9437.64A Accident Range Stack Monitor (AXM) 0RIX-PR008 Channel Calibration (Markup) (Constellation Proprietary)
Rev. 0b CPS 9437.64B Accident Range Stack Monitor (AX) 0RIX-PR012 Channel Calibration (Markup) (Constellation Proprietary)
Rev. 0b WO 01496377 IRM G Spiking 12/12/2011 WO 01773711 High Range Detector Failed PM on 0RIX-PR008 10/01/2014 WO 05223790 IRIX-PR009C Degraded Cabling 3/13/2024 IR #: 04548088 PM Modification Request (PMMR): LR AMP.XI.E2 10 Year Trend of Results not available IR #: 04548088 PM Modification Request (PMMR): Perform TDR, I/V Plot, and CDT on SRM Detectors not available 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 Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in
59 Instrumentation Circuits provided in the FSAR Supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application The LRA notes that AMP B.2.1.39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program with exception that will be consistent with the program elements in GALL-LR Report AMP XI.E3, Inaccessible Power Cables 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 on-site audit was performed September 10 to September 12, 2024.
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 CL-PBD-AMP-XI.E3 Program Basis Document: Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Rev. 1 OP-AA-108-111-1001 Severe Weather and Natural Disaster Guidelines (Markup) (Constellation Proprietary)
Rev. 24 ER-AA-300-150 Cable Condition Monitoring Program (Markup)
(Constellation Proprietary)
Rev. 8 MA-AA-723-330 Electrical Testing of AC Motors Using Baker Instrument Advanced Winding Analyzer (Markup)
(Constellation Proprietary)
Rev. 6 AR 01056715 NER NC-10-008 Yellow Buried Cable Printed 04/04/2024 AR 01056715 Assign #22 NER NC-008-Y Action Item 3 - Identify current inspection and/or dewatering strategy Printed 04/04/2024 AR 00591281 NRC Generic Letter 2007 Power Cable Failures Printed 04/04/2024 AR 00591281 Assign #04 Response to GL 2007-01 Input Printed 04/04/2024 AR 00692997 Submerged Cable Long Term Asset Management Strategy Printed 04/04/2024 DWG E02-1AP03 Sh. 1 Electrical Loading Diagram Clinton Power Station Unit 1 Rev. AD
60 Document Title Revision / Date DWG E-CLT6-T02-OSY01-1 Single Line Diagram 345KV Switchyard Clinton Power Station Units 1 & 2 Rev. W WO 5119345-01 Pump Out and Inspect Safety Related Cable Vaults 04/03/2024 AR 02423635 Cable Vault 0SHA-1C High Water Level Light On Printed 10/10/2024 AR 02595854 NCV 2015007-01 No IRS for Conditions Adverse to Quality Printed 10/10/2024 AR 04079295 0SHC-1C High Level Light On With Vault Dry Printed 10/10/2024 AR 04086090 Cable Vault UAT Will Not Pump Printed 10/10/2024 AR 04464012 0SHA1B Cable Vault High Level Advisory Printed 10/10/2024 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 will be consistent with the corresponding elements of the GALL-LRReport AMP.
The staff also verified the applicants claim that aspects of 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 element inthe GALL-LR Report AMP.
During the audit, the staff made the following observations:
During its review of the CPS LRA AMP, the staff identified that the applicants planned inspection frequency of non-safety related manholes and operational testing of dewatering equipment before heavy rain/flooding was not consistent with GALL-LR. The applicant plans to revise LRA AMP B.2.1.39 to ensure consistency with GALL-LRReport AMP XI.E3 in a future supplement.
The staff also audited the description of the LRA Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements provided in the FSAR supplement.
The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.40, Metal Enclosed Bus Summary of Information in the Application The LRA notes that AMP B.2.1.40, Metal Enclosed Bus, is an existing program that is consistent with the program elements in GALL-LR Report AMP XI.E4, Metal Enclosed Bus.
Audit Activities An on-site audit was performed September 10 to September 12, 2024.
61 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 CL-PBD-AMP-XI.E4 Metal Enclosed Bus Rev. 1 ER-AA-300-140 License Renewal Metal Enclosed Program (Constellation Proprietary)
Rev. 4 PM Modification Request (PMMR) IR
- 04548088 LR AMP.XI.E4 MEB Inspections Not available WO 01368885 LL - SER 5-09 Check Tightness of Bolts for 4 KV &
6.9 KV Bus 04/19/2011 WO 01471750 Create WO for SER 5-09 Non-Seg Bus Torque/DLRO Checks ERAT 10/26/2015 WO 047770333 Perform EMI Survey on UAT Non Seg Bus (POW1 C1R18) 11/12/2018 AR 01108235 LL-SER 5-09 Check Tightness of Bolts for 4 KV &
6.9 KV Bus OIO 08/31/2010 (event date)
AR 01297528 Crack IDD on 1AT4B UAT Non-Seg Bus U-Bracket 12/03/2011 (event date)
AR 00989226 SER 5-09 Nonsegregated Bus Failure and Complicated Scram Print date 05/29/2024 DWG E02-1AP03 Electric Loading Diagram Clinton Power Station Unit 1
Rev. AD 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 Metal Enclosed Bus provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
The staff made the following observationduring walkdowns:
During the on-site audit, the staff interviewed the applicants staff and performed a walkdown from the switchyard to the auxiliary, control, diesel generator, and turbine building. The conditions of the metal enclosed bus that were observed by the staff did not show significant signs of age-related degradation.
62 LRA AMP B.2.1.41, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application The LRA notes that AMP B.2.1.41, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-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 on-site audit was performed September 10 to September 12, 2024.
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 CL-PBD-AMP-XI.E6 Program Basis Document: Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Rev. 1 CL-AMPBD-E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Sample Basis Document Rev. 0 ER-AA-300-120 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program (Markup) (Constellation Proprietary)
Rev. 5 AR 1654494 1RP10J Increasing Thermography Trend on Fuste/Fuse Holder Printed 05/29/2024 AR 4154359 High Delta T Observed Using Thermography on CT in RAT SVC Printed 05/29/2024 AR 4252836 High Delta T Observed Using Thermography on 1MP04EA 52-05 Printed 05/29/2024 AR 4154359 Risk Issue CPS-1-2018-0260 RAT SVC CT Elevated Delta T Printed 04/04/2024 AR 4154359 Risk Issue CPS-1-2018-0318 RAT SVC CT Elevated Delta T Printed 04/04/2024 MA-AA-716-230 Predictive Maintenance Program (Markup)
(Constellation Proprietary)
Rev. 11 MA-AA-716-230-1003 Thermography Program Guide (Constellation Proprietary)
Rev. 7 Engineering Technical Evaluation 20230329 New One-Time Technical Evaluation to Evaluate Thermography and Contact Resistance Testing Results Printed 04/04/2024
63 Document Title Revision / Date AR 01608125 Div 3 DC Possible High Resistance Control Circuit Connection Printed 10/10/2024 AR 03984857 RA OE: Loss of Safety Function Due to Two Inoperable Standby Liquid Control Subsystems Printed 10/10/2024 AR 04263873 Test Position Failed to Energize/Open Drain Solenoid Valve Printed 10/10/2024 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 Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements provided in the FSAR supplement.
The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Summary of Information in the Application The LRA states that AMP B.2.1.42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, 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 Exchanger, and Tanks, as described in LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks. 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 CL-PBD-AMP-XI.M42 Program Basis Document: Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Rev.1 AR 00539602 Action Request: 1DO01TA Has Small Area of Coating Peeled Off 10/03/2006 AR 01626078 Action Request: Missing Coating on 0WO02CD Condenser Water Box 02/25/2014 AR 01656705 Action Request: 1SX20AB As-Found Inspection of Coating 05/06/2014 AR 02566881 Action Request: Indications Found During Fuel Tank Inspection 10/07/2015
64 Document Title Revision / Date EC403488 Document Acceptability of the Existing Coating Deficiency Identified Per A/R 02566881 for 1DO01TB Rev. 0 WO 1468632 Work Order: 0WO02CD Clean Heat Exchanger, Hydrolance Tubes, Eddy 01/17/2014 ER-AA-330-014 Exelon Safety-Related (Service Level III) Coatings (Constellation Proprietary)
Rev. 5 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, detection of aging effects, and monitoring and trending 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, 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 an RAI in order 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 FSAR supplement.
The staff verified this description is consistent with the description provided in the SRP-LR.
LRA AMP B.3.1.1, Fatigue Monitoring Summary of Information in the Application The LRA states that aging management program (AMP) B.3.1.1, Fatigue Monitoring, is an existing 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.
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 experience (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 program. The staff will document its review of this information in the SE.
65 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 Report AMP, or will be consistent after implementation of the identified enhancements.
The staff also audited the description of the LRA Fatigue Monitoring AMP provided in the FSAR supplement. The staff verified this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 3.1.2.5.
Document Title Revision /
Date ER-AA-700-1003 Use of Operating Experience for License Renewal Implementation/Aging Management (Constellation Proprietary)
Rev.6 PI-AA-115 Operating Experience Program (Constellation Proprietary)
Rev. 7 CPS-PBD-AMP-X.M1 Program Basis Document Fatigue Monitoring Rev. 3 07/23/2024 ER-AA-47 Fatigue Management Program Description (Constellation Proprietary)
Rev. 3 ER-AA-470 Fatigue and Transient Monitoring Program (Constellation Proprietary)
Rev. 10 CPS 1437.01 NSSS Transient Monitoring (Constellation Proprietary)
Rev. 2a 10/15/2014 EC 627713 CPS Fatigue Monitoring Report 2018 09/24/2019 AR 00815315 CPS Exceeded 80% of Allowable Turbine Roll Transients 09/08/2008 AR 01105330 Fatigue Monitoring Related to Turbine Roll Transients 08/24/2010 AR 00905434 Potential Issue with FatiguePro Monitoring of FW Nozzle 04/09/2009 AR 02535716 Location MS-460 Reaches 80% Cumulative Usage Factor (CUF) 07/31/2015 AR 02724948 FatiguePro Program Data Shows No Change in FW Nozzle Fatigue 10/06/2016 AR 04521325 LR - MSIV Lines EC 360654 09/08/2022 AR 04554704 2001 EPU Report Results Not Incorporated in Fatigue Program 02/15/2023
66 LRA AMP B.3.1.2, Environmental Qualification (EQ) of Electric Components Summary of Information in the Application The LRA notes that AMP B.3.1.2, Environmental Qualification (EQ) of Electric Components, 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 on-site audit was performed September 10 to September 12, 2024.
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 CL-PDB-AMP-X.E1 Environmental Qualification (EQ) of Electric Components GALL PROGRAM X.E1 - Environmental Qualification (EQ) of Electric Components Rev. 1 AR 02537305 10 CFR Part 21 NAMCO EA180 and EA170 Limit Switches Print date 05/30/2024 AR 02541236 Part 21: NAMCO Limit Switch (EA170/EA180)
Print date 05/30/2024 AR 04431409 NOS ID: Develop work down curve for EQ Binder revisions Print date 05/30/2024 AR 04675921 EQ Program Document Issues Print date 05/30/2024 AR 04775740 LR: Enhance CPS EQ Program to Support 60 Year Ops Print date 09/12/2024 AR 04776265 LR: EQ Process Radiation Monitors Print date 09/12/2024 CC-AA-203 (Markup)
Environmental Qualification Program (Constellation Proprietary)
Rev. 17 NSED Procedure E.6 Environmental Qualification Packages (Constellation Proprietary)
Rev. 13 NSED-MEQPM-MS-02.00 Maintenance of Equipment Qualification Program Manual (Constellation Proprietary) 10/19/2018 EC 0000636711 RWCU Differential Flow modification 03/13/2024 CPS EQ Challenges (IR #: 4776265)
EQ-CL016 - Eberline SR Process Radiation Monitoring System 08/19/2024 EQ-CL003 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 14 EQ-CL011 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 22
67 Document Title Revision / Date EQ-CL037 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 08 EQ-CL068 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 11 EQ-CL093 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 16 EQ-CL015 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 03 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 Environmental Qualification (EQ) of Electric Components provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR Report.
The staff made the following observation during walkdowns:
During the on-site audit, the staff interviewed the applicants staff and performed a walkdown. During the staff interviews, the staff asked the applicant if they were aware of the latest version of the EPRI Report NP-1558, A Review of Aging Theory and Technology, and whether they assessed its potential impact on the qualification of electrical components in the CPS EQ program. The applicant responded that they reviewed their EQ files and determined that there was only one EQ binder that used an activation energy value from EPRI Report NP-1558 and the selected activation energy remains valid in the current version of the report.
LRA TLAA Section 4.1, Identification and Evaluation of Time-Limited Aging Analyses (TLAAS)
Summary of Information in the Application LRA Section 4.1, Identification and Evaluation of Time-Limited Aging Analyses (TLAAS),
discusses the methodology for the identifying of TLAAs in the LRA. The staff performed an audit to verify the implementation of the applicants methodology to identify TLAAs in accordance with 10 CFR Part 54. Issues identified but not resolved in this report will be addressed in the SE.
Audit Activities During the audit, the staff reviewed documentation contained in the LRA and provided by the applicant via the ePortal. The table below lists documents that were reviewed by the staff and were found relevant to its review for TLAA identification. The staff will document its review of this information in the SE.
68 Document Title Revision / Date CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document -
Part 1 - TLAA Identification -
Clinton LR Includes Attachments 1 through 13 Rev. 0 Updated Safety Analysis Report Rev. 23 During the audit, the staff verified that the applicant has provided its basis and methodology for identifying TLAAs, as defined in 10 CFR 54.3(a), in accordance with 10 CFR 54.21(c)(1).
During the audit, the staff made the following observations:
The staff reviewed the CL-TLAABD, Part 1, and confirmed that current licensing basis and design basis documentation were searched to identify potential TLAAs.
o The staff noted that specific key words were used during this search that would identify potential TLAAs. The staff noted that a comprehensive list of key words was used for this search.
o The staff noted that keywords used were reasonable for identifying analyses associated with time-dependency and aging-related degradation.
Keywords included, but not limited to the following: fluence, life, cycles, 40-year, 50.12, exemption, corrosion allowance of CL-TLAABD, Part 1 - contained the applicants complete list of keywords The staff reviewed the CL-TLAABD, Part 1, 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 period of extended operation.
o of CL-TLAABD, Part 1 - contained the applicants complete documentation of dispositioning any potential analyses against the six criteria of a TLAA in 10 CFR 54.3 The staff reviewed the CL-TLAABD, Part 1, and confirmed that a search of docketed licensing correspondence, the operating license, and the FSAR identified whether there were any active exemptions currently in effect pursuant to 10 CFR 50.12.
69 The staff reviewed the CL-TLAABD, Part 1, and confirmed that these exemptions were then reviewed to determine whether the exemption was based on a TLAA.
o The staff confirmed that there are no identified 10 CFR 50.12 exemptions identified that is currently in effect that is based upon a TLAA.
LRA TLAA Section 4.2.1, Reactor Pressure Vessel and Internals Neutron Fluence Analyses Summary of Information in the Application LRA Section 4.2.1, Reactor Pressure Vessel and Internals Neutron Fluence Analyses, 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.
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 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 CL-TLAABD TLAA Basis Document - Part 2 - TLAA Evaluation Rev. 0 NEDC-32983P-A Licensing Topical Report - General Electric Methodology for Reactor Pressure Vessel Fast Neutron Flux Evaluations Rev. 2 During the audit of the TLAA, the staff verified that the applicant provided basis that supports the disposition of 10 CFR 54.21(c)(1)(ii). In addition, the staff determined that no RAI was necessary. The staff will discuss the findings of the audit in the SE.
LRA TLAA Sections 4.2.2 and 4.2.3 (Upper-Shelf Energy and Adjusted Reference Temperature)
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, Reactor Pressure Vessel Upper-Shelf Energy (USE) Analyses 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).
70 LRA Section 4.2.3, Reactor Pressure Vessel Adjusted Reference Temperature (ART)
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 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 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 CL-TLAABD TLAA Basis Document - Part 2 - TLAA Evaluation Rev. 0 BWRVIP-135 BWR Vessel and Internals Project: Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations Rev. 4 BWRVIP-74-A BWR Vessel and Internals Project: BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal 06/2003 GEH Report 007N4076R0 License Renewal Fluence & RPV Internal Analysis Rev. 0 GEH Report DBR-00686669 GEH Internal Design Basis Record - Design Notes Rev. 0 GE-NE-B13-02084-00-01 Pressure-Temperature Curves For AmerGen, Clinton Power Station Using the KIC Methodology Rev. 0 GEH Report 0000-0132-5419 GEH internal Design Basis Record - Design Notes Rev. 1 GE, DRF No. A00-01796 GEH internal Design Basis Record - Design Notes 01/1985 Certified Material Test Report for Heat C4209-1 Certified Material Test Report for Heat C4212-1 Certified Material Test Report for Heat C4245-1 Certified Material Test Report for Heat Q2QL13W Certified Material Test Report for Heat Q2QL4W Certified Material Test Report for Heat Q2QL8QT (N2)
Certified Material Test Report for Heat Q2QL8W Certified Material Test Report for Heat Q2QL8QT (N6)
Certified Material Test Report for Heat Q2QL19QT Certified Material Test Report for Heat 3P4955/3478 (Single)
71 Document Title Revision / Date Certified Material Test Report for Heat 3P4955/3478 (Tandem)
Certified Material Test Report for Heat 3P4955/3478 (Tandem)
Certified Material Test Report for Heat 422P5621/L414B27AD Certified Material Test Report for Heat C4320-2 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 Sections 4.2.2 and 4.2.3.
During the audit, the staff made the following observations:
The staff verified that the material information (e.g., initial RTNDT, %Cu, %Ni, initial USE, margin values) for the RPV materials contained in LRA Tables 4.2.2-1, 4.2.2-2, 4.2.2-3, 4.2.2-4, 4.2.2-5, 4.2.2-6, 4.2.2-7, 4.2.3-1, 4.2.3-2, 4.2.3-3, and 4.2.3-4, 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 Or based on information from certified material test reports (CMTRs) or fabrication records for the specific material or weld type The staff noted that the %Cu of the following RPV materials were calculated in a manner more conservative than the methodology in RG 1.99, Revision 2 (GE, DBR-0068669, Rev 0):
o CPS Shell #3 plates contained in LRA Table 4.2.3-1 (i.e., Heat Nos.
C4209-1, C4212-1 and C4245-1) o CPS N1 nozzle contained in LRA Tables 4.2.2-3 and 4.2.3-3 (i.e., Heat No. Q2QL13W) o CPS N6 nozzle, contained in LRA Tables 4.2.2-3 and 4.2.3-3 (i.e., Heat No. Q2QL8QT).
The staff noted that for the following RPV materials, plant-specific measured values from CMTRs or fabrications records were used in lieu of best estimate data:
o
%Ni of CPS Heat No. 5P6756 contained in LRA Tables 4.2.3-1 through 4.2.3-4 (GE, DRF No. A00-01796).
o Initial USE for CPS Heat No. C4320-2 contained in LRA Table 4.2.2-1 (CMTR for Heat No. C4320-2).
o Initial USE for CPS Heat No. 422P5621/L414B27AD contained in LRA Table 4.2.2-2 (CMTR for Heat No. 422P5621/L414B27AD).
72 The staff noted that USE data of CPS N2 nozzles contained in LRA Tables 4.2.2-3 and 4.2.3-3 (i.e., Heat Nos. Q2QL4W, Q2QL8QT, Q2QL8W) were not available in CMTRs and were conservatively determined (i.e., lowest of all measured values for same class of material) (GEH, 0000-0132-5419, Revision 1).
The staff confirmed that the initial RTNDT for the CPS Shell #3 plates contained in LRA Table 4.2.3-1 (i.e., Heat Nos. C4209-1, C4212-1 and C4245-1) were determined based on available information in CMTRs based on a methodology previously approved by the NRC (GE-NE-B13-02084-00-01).
The staff noted LRA Table 4.2.3-4 discusses the applicants adjustment for ART when considering surveillance data. The staff verified the applicants assessment of surveillance data contained in BWRVIP-135, Revision 4 was performed in accordance with RG 1.99, Revision 2, for the following RPV material:
o Heat No. 5P6756 The staff also audited the description of the USE and ART TLAAs in LRA Section A.4.2.2 and A.4.2.3, respectively, provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.2.4, Reactor Pressure Vessel Pressure-Temperature (P-T) Limits Summary of Information in the Application LRA Section 4.2.4, Reactor Pressure Vessel Pressure-Temperature (P-T) Limits, discusses the analysis for the P-T limit curves, which specify the minimum acceptable reactor coolant temperature as a function of reactor pressure, associated with the RPV. 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 Constellation Energy Generation, LLC - Docket No.
50-461 Clinton Power Station, Unit No. 1 Facility Operating License - Technical Specifications -
Section 3.4.11 Amendment No.
134 CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document
- Part 2 - TLAA Evaluation - (Clinton LR) - Section 4.2.4 Rev. 0 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).
73 During the audit, the staff made the following observations:
Current P-T limits are contained in Technical Specification Section 3.4, "REACTOR COOLANT SYSTEM (RCS) - Section 3.4.11 RCS Pressure and Temperature (P/T)
Limits Current P-T limits are applicable though 32 Effective Full Power Years (EFPY)
The staff also audited the description of the LRA TLAA provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.2.5, Reactor Pressure Vessel Circumferential Weld Failure Probability Analyses Summary of Information in the Application LRA Section 4.2.5, Reactor Pressure Vessel Circumferential Weld Failure Probability Analyses discusses the analysis for the RPV circumferential weld failure probability. The applicant dispositioned the TLAAs in accordance with 10 CFR54.21(c)(1)(iii).
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 used the following relevant keywords:
(cracking, embrittlement)
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 CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document
- Part 2 - TLAA Evaluation - (Clinton LR) - Section 4.2.5 Rev. 0 BWRVIP-05 BWR Vessel and Internals Project, BWR Reactor Pressure Vessel Shell Weld Inspection Recommendations (BWRVIP-05) (Proprietary) 09/1995 BWRVIP-05 SER (Final)
USNRC letter from Gus C. Lainas to Carl Terry, Niagara Mohawk Power Company, BWRVIP Chairman, Final Safety Evaluation of the BWR Vessel and Internals Project BWRVIP-05 Report, (TAC No.
M93925) (Proprietary) 07/28/1998 USNRC Generic Letter 98-05, Boiling Water Reactor Licensees Use of the BWRVIP-05 Report to Request Relief From Augmented Examination Requirements on Reactor Pressure Vessel Circumferential Shell Welds 11/10/1998 Supplement To Final Safety Evaluation of the BWR Vessel and Internals Project BWRVIP-05 Report (TAC NO. MA3395) 03/07/2000
74 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 staff confirmed that the RPV material identified in LRA Table 4.2.5-1 (i.e., Heat No.
76492) is the limiting RPV circumferential weld The staff confirmed the material property information for Heat No. 76492 is consistent with the information in FSAR Section 5.3.
The staff also audited the description of the LRA TLAA provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.2.6, Reactor Pressure Vessel Axial Weld Failure Probability Analyses Summary of Information in the Application LRA Section 4.2.6, Reactor Pressure Vessel Axial Weld Failure Probability Analyses discusses the analysis for the reactor pressure vessel axial weld failure probability. The applicant dispositioned the TLAAs in accordance with 10 CFR54.21(c)(1)(ii).
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 used the following relevant keywords:
(cracking, embrittlement).
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 CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document
- Part 2 - TLAA Evaluation - (Clinton LR) - Section 4.2.6 Rev. 0 ML093640023 NRC Letter - Clinton Power Station Unit No.1 -
Request For Alternative 4215 For Class 1 Reactor Vessel Circumferential Shell Welds (TAC No.
ME0407) 12/30/2009 BWRVIP-74-A BWR Vessel and Internals Project - BWR Reactor Pressure Vessel Inspection and Flaw Evaluation Guidelines for License Renewal, (Proprietary) 06/2003 Supplement To Final Safety Evaluation of the BWR Vessel and Internals Project BWRVIP-05 Report (TAC NO. MA3395) 03/07/2000 BWRVIP-135 Integrated Surveillance Program (ISP) Data Source Book and Plant Evaluations (Proprietary)
Rev.4
75 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).
During the audit, the staff made the following observations:
The staff confirmed that the RPV material identified in LRA Table 4.2.6-1 (i.e., Heat No.
3P4955/0342) is the limiting RPV axial weld The staff confirmed the material property information for Heat No. 3P4955/0342 is consistent with the information in FSAR Section 5.3. The staff noted that Cu% and Ni%
for this material is the BWRVIP Integrated Surveillance Program best estimate chemistry and is also contained in BWRVIP-135, Revision 4. The staff will evaluate this in its SE.
The staff also audited the description of the LRA TLAA provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.2.8, Jet Pump Beam Bolts and Core Plate Bolts Preload Relaxation Analyses Summary of Information in the Application LRA Section 4.2.8 Jet Pump Beam Bolts and Core Plate Bolts Preload Relaxation Analyses, discusses the analyses for stress relaxation in important bolts that must carry a load to maintain functionality of the jet pump and the core plate. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii).
Audit Activities The staff reviewed the OE listed in the LRA and the document portal. 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 007N3874 RPV Internals Analysis of Preloaded Joints & Core Shroud Thermal Shock Analysis (Proprietary)
Rev. 0 12/2022 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)(ii).
During the audit, the staff made the following observations:
General Electric Hitachi (GEH) proprietary report 007N3874 describes clamping loads relied on by the applicant, but it does not explain how those loads were determined.
The applicant explained that GEH calculated required clamping loads based on operating conditions. Then, GEH used proprietary stress relaxation data to ensure that the end-of-life clamping loads are greater than the required loads.
76 The staff also audited the description of the Jet Pump Beam Bolts and Core Plate Bolts Preload Relaxation Analyses provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.2.9, Core Shroud Repair Stabilizer Assembly Bracket Preload Relaxation Analysis Summary of Information in the Application LRA Section 4.2.9 Core Shroud Repair Stabilizer Assembly Bracket Preload Relaxation Analyses, discusses the analyses for stress relaxation in repair hardware for the core shroud.
The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii).
Audit Activities The staff reviewed the OE listed in the LRA and the document portal. 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 007N3874 RPV Internals Analysis of Preloaded Joints & Core Shroud Thermal Shock Analysis (Proprietary)
Rev.0 12/2022 During the audit of the TLAA, the staff questioned the applicants basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
During the audit, the staff made the following observations:
General Electric Hitachi (GEH) proprietary report 007N3874 describes clamping loads relied on by the applicant, but it does not explain how those loads were determined.
The applicant explained that GEH calculated required clamping loads based on operating conditions. Then, GEH used proprietary stress relaxation data to ensure that the end of life clamping loads are greater than the required loads.
The applicant explained that the TLAA may be more appropriately dispositioned as 10 CFR 54.21(c)(1)(i), since the clamping load analysis was not updated.
The applicant stated that they may submit a supplement changing the proposed disposition of the TLAA.
The staff also audited the description of the Core Shroud Repair Stabilizer Assembly Bracket Preload Relaxation Analyses provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
77 LRA TLAA Section 4.2.10, Reactor Pressure Vessel Core Support Structure Strain Evaluation Summary of Information in the Application LRA Section TLAA 4.2.10, Reactor Pressure Vessel Core Support Structure Strain Evaluation, discusses the evaluation of core support structure components: the shroud, shroud support, top guide, core plate, core plate wedges, orificed fuel support, peripheral fuel support, control rod guide tubes, and control rod housing. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii). To verify that the applicant provided an acceptable technical basis to support its disposition of the TLAA, the staff audited the TLAA.
Audit Activities A search of the applicants operating experience database was conducted using keywords: flaw evaluation, core support, stresses, design cycle, neutron fluence, RPV internals, stress analysis, and cracking. No significant plantspecific operating experience associated with the LRA TLAA Section 4.2.10, was noted by the staff during its review.
During its audit, the staff interviewed the applicants staff and reviewed documentation provided by the applicant. The staff reviewed the following relevant documents.
Document Title Revision /
Date GE Hitachi, ePortal Reference 4.9.11 Clinton RPV Internals Fluence Impact Assessment Revision 0 November 2022 GE, ePortal Reference 4.9.12 Stress Analysis report for BWR/6-218 Core Plate and Lower Shroud Revision 0 1979 GE, ePortal Reference 4.9.93 Core Support Structure Revision 8 8/29/1991 LRA Section 4.2.10 Reactor Pressure Vessel Core Support Structure Strain Evaluation Revision 0 2/14/2024 LRA Section 4.2.1.2 Reactor Pressure Vessel Internals Neutron Fluence Analysis Revision 0 2/14/2024 During the audit of the TLAA, the staff verified that the applicant has provided its technical basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
During the audit, in addition to reviewing relevant Clinton LRA sections, the staff reviewed the following three reports in the ePortal, Clinton RPV Internals Fluence Impact Assessment, Stress Analysis report for BWR/6-218 Core Plate and Lower Shroud, and Core Support Structure.
78 Based on those reports, the staff made the following observations:
The staff noted that Clinton design specifications required calculated strain assessments of reactor core support structure components fabricated from 304, 304L, 308, and 308L austenitic stainless steels if the specified fluence thresholds in the design specifications were exceeded as discussed in ePortal reference 4.9.11, Clinton RPV Internals Fluence Impact Assessment.
The staff confirmed that evaluations demonstrating that the specified design criteria were met for the 40-year life of the station, were documented in the original component design stress reports as discussed in the report, Stress Analysis report for BWR/6-218 Core Plate and Lower Shroud.
The staff confirmed that Clinton evaluated core support structure components fabricated from austenitic stainless steels using 60-year fluence projections (52 EFPY) as discussed in the report, Clinton RPV Internals Fluence Impact Assessment report.
o The staff confirmed that the applicants methodology in this updated strain assessment for 60 years is consistent with the methodology used in the original design analysis (i.e., Stress Analysis report for BWR/6-218 Core Plate and Lower Shroud.)
o The staff confirmed that the acceptance criteria in the applicants updated strain assessment is consistent with those established in the original design analysis (i.e.,
Stress Analysis report for BWR/6-218 Core Plate and Lower Shroud.)
o The staff confirmed that the applicants updated strain assessment took into consideration the neutron fluence exposure of the RPV core support structure through 60 years of operation as discussed in LRA Section 4.2.1.2, Reactor Pressure Vessel Internals Neutron Fluence Analyses, and ePortal Reference 4.9.11, Clinton RPV Internals Fluence Impact Assessment.
o The staff noted that LRA Section 4.2.1.2 states that the applicant has used the NRC approved GEH DORT methodology in developing 60-year fluence projections that account for an Extended Power Uprate (EPU). These 60-year fluence projections are based on the methodology in Licensing Topical Report (LTR) NEDC-32983P-A (LRA Reference 4.8.9 or ML072480121).
The staff found that sufficient information was available to complete its review of TLAA Section 4.2.10.
During the audit of the operating experience associated with the TLAA, the staff independently searched the plant-specific database to identify any previously unknown or recurring aging effects. The staff did not identify any additional aging effects that would have an impact on the evaluation of the TLAA.
The staff also audited the summary description of the TLAA for the reactor pressure vessel core support structure strain evaluation provided in Section A.4.2.10 of the UFSAR supplement. The staff verified this summary description is consistent with the generic description provided in the SRPLR.
79 LRA TLAA Section 4.3.1, Transient Cycle And Cumulative Usage Projections For 60 Years Summary of Information in the Application LRA Section 4.3.1, Transient Cycle And Cumulative Usage Projections For 60 Years, discusses the 60-year projections of design transient cycles and the associated cumulative usage factor (CUF) and environmentally adjusted CUF (CUFen) values. The applicant did not identify these projections as a TLAA because (1) the 60-year projections are used as the input to the fatigue TLAAs in LRA Sections 4.3.2 through 4.3.7 and (2) the specific dispositions of the TLAAs are separately addressed in LRA Sections 4.3.2 through 4.3.7. To verify the adequacy of the cycle and cumulative usage projections, the staff audited the applicants approach in LRA Section 4.3.1. 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 operating experience (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 60-year projections of transient cycles and the associated CUF and CUFen values. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document - Part 2 - TLAA Evaluation -
Clinton LR Rev. 0 02/6/2024 Structural Integrity Associates (SIA) FP-CPS-314 Cycle, Fatigue, and Environmentally Assisted Fatigue (EAF) Projections for 60 Years Rev. 1 12/22/2023 SIA 1701003.301 SI:FatiguePro4 Cycle and Fatigue 60-Year Projections Rev. 0 05/04/2022 During the audit of the cycle and cumulative usage projections, the staff verified that the applicant provided its basis for the projections. However, the staff found that sufficient information was not available to complete its review of the adequacy of the 60-year projections.
In order to obtain the necessary information, the staff will consider issuing RAIs. During the audit, the staff made the following observations.
LRA Table 4.3.1-1 indicates that the number of the 60-year projected occurrences (cycles) of the design hydrostatic test transient is 44, which is greater than the design transient cycles of
- 40. Similarly, LRA Table 4.3.1-1 indicates that, for the turbine roll transient and hot zero power scram transient, the number of 60-year projected cycles exceeds the number of design transient cycles.
80 In comparison, the applicant dispositioned the fatigue TLAAs for the following components in accordance with 10 CFR54.21(c)(1)(i): (1) main steam isolation valves; (2) safety/relief valves; (3) recirculation system flow control valves; (4) recirculation system gate valves; (5) recirculation system pumps; (6) control rod drives; and (7) core plate stiffener to skirt weld and top guide/grid reactor vessel internal components.
Given the TLAA disposition for the components discussed above in accordance with 10 CFR54.21(c)(1)(i) (i.e., not using cycle projections or Fatigue Monitoring AMP), the staff needs clarification on whether the 60-year projected cycles of the design hydrostatic test, turbine roll, and hot zero power scram transients, which are greater than the design cycles, may affect the validity of the TLAA disposition (e.g., resulting in the 60-year CUF values of these components exceeding the design limit).
The staff also audited the description of the 60-year cycle and cumulative usage projections.
The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 4.3.2.2.
LRA TLAA Section 4.3.2, ASME Section III, Class 1 and Environmentally Assisted Fatigue Analyses Summary of Information in the Application LRA Section 4.3.2, ASME Section III, Class 1 and Environmentally Assisted Fatigue Analyses, discusses the Class 1 fatigue and environmentally assisted fatigue (EAF) TLAAs. The applicant dispositioned the TLAAs in accordance with 10 CFR54.21(c)(1)(iii). To verify that the applicant provided a basis to support its disposition of the TLAAs, the staff audited the TLAAs.
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 operating experience (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 Class 1 fatigue and EAF TLAAs. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document - Part 2 - TLAA Evaluation - Clinton LR Rev. 0 02/06/2024 SIA FP-CPS-314 Cycle, Fatigue, and Environmentally Assisted Fatigue (EAF) Projections for 60 Years Rev. 1 12/22/2023 SIA 1701003.301 SI:FatiguePro4 Cycle and Fatigue 60-Year Projections Rev. 0 05/04/2022
81 Document Title Revision / Date SIA 1701003.304 Environmentally Assisted Fatigue Screening for Clinton Rev. 0 10/21/2022 SIA 1701003.305 Environmentally Assisted Fatigue Calculations for Sentinel Locations at Clinton Rev. 0 03/17/2023 SIA FP-CPS-403 SI:FatiguePro 4.0 SBF Transfer Functions for Clinton Power Station Fatigue Monitoring System Rev. 1 04/18/2023 During the audit of the TLAAs, 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 TLAA disposition. In order 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 indicates that the screening values of environmental fatigue correction factor (Fen) are based on the component material, maximum operating temperature, and bounding dissolved oxygen. The LAR also indicates that sulfur content is also an input for carbon and low alloy steels component Fen screening values.
However, LRA Section 4.3.2 does not clearly discuss how the applicant determined conservative sulfur content (for carbon and low alloy steels) and strain rates in the screening EAF evaluations. In addition, the staff needs clarification on how the applicant removed the excessive conservatism associated with the CUFen values in the detailed EAF evaluation after the screening EAF evaluation.
LRA Section 4.3.2 addresses the EAF TLAA for Class 1 piping systems. Specifically, LRA Table 4.3.1-2 describes the 60-year projected values of environmentally adjusted cumulative usage factor (CUFen) for the limiting (bounding) EAF locations. However, LRA Table 4.3.1-2 does not describe the materials of the limiting locations. The staff also needs clarification on whether the applicant eliminated certain EAF locations based on the more limiting EAF locations fabricated with a different material (e.g., a low alloy steel location was eliminated in consideration of the more limiting stainless steel location in the screening evaluation for EAF). In addition, LRA Table 4.3.1-2 does not clearly describe the specific piping systems or components (e.g., specific reactor vessel components) of the limiting EAF locations.
The staff also audited the description of the Class 1 fatigue and EAF TLAAs in the FSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 4.3.2.2.
LRA TLAA Section 4.3.3, ASME Section III, Class 1 Components Summary of Information in the Application LRA Section 4.3.3, ASME Section III, Class 1 Components, discusses the Class 1 fatigue TLAAs for the following piping systems and components: (1) main steam system; (2) main steam isolation valves; (3) safety and relief valves; (4) recirculation system; (5) recirculation
82 system flow control valves; (6) recirculation system gate valves; (7) recirculation system pumps; and (8) control rod drives.
The applicant dispositioned the fatigue TLAAs for the main steam system and recirculation system in accordance with 10 CFR54.21(c)(1)(iii). The applicant dispositioned the fatigue TLAAs for the valves, pumps and control rod drives discussed above in accordance with 10 CFR54.21(c)(1)(i).
To verify that the applicant provided a basis to support its dispositions of the fatigue TLAAs, the staff audited the TLAAs. 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 operating experience (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 the Class 1 piping systems and components. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document - Part 2 - TLAA Evaluation - Clinton LR Rev. 0 02/06/2024 SIA FP-CPS-314 Cycle, Fatigue, and Environmentally Assisted Fatigue (EAF) Projections for 60 Years Rev. 1 12/22/2023 VPF3948-044 Design Report for 24 Main Steam Isolation Valve Rev. 1 02/15/1988 VPF-5529-029 Stress Report No. G471-6/125.04.07: 8 inch-1500 Cast Carbon Steel Safety Relief Valve Rev. 8 05/02/1979 SIR-99-055 Report on System Review and Recommendations for a Transient and Fatigue Monitoring System at the Clinton Power Station Rev. 0 08/02/1999 VPF5521-212 Design Report #638 Design Analysis of a 20-inch Flow Control Valve Rev. 3 08/21/1979 SQ-CL731 Dynamic Qualification of Recirculation Discharge Valve 1B33-F067A/B Rev. 5 06/21/1990 SQ-CL620 Qualification Document for Recirculation Pumps, Tab D, Stress Analysis Rev. 5 04/25/1983
83 Document Title Revision / Date 22A4912 Control Rod Drive Rev. 2 02/09/1991 During the audit of the TLAAs, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii) for the main steam system and recirculation system and its disposition of 10 CFR 54.21(c)(1)(i) for the valves, pumps and control rod drives described above. However, the staff found that sufficient information was not available to complete its review of the applicants basis for TLAA dispositions. In order to obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations related to LRA Section 4.3.3. As previously discussed, the applicant dispositioned the fatigue TLAAs for the main steam system and recirculation system in accordance with 10 CFR54.21(c)(1)(iii). The applicant also dispositioned the fatigue TLAAs for the valves, pumps and control rod drives discussed above in accordance with 10 CFR54.21(c)(1)(i). In comparison, LRA Section 4.3.2.1 addresses the fatigue analyses for the ASME Code Section III, Class 1 RPV and piping components. The applicant dispositioned these fatigue TLAAs in accordance with 10 CFR54.21(c)(1)(iii).
It is not clear to the staff whether some of the Class 1 piping systems and components are addressed in both of the LRA sections (i.e., LRA Sections 4.3.3 and 4.3.2.1). In addition, the staff needs clarification on whether all the piping systems and components addressed in LRA Section 4.3.3 are evaluated in the EAF analysis in LRA Section 4.3.2.2.
The staff also audited the description of the fatigue TLAAs for the Class 1 piping systems and components in the FSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 4.3.2.2.
LRA TLAA Section 4.3.4, ASME Section III, Class 1 Fatigue Exemptions Summary of Information in the Application LRA Section 4.3.4, ASME Section III, Class 1 Fatigue Exemptions, discusses the fatigue exemption (waiver) TLAAs for the Class 1 components. The applicant dispositioned the fatigue exemption TLAAs in accordance with 10 CFR54.21(c)(1)(ii).
To verify that the applicant provided a basis to support its dispositions of the fatigue exemption TLAAs, the staff audited the TLAAs. 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 operating experience (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.
84 The table below lists documents that were reviewed by the staff and were found relevant to the fatigue exemption TLAAs for the Class 1 components. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document - Part 2 - TLAA Evaluation - Clinton LR Rev. 0 02/06/2024 SIA 1701003.302 Fatigue Exemptions (Waivers) for Clinton Class 1 Components Rev. 0 06/29/2022 During the audit of the TLAAs, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations. LRA Section 4.3.4 indicates that the fatigue exemption (waiver) analyses are based on the 60-projected cycles of the design transients described in LRA Table 4.3.1-1. Specifically, LRA Table 4.3.4-2 indicates that, with respect to the provision of ASME Code Section III, NB-3222.4(d)(1), the number of pressure cycles from atmospheric to operating conditions and back is based on 101 cycles of the startup transient and 44 cycles of the hydro test transient, which are total 145 cycles.
In contrast, LRA Table 4.3.4-2 indicates that the number of pressure cycles evaluated in the fatigue exemption analyses in relation to NB-3222.4(d)(1) is 144 cycles, which is slightly less than 145 cycles (i.e., 60-year projected cycles). Therefore, the staff needs clarification on whether the 145 pressure cycles do not affect the validity of the fatigue exemption analyses.
The staff also audited the description of the fatigue exemption TLAAs for the Class 1 components in the FSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 4.3.2.2.
LRA TLAA Section 4.3.5, ASME Section III, Class 2, Class 3, and ANSI B31.1 Allowable Stress Analyses and Related High-Energy Line Break (HELB) Selection Analyses Summary of Information in the Application LRA Section 4.3.4, ASME Section III, Class 2, Class 3, and ANSI B31.1 Allowable Stress Analyses and Related HELB Selection Analyses, discusses the allowable stress and HELB selection TLAAs for the non-Class 1 piping systems. The applicant dispositioned these TLAAs in accordance with 10 CFR54.21(c)(1)(i).
To verify that the applicant provided a basis to support its dispositions of the allowable stress and HELB selection TLAAs, the staff audited the TLAAs. 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 operating experience (OE) review, the applicant made a presentation on the process used to identify and
85 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 allowable stress and HELB selection TLAAs for the non-Class 1 piping systems. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-TLAABD Time-Limited Aging Analysis (TLAA)
Basis Document - Part 2 - TLAA Evaluation - Clinton LR Rev. 0 02/06/2024 N/A TLAA Pipe Segment Review N/A During the audit of the TLAAs, 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 TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations. LRA Table 4.3.5-2 describes the 60-year projected cycles for each non-Class 1 piping system to confirm that the 60-year projected cycles do not exceed 7000 cycles in the implicit fatigue analysis. However, LRA Section 4.3.5 does not clearly describe how the 60-year cycles were determined (e.g., based on piping system design information, plant operation procedures, test requirements, FSAR information and specific system-level knowledge).
The staff also audited the description of the allowable stress and HELB selection TLAAs for the non-Class 1 piping systems in the FSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 4.3.2.2.
LRA TLAA Section 4.3.6, High-Energy Line Break (HELB) Analyses Based On Cumulative Fatigue Usage Summary of Information in the Application LRA Section 4.3.6, High-Energy Line Break (HELB) Analyses Based On Cumulative Fatigue Usage, discusses the HELB TLAA based on the cumulative usage factor (CUF) for the Class 1 piping systems. The applicant dispositioned these TLAA in accordance with 10 CFR54.21(c)(1)(iii).
To verify that the applicant provided a basis to support its dispositions of the CUF-based HELB TLAA for the Class 1 piping systems, the staff audited the TLAAs. 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 operating experience (OE) review, the applicant made a presentation on the process used to identify and
86 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 CUF-based HELB TLAA for the Class 1 piping systems. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-TLAABD Time-Limited Aging Analysis (TLAA)
Basis Document - Part 2 - TLAA Evaluation - Clinton LR Rev. 0 02/06/2024 N/A HELB Breakdown N/A During the audit of the TLAAs, 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 CUF-based HELB TLAA for the Class 1 components in the FSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 4.3.2.2.
LRA TLAA Section 4.3.7, Reactor Vessel Internals Summary of Information in the Application LRA Section 4.3.7, Reactor Vessel Internals, discusses the fatigue TLAAs for the reactor vessel internal (RVI) components that support the reactor core.
The applicant dispositioned the fatigue TLAAs for the core plate stiffener to skirt weld and top guide/grid in accordance with 10 CFR54.21(c)(1)(i). The applicant dispositioned the fatigue exemption TLAAs for the control rod guide tubes, peripheral fuel support and orificed fuel support in accordance with 10 CFR54.21(c)(1)(ii). The applicant also dispositioned the fatigue TLAAs for the core shroud support structure and core shroud stabilizer assembly brackets in accordance with 10 CFR54.21(c)(1)(ii). In addition, the applicant dispositioned the fatigue TLAAs for the jet pump riser brace and core spray piping in accordance with 10 CFR54.21(c)(1)(iii).
To verify that the applicant provided a basis to support its dispositions of the TLAAs, the staff audited the TLAAs. 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 operating experience (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.
87 The table below lists documents that were reviewed by the staff and were found relevant to the TLAAs for the RVI components. The staff will document its review of this information in the SE.
Document Title Revision /
Date CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document - Part 2 - TLAA Evaluation - Clinton LR Rev. 0 02/06/2024 EPU-T0303-01 Extended Power Uprate: Task T0303, RPV Internals Structural Integrity Evaluation Core Support Structure Components (Proprietary)
Rev. 0 03/06/2002 EPU-T0303-02 Extended Power Uprate: Task T0303-02, RPV Internals Structural Integrity Evaluation Non-Core Support Structure Components (Proprietary)
Rev. 2 10/10/2018 GE 007N4023 Clinton PCR Item 2 Reactor Internals Transient Cycles Report (Proprietary)
Rev. 0 01/2023 SIA 1701003.302 Fatigue Exemptions (Waivers) for Clinton Class 1 Components Rev. 0 06/29/2022 GE-NE-26A-6217 Shroud and Shroud Support Structure (Proprietary)
Rev. 0 03/09/2005 During the audit of the TLAAs, the staff verified that the applicant has provided its basis that supports its TLAA disposition as follows: (1) disposition of 10 CFR54.21(c)(1)(i) for the core plate stiffener to skirt weld and top guide/grid; (2) disposition of 10 CFR54.21(c)(1)(ii) for the control rod guide tubes, peripheral fuel support and orificed fuel support (fatigue exemption analyses); (3) disposition of 10 CFR54.21(c)(1)(ii) for the core shroud support structure and core shroud stabilizer assembly brackets (fatigue analyses); and (4) disposition of 10 CFR54.21(c)(1)(iii) for the jet pump riser brace and core spray piping. However, the staff found that sufficient information was not available to complete its review of the applicants basis for TLAA dispositions. In order to obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations. The LRA explains that the 40-year CUF for the core shroud support plate, which is the limiting location for the core shroud support structure and core shroud stabilizer assembly, is 0.426. The LRA indicates that the CUF value is based on safety relief valve (SRV) actuation transient cycles, which are greater than 12000 cycles in the 40-yearfatigue analysis. The LRA also explains that the SRV actuation transient is the most significant contributor to fatigue in the core shroud support plate.
In contrast, the following reference indicates that the most significant contribution to the 40-year CUF is due to thermal cycles (i.e., contribution of 0.406 due to certain thermal cycles)
(
Reference:
GE-NE-26A-6217, Shroud and Shroud Support Structure, Section 6.2.5.2, Revision 0, March 9, 2005). The reference also indicates that the calculation of the CUF contribution (0.406) is based on the maximum usage factor in the shroud support plate for a similar standard BWR/6 plant.
The reference further explains that the 40-year CUF contribution of the SRV actuation cycles to the core shroud support plate is approximately 0.013 and the 40-year CUF contribution of other thermal transients is less than 0.01. However, the LRA does not clearly discuss whether the
88 transient cycles evaluated for the standard plant reasonably represent the 40-year transient cycles of the Clinton Power Station.
The staff also audited the description of the fatigue TLAAs for the RVI components in the FSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 4.3.2.2.
LRA TLAA Section 4.4, Environmental Qualification of Electric and Mechanical Equipment Summary of Information in the Application LRA Section 4.4, Environmental Qualification of Electric and Mechanical Equipment, discusses the thermal, radiation, and cyclical aging analyses for the plant electrical and mechanical components. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii).
Audit Activities An on-site audit was performed September 10 to September 12, 2024.
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 CL-TLAABD 4.4 Environmental Qualification of Electric and Mechanical Equipment Rev. 0 AR 04775740 LR: Enhance CPS EQ Program to Support 60 Year Ops Print date 09/12/2024 AR 04776265 LR: EQ Process Radiation Monitors Print date 09/12/2024 AR 02537305 10 CFR Part 21 NAMCO EA180 and EA170 limit Switches Print date 05/30/2024 AR 02541236 Part 21: NAMCO Limit Switch (EA170/EA180)
Print date 05/30/2024 AR 04431409 NOS ID: Develop work down curve for EQ Binder revisions Print date 05/30/2024 AR 04675921 EQ Program Document Issues Print date 05/30/2024 CC-AA-203 (Markup)
Environmental Qualification Program (Constellation Proprietary)
Rev. 17 NSED Procedure E.6 Environmental Qualification Packages (Constellation Proprietary)
Rev. 13 NSED-MEQPM-MS-02.00 Maintenance of Equipment Qualification Program Manual (Constellation Proprietary) 10/19/2018 EC 0000636711 RWCU Differential Flow modification 03/13/2024
89 Document Title Revision / Date CPS EQ Challenges (IR #: 4776265)
EQ-CL016 - Eberline SR Process Radiation Monitoring System 08/19/2024 EQ-CL003 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 14 EQ-CL011 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 22 EQ-CL037 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 08 EQ-CL068 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 11 EQ-CL093 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 16 EQ-CL015 Tab C Analysis, Calculation, or Justification to Support Qualification Rev. 03 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 LRA Environmental Qualification of Electric and Mechanical Equipment provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.6, Primary Containment Fatigue Analyses Summary of Information in the Application LRA Section 4.6.1 Containment Class MC Mechanical Penetrations, discusses the fatigue analyses for the Containment Class MC Mechanical Penetrations. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(i) for 119 of the existing 121 containment penetration fatigue evaluations and 10 CFR54.21(c)(1)(ii) for two of the existing 121 containment penetration fatigue evaluations.
LRA Sections 4.6.2 Containment Liner, 4.6.3 Suppression Pool Liner, 4.6.4 Containment and Drywell Equipment Hatch and Personnel Locks, and Dry well Head Fatigue Assessment, 4.6.5 Inclined Fuel Transfer Tube Bellows, 4.6.6 Refueling Bellows, 4.6.7 SRV X-Quenchers, 4.6.8 Containment/Drywell Penetration High Energy Guard Pipe Bellows, and 4.6.11 ECCS Suction Strainer Bellows, discusses the fatigue analyses for the containment liner, suppression pool liner, containment and drywell equipment hatch and personnel locks, and dry well head, inclined fuel transfer tube bellows, refueling bellows, SRV X-Quenchers, containment/drywell penetration high energy guard pipe bellows, and ECCS suction strainer bellows, respectively. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(i).
LRA Section 4.6.9 Containment Liner Corrosion Assessment, discusses the fatigue analysis for the Containment Liner Corrosion. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii).
90 LRA Section 4.6.10 Containment Electrical Penetration, discusses the fatigue analysis for the Containment Electrical Penetration. 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 TLAAs, the staff audited the TLAAs. 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 the applicant via the ePortal.
For the operating experience (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 Review of Mechanical Penetrations Assessment for 60 years Clinton Containment Mechanical Penetrations Breakdown 05/16/2023 Penetrations Breakdown Clinton Containment Mechanical Penetrations Breakdown 05/13/2023 CQD-4536-1PC0065 Penetration Stress Analysis Report - Primary Containment Penetration 1PC0065 Rev. 2 CQD-4536-1PC0064 Penetration Stress Analysis Report - Primary Containment Penetration 1PC0064 Rev. 5 CQD-4536-1PC0017 Penetration Stress Analysis Report - Primary Containment Penetration 1PC0017 Rev. 2 04/20/1990 CQD-4536-1AB0111 Penetration Stress Analysis Report - Primary Containment Penetration 1AB0111 Rev. 2 SDQ12-42DG07 Containment/Reactor Building Containment Liner Special Problems Rev. 0 03/11/1991
91 Document Title Revision / Date 22A7000 238 Nuclear Island GESSAR II Rev. 1 SD-Q12-42DG02 Containment/Reactor Building Containment Liner Floor Liner Design Rev. 3 06/08/1998 EC-0000638891 Clinton Containment/Drywell Equipment Hatch, Personnel Locks, and head Fatigue Assessment Rev. 0 06/01/2023 SQ-CL502 Containment Bellows for The Inclined Transport System Rev. 1 02/06/1985 K-2893 Technical Specification for Refueling Bellows Rev. 6 09/20/1982 21A2139 Design Specification for Quencher, X-Type, Pedestal Mounted 06/01/1978 Letter Dated Oct 31, 1984 (Docket No.
50-461)
Potential Deficiency 55-83-08 10CFR50.55(e)
Damage to Guard Pipe Bellows Assemblies 10/31/1984 SDQ12-42DG11 Containment Liner - Corrosion of Liner Rev. 0 12/03/1992 2201232.401.R0 Clinton Containment Liner Corrosion Rate Assessment Rev. 0 08/09/2023 2201232.301.R0 Clinton Containment Liner Corrosion Allowance and Margin Assessment Rev. 0 08/10/2023 CL-LR-SIA-005 Clinton Containment Humidity at Elevation 735 foot Rev. 1 SQ-CL373 Medium Voltage Electrical Penetration Rev. 1 06/14/1985 SQ-CL433 Airlock Penetration for Lighting and Telephone Service Rev. 4 06/13/1985 SQ-CL375 Low Voltage Power Electric Penetrations Rev. 0 06/13/1985 SQ-CL372 Low Voltage Control and Instrumentation Penetrations Rev. 3 06/12/1990 K-2888B Technical Specification for ECCS Suction Strainer Rev. 1 03/23/1998 During the audit of the TLAA, the staff verified that the applicant has provided its basis to support its dispositioning of 10 CFR 54.21(c)(1)(i), (ii) and (iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs or use a voluntary LRA supplement offered by the applicant during the audit.
During the audit, the staff made the following observations:
92 The staff reviewed Review of Mechanical Penetrations Assessment for 60 years, and noted that the LRA conservatively assumed that the RWCU heat exchangers are swapped 10 times per year for 60 years, resulting in 600 occurrences, which is significantly larger than the original assumption of 20 RWCU heat exchanger swaps over the initial 40 years as assumed in CQD-4536-1PC0064. The staff further noted that the LRA conservatively assumed that the backwash transient occurs 10 times per day for 60 years, resulting in 10,950 occurrences, which is significantly larger than the original assumption of 2,450 occurrences over the initial 40 years (once every 6 days) as assumed in CQD-4536-1PC0065.
The staff reviewed Calculations CQD-4536-1PC0017 and CQD-4536-1AB0111 and noted that the contribution of the Hydro Test transient and the Misc. Head Spray transient to the overall Cumulative Usage Factor (CUF) is negligible.
The staff reviewed Calculation CQD-4536-1PC0064 and noted that this calculation determined a CUF of 0.5901 (PDF page 36) assuming 1) 123 boltup transients (70 to 437), 2) 10,000 normal operation transients (SS at 437), 3) 20 RT heat exchanger swap transients (437, 260, 525, 475, 380, 430), 4) 500 filter demin off/on transients (435 to 480), and 5) 130 unbolt transients (480 to 70) - PDF 75.
The staff reviewed Calculation CQD-4536-1PC0065 and noted that this calculation determined a CUF value of 0.01245 (PDF 34) assuming 1) 10,000 pump standby transients at 65F (SS), 2) 2450 backwash transients from 65F to 120F and back to 65F.
The assumption of 2450 transients in 40 years results in a backwash transient approximately every 6 days.
The staff reviewed Calculation SDQ12-42DG07 and noted that the containment liner and associated welds were qualified for 1948 SRV actuations over 40 years.
The staff reviewed Calculation 22A7000 and noted that the suppression liner was qualified for 1800 SRV actuations over 40 years. The staff also reviewed SD-Q12-42DG02 and noted that the design analysis evaluated fatigue for the suppression pool floor liner by addressing the six criteria in NE-3222.4(d) assuming 1,000 SRV actuations during the 40-year life of the plant.
The staff reviewed EC-0000638891 and noted that Constellation evaluated containment and drywell equipment hatch and personnel locks, and drywell head for 2500 occurrences in which the component experiences a temperature and pressure increase from ambient to operating temperature and pressure per the six criteria in NE-3222.4(d) and demonstrated that these five components were exempted from a more detailed fatigue evaluation in accordance with NE-3222.4(e).
The staff reviewed Page 64 of SQ-CL502 and noted that the projected thermal cycles for 40 years of operation for the three design conditions (normal operation, upset conditions, and faulted conditions) of the inclined fuel transfer tube bellows stated in the LRA Section 4.6.5 were 150, 30, and 1, respectively. The staff further noted that the design temperature and pressure of 185 °F and 20 psig were used for the three design conditions.
93 The staff reviewed Page 31 of Technical Specification K-2893 and noted that refueling bellows were qualified for a minimum of 360 occurrences of axial compression corresponding to the thermal expansion of the RPV during normal operational startups and shutdowns, three cycles of axial compression corresponding to the thermal expansion of the RPV during accident conditions and a minimum of 30 OBE and 30 SSE seismic cycles of horizontal and vertical movement.
The staff reviewed Page 10 of 21A2139 and noted that the SRV X-Quenchers were qualified for 11,600 SRV actuations, five OBEs, and one SSE over 40 years.
The staff reviewed Page 3 of Letter Dated Oct 31, 1984 (Docket No. 50-461), Potential Deficiency 55-83-08 10CFR50.55(e) Damage to Guard Pipe Bellows Assemblies, and noted that the prototype assembly was tested by imposing greater than 10,000 cycles of calculated movement.
The staff reviewed Sheet 8 of SDQ12-42DG11and noted that Constellation performed a conservative analysis to estimate the amount of corrosion on the uncoated liner surfaces under the test channel and concluded that the estimated conservative material loss over 40 years was less than the acceptance criteria. Based on its review of 2201232.301.R0, the staff verified that the total material loss estimate of 3.5 mils for carbon steel surfaces for 60 years of exposure is significantly less than the acceptance criteria of 125 mils of local thinning under the test channels. In addition, based on its review of 2201232.401.R0 and CL-LR-SIA-005, the staff verified the screening basis for galvanic corrosion for areas where carbon steel liner plates are attached to stainless steel liner plates, based on the availability of containment ventilation system maintaining containment environment temperatures above the dew point and no OE incidents of corrosion.
The staff reviewed Section 5.6 of SQ-CL372, SQ-CL375 and SQ-CL433 and Section 7.10 of SQ-CL373 and verified that electrical penetrations were qualified for 120 startups and shutdowns in which penetration temperature was increased from ambient to 150 °F.
The staff reviewed Appendix E, Page 1 of 3, of K-2888B, Revision 1 and verified that ECCS suction strainer bellows were qualified for a minimum of 12,600 occurrences of axial and lateral movements that encompassed thermal, seismic, SRV and LOCA.
The staff also audited the descriptions of the LRA TLAAs for Primary Containment Fatigue Analyses provided in the FSAR supplement in LRA Section A.4.6. The staff found that sufficient information was not available to determine whether the descriptions provided in the USAR supplement were adequate descriptions of the LRA TLAAs Primary Containment Fatigue Analyses. The staff will consider issuing RAIs or use a voluntary supplement offered by the applicant during the audit in order to obtain the information necessary to verify the sufficiency of the FSAR supplement program descriptions.
LRA TLAA Section 4.7.1, CPS Crane Cyclic Loading Analyses TLAA Summary of Information in the Application The LRA Section 4.7.1, CPS Crane Cyclic Loading Analyses TLAA discusses the analyses for the Containment Polar Crane and Fuel Building Crane. The applicant dispositioned the TLAAs in accordance with 10 CFR54.21(c)(1)(i).
94 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 operating experience (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 CL-TLAABD TLAA Basis Document: Part 2 - TLAA Evaluation -
Clinton LR Rev. 0 FSAR CPS Final Safety Analysis Report Rev. 23 MA-AA-716-021 Rigging and Lifting Program (Constellation Proprietary)
Rev. 36 MA-AA-716-022 Control of Heavy Loads Program (Constellation Proprietary)
Rev. 15 AR 02436853 1HC02G: 1 loose bolt found during crane inspection 01/13/2015 AR 04282958 Minor discrepancies during refuel bridge (F15) walkdown 09/27/2019 ECR 417375 WO 1710259-01 inspection 1 loose bolt was found 01/14/2015 AR 03987841 Investigate leak from crane 03/21/2017 AR 04209989 N and S TB overhead cranes safety mitigation 01/11/2019 AR 02436853 1HC02G: 1 loose bold found during crane inspection -
bolt is located on the west site. G-104 on the crane rail upper 01/13/2015 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.2,1.14, CPS Crane Cyclic Loading Analyses TLAA. The staff verified this description is consistent with the description provided in the SRP for TLAAs.
LRA TLAA Section 4.7.2, Main Steam Line Flow Restrictor Erosion Analysis Summary of Information in the Application LRA Section 4.7.2, Main Steam Line Flow Restrictor Erosion Analysis, discusses the analysis of the main steam line flow restrictors during a main steam line break outside of primary containment. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(i).
95 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 CL-TLAABD TLAA Basis Document - Section 4.7.2 Main Steam Line Flow Restrictors Erosion Analysis Rev. 0 NUREG-0800 Standard Review Plan - Section 15.6.4 Radiological Consequences of Main Steam Line Failure Outside Containment (BWR)
Rev. 2 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 Main Steam Line Flow Restrictors Erosion Analysis provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.7.3, Generic Letter 81-11 Crack Growth Analysis to Demonstrate Conformance to the Intent of NUREG-0619 Summary of Information in the Application LRA Section 4.7.3, Generic Letter 81-11 Crack Growth Analysis to Demonstrate Conformance to the Intent Of NUREG-0619, discusses the analysis related to crack growth for the feedwater nozzles of the RPV. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(i).
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 CL-TLAABD Clinton Power Station License Renewal Project -
TLAA Basis Document - Part 2 - TLAA Evaluation (Section 4.7 - Other Plant-Specific Time-Limited Aging Analyses)
Rev. 0 CL-TLAABD Clinton Power Station License Renewal Project -
TLAA Basis Document - Part 2 - TLAA Evaluation (Section 4.3 - Metal Fatigue Analyses)
Rev. 0 IP-M-0715 Post Power Uprate Feedwater Nozzle Fracture Mechanics Analysis to show compliance with NUREG-0619 - (DRF 000-0003-7901 May 2002)
Rev.0
96 Document Title Revision / Date FP-CPS-314 Cycle, Fatigue, and Environmentally Assisted Fatigue (EAF) Projections for 60 Years Rev. 1 ER-AA-470 Fatigue and Transient Monitoring Program (Constellation Proprietary)
Rev. 10 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).
During the audit, the staff made the following observations:
The staff confirmed that the applicant reassessed the plant-specific fracture mechanics analysis to account for uprated plant conditions to demonstrate continued compliance with NUREG-0619 and Generic Letter 81-11 (i.e., IP-M-0715);
The staff confirmed that this plant-specific fracture mechanics analysis, incorporating the uprated conditions at CPS, assumed a specified number of startup, shutdown and scram occurrences intended to bound original 40-year operating period; The staff confirmed that the 60-year cycle projections were based on historical plant-specific operating characteristics and anticipated future operation (i.e., FP-CPS-314);
The staff confirmed that the assumed number of transient occurrences in this plant-specific fracture mechanics analysis were considerably greater than the 60-year projections presented in LRA 4.3.1-1 for the same design transients.
The staff also audited the description of the TLAA provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.7.4, Reactor Shield Wall Fluence Summary of Information in the Application LRA Section 4.7.4, Reactor Shield Wall Fluence, discusses the fluence evaluation for the reactor shield wall. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(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.
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 GEH Report No.
007N1817 Proprietary Constellation Energy GroupClinton Power Station, License Renewal Application, Task T0313 RPV Flux Evaluation Rev. 0 10/2022
97 Sargent & Lundy Drawing No. MO1-1112 General Arrangement, Fuel Bldg. & Containment Section G-G - Clinton Power Station, Unit 1 Rev. D EPRI Report 1015078 Proprietary Plant Support Engineering: Aging Effects for Structures and Structural Components (Structural Tools) 12/2007 Responses to breakout questions Item #4 (TRP-116.4) and Item #18 (TRP-116.4)
N/A CPS-FLU-001-R-003r0_RVE Clinton Power Station Reactor Vessel Externals Radiation Evaluation with Projections to 52 EFPY -
2024 (Constellation Proprietary)
Rev. 0 03/2024 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).
During the audit, the staff made the following observations:
Proprietary GEH Report No. 007N1817 states the 60-year projected neutron fluence value for the reactor shield wall inner surface to be below a certain value.
Sargent & Lundy Drawing No. MO1-1112 shows no lateral connections between the Clinton Unit 1 RPV and the reactor shield wall.
The response to the breakout question in Item #4 (TRP-116.4) states that the 1973 revision to Section 3.8.3.6 of the FSAR documented a different threshold of 10E19 nvt and that this threshold was revised to 10E22 nvt in FSAR Amendment 37. During the audit discussion regarding the response, the applicant committed to providing a supplement to revise the embrittlement threshold.
CPS-FLU-001-R-003r0_RVE documented the methodology used to calculate the neutron fluence and gamma dose to the reactor shield wall including the steel liner and confirms the conclusions related to neutron fluence in GEH Report No. 007N1817.
The staff also audited the description of the LRA Section A.4.7.4, Reactor Shield Wall Fluence provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.7.5, Hydraulic Control Units Summary of Information in the Application LRA Section 4.7.5, Hydraulic Control Units, discusses the fatigue TLAA for the hydraulic control units. 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.
98 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 experience (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 the hydraulic control units. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document
- Part 2 - TLAA Evaluation - Clinton LR Rev. 0 2/6/2024 GE 22A4168 Hydraulic Control Unit (Proprietary)
Rev. 2 12/13/1978 GE 22A4309 Riser Assemblies (Proprietary)
Rev. 0 4/26/1976 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 TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.
During the audit, the staff made the following observations. FSAR Section 3.9.1.1.3 indicates that the following design cycles related to scrams were evaluated in the existing fatigue analysis for the HCUs: (1) 140 cycles of the scram test transient; (2) 160 cycles of startup scram transient; and (3) 300 cycles of operational scram transient. However, LRA Section 4.7.5 does not clearly describe the 60-year projected cycles for these scram transients compared to the transient cycles evaluated in the existing fatigue analysis.
The staff also audited the description of the fatigue TLAA for the hydraulic control units in the FSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 4.3.2.2.
LRA TLAA Section 4.7.6, Fuel Pool Storage Rack Fatigue Analysis Summary of Information in the Application LRA Section 4.7.6, Fuel Pool Storage Rack Fatigue Analysis, discusses the analysis for the new fuel storage racks installed in the mid 2000s for the spent fuel pool. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(i).
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 keywords. An on-site audit was performed from September 10, 2024, to September 12, 2024.
99 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 CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document
- Part 2 - TLAA Evaluation - Clinton LR Rev. 0 FSAR Clinton Power Station Final Safety Analysis Report Rev. 23 0000349325 Spent Fuel Storage Capacity Expansion, Phase 1 -
Cask Storage Pool Rev. 002 01FC34 Rack Fatigue Analysis for Clinton Spent Fuel Racks -
Holtec Calculation HI-2033100 (Proprietary)
Rev. 001 HI-2033124 Spent Fuel Storage Expansion at Clinton Power Station - Holtec International Report No. HI-2033124 (Proprietary)
Rev. 2 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 TLAA Fuel Pool Storage Rack Fatigue Analysis provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.7.7, Refueling Bulkhead Ring Flaw Evaluation Summary of Information in the Application LRA Section 4.7.7, Refueling Bulkhead Ring Flaw Evaluation, discusses the analysis for the crack indications in the weldments of the refueling bulkhead ring plates. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(i).
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 keywords. An on-site audit was performed from September 10, 2024, to September 12, 2024.
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 CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document
- Part 2 - TLAA Evaluation - Clinton LR Rev. 0 NRC Docket No.
STN 50-461 Clinton Power Station Updated Safety Analysis Report Rev. 23 CQD-005346 Structural Integrity of Refueling Bellows Ring Against Crack Propagation in Weldment Flaws Rev. 0 CQD-002857 Fracture Mechanics Evaluation of Crack Propagation in Weldment Flaws in Refueling Bellows (RPV) Ring Rev. 0
100 Document Title Revision / Date PC-01 and PC-02 System Big Notes - Primary Containment Rev. 1 4402.01 Emergency Operating Procedure-6 Primary Containment Control (Constellation Proprietary)
Rev. 31 5068.03 Alarm Panel 5068 Annunciators - Row 3 (Constellation Proprietary)
Rev. 26a DC-ME-09-CP Equipment Environmental Design Conditions Design Criteria Rev. 13 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 TLAA Refueling Bulkhead Ring Flaw Evaluation provided in the FSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
LRA TLAA Section 4.7.8, Fuel Pool Cleanup System, Flow Control Valves Summary of Information in the Application LRA Section 4.7.8, Fuel Pool Cleanup System, Flow Control Valves, discusses the fatigue TLAA for the flow control valves of the fuel pool cleanup system. 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 operating experience (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 the flow control valves of the fuel pool cleanup system. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-TLAABD Time-Limited Aging Analysis (TLAA) Basis Document
- Part 2 - TLAA Evaluation - Clinton LR Rev. 0 02/06/2024 Calculation CQD-025544 Fatigue Analysis of Valve Nos. 1FC004A, B Rev. 0 11/18/1985 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 TLAA disposition. In order to obtain the necessary information, the staff will consider issuing RAIs.
101 During the audit, the staff made the following observations. LRA Section 4.7.8 indicates that the fatigue analysis for the flow control valves assumed the transient cycles (occurrences) as follows: (1) 87600 cycles of operational loads; (2) 14790 cycles of SRV lifts; (3) 5 cycles of operational basis earthquake (OBE); and (4) one cycles of safe shutdown earthquake (SSE).
However, the following reference indicates that 76990 cycles of operational loads were evaluated in the fatigue analysis for these valves (
Reference:
Calculation CQD-025544, Fatigue Analysis of Valve Nos. 1FC004A, B, Revision 0, November 18, 1985, PDF file page 39 of 42).
Given the apparent inconsistency of the operational loading cycles between the LRA section and the reference document (i.e., 87600 and 76990 cycles), the staff needs clarification on the cycles of operational loading evaluated in the fatigue analysis for the flow control valves. In addition, LRA Section 4.7.8 indicates that LRA Table 4.3.1-1 documents 60-year cycle projections for SRV lift, OBE, and SSE transients. However, the LRA section does not clearly describe which specific transients in LRA Table 4.3.1-1 correspond to the SRV lift transient evaluated in LRA Section 4.7.8.
The staff also audited the description of the fatigue TLAA for the flow control valves in the FSAR supplement. The staff verified that this description is consistent with the acceptance criteria provided in SRP-LR (Revision 2) Section 4.3.2.2.
AMR Items Not Associated with an AMP 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 Electrical Components, Item Number 3.6.1 High-voltage insulators composed of porcelain; malleable iron; aluminum; galvanized steel; cement exposed to air -
outdoor LRA Table 3.6,1, Item Number 3.6.1 High-voltage insulators composed of porcelain; malleable iron; aluminum; galvanized steel; cement exposed to air -
outdoor Audit Activities An on-site audit was performed September 10, 2024, to September 12, 2024.
The table below lists documents that were reviewed by the staff and were found relevant to the 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. The staff will document its review of this information in the SE.
102 Document Title Revision / Date CL-AMRBD-MEAE Materials, Environments, and Aging Effects Aging Management Review Basis Document Rev. 2 ER-AA-700-1003 Use of Operating Experience for License renewal Implementation / Aging Management (Constellation Proprietary)
Rev. 006 WO 01775588 Need Work Order Created for SY DISC 4507 Ohio Brass Replmnt 02/09/20215 WO 01824127 EIN: 0SY4504 Degraded Ohio Brass Insulators on Disconnect 04/29/2015 AR 02386323 Track Ohio Brass Insulators in 345 KV Switchyard 05/24/2017 AR 02390377 Need Work Order created for SY DISC 4509 Ohio Brass Replmnt 10/08/2014 AR 02468347 Degraded manual disconnect 4505 insulator 04/03/2015 AR 02484441 EIN: 0SYS4504 Degraded Ohio Grass Insulators on Disconnect 04/27/2015 The staff made the following observation during walkdowns:
During the on-site audit, the staff performed a walkdown of the SBO offsite power recovery path from the switchyard to the plant auxiliary transformers. The staff did not observe any adverse or abnormal signs of age-related degradation with in-scope high-voltage insulators.
LRA AMR Evaluation 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 AMRs discussed in LRA Sections 3.6.2.2.3 and the following:
LRA Table 3.6.1, Summary of Aging Management Evaluations for Electrical Components, Item Number 3.6.1 Transmission conductors composed of aluminum; steel exposed to air - outdoor LRA Table 3.6,1, Item Number 3.6.1 Transmission connectors composed of aluminum; steel exposed to air - outdoor LRA Table 3.6,1, Item Number 3.6.1 Switchyard bus and connections composed of aluminum; copper; bronze; stainless steel; galvanized steel exposed to air - outdoor
103 LRA Table 3.6,1, Item Number 3.6.1 Transmission conductors composed of aluminum; steel exposed to air - outdoor Audit Activities An on-site audit was performed September 10, 2024, to September 12, 2024.
The table below lists documents that were reviewed by the staff and were found relevant to the LRA AMR Evaluation 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. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-AMRBD-MEAE Materials, Environments, and Aging Effects Aging Management Review Basis Document Rev.2 ER-AA-700-1003 Use of Operating Experience for License renewal Implementation / Aging Management (Constellation Proprietary)
Rev.006 The staff made the following observation during walkdowns:
During the on-site audit, the staff performed a walkdown of the SBO offsite power recovery path from the switchyard to the plant auxiliary transformers. The staff did not observe any signs of adverse or abnormal age-related degradation with in-scope Switchyard Bus and Connections, Transmission Conductors, and Transmission Connectors.
LRA Section 3.6.2.3.1 - Fuse Holders Summary of Information in the Application During the audit, the staff reviewed plant documentation associated with the following:
LRA Table 3.6.1, Summary of Aging Management Evaluations for the Electrical Components, Item 3.6.1-016 notes that fuse holders (not part of active equipment):
metallic clamps composed of Various metals used for electrical connections exposed to air - indoor, uncontrolled have an aging effect/mechanism of increased resistance of connection due to chemical contamination, corrosion, and oxidation (in an air, indoor controlled environment, increased resistance of connection due to chemical contamination, corrosion, and oxidation do not apply); fatigue due to ohmic heating, thermal cycling, electrical transients; however, these aging effects are not applicable to CPS.
LRA Table 3.6.1, Item 3.6.1-017 notes that fuse holders (not part of active equipment):
metallic clamps composed of various metals used for electrical connections exposed to air - indoor, controlled or uncontrolled have an aging effect/mechanism of increased resistance of connection due to fatigue caused by frequent manipulation or vibration;
104 however, these aging effects are not applicable to CPS.
LRA Table 3.6.1, Item 3.6.1-021 notes that fuse holders (not part of active equipment):
insulation material, metal enclosed bus: external surface of enclosure assemblies composed of insulation material: bakelite; phenolic melamine or ceramic; molded polycarbonate; other, galvanized steel; aluminum, steel exposed to air - indoor, controlled or uncontrolled have no aging effect/mechanism at CPS; and therefore, no Aging Management Program is proposed.
Audit Activities An on-site audit was performed September 10 to September 12, 2024.
The table below lists documents that were reviewed by the staff and were found relevant to the applicants aging management evaluation of fuse holders. The staff will document its review of this information in the SE.
Document Title Revision / Date CL-AMRBD-MEAE Materials, Environments, and Aging Effects Aging Management Review Basis Document Rev. 2 Electrical Components Grouping On-site Power System System and Structure Scoping Report Rev. 0 Electrical Components Grouping Plant Lightning System System and Structure Scoping Report Rev. 0 Electrical Components Grouping Plant Computer System System and Structure Scoping Report Rev. 0 Electrical Components Grouping Miscellaneous Electrical System System and Structure Scoping Report Rev. 0 Picture of 1E22-S301 External Fuse JBox 1E22-S301 External Print date 09/12/2024 Picture of 1E22-S301 Internal Fuse JBox 1E22-S301 Internal Print date 09/12/2024 During the audit, the staff made the following observation:
Section 3.6.2.3.1 of the LRA noted that XI.E5, Fuse Holders, is not applicable to CPS.
The LRA also noted that fuse holders (metallic clamps) do not meet the screening criteria of NUREG-1801, Chapter XI.E5, because the metallic clamps are not subject to adverse environmental conditions that could cause an increase in electrical resistance of connection, fatigue from ohmic heating, thermal cycling, or electrical transients, or fatigue from frequent fuse removal/manipulation or vibration. As such, the applicant indicated that fuse holders (metallic clamps) are not subject to AMR. Insulating portions
105 of fuse holders are evaluated with insulation material for electrical cables and connections.
The staff made the following observationduring walkdowns:
During the on-site audit, the staff performed a walkdown of the plant and observed fuse holders within scope of LR. No signs of moisture intrusion, chemical contamination, oxidation, or corrosion were observed during the walkdown.
LRA Sections 3.2.2.2.3.2, 3.2.2.2.6, 3.3.2.2.3, 3.3.2.2.5, 3.4.2.2.2, and 3.4.2.2.3 - Stainless Steel Summary of Information in the Application The LRA addresses FE of cracking due to stress corrosion cracking, and loss of material due to pitting or crevice corrosion, of stainless steel in the Engineered Safety Features, Auxiliary, and Steam and Power Conversion Systems. The LRA sections for these FE discussions are:
3.2.2.2.3.2, 3.2.2.2.6, 3.3.2.2.3, 3.3.2.2.5, 3.4.2.2.2, and 3.4.2.2.3.
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 experience (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 staff audited this topic to determine if the information in the LRA is consistent with the FE information in the SRP-LR Report.
The staff will document its review of this information in the SE.
3.
Supplements to the LRA By letters dated November 27, 2024 (ML24332A050), December 20, 2024 (ML24355A050), and January 30, 2025 (ML25030A182), CPS voluntarily submitted Supplements 1, 2 and 3 to the LRA resulting from discussions held during the audit.
4.
Audit Questions Provided to CPS Over the course of the audit, the NRC staff provided audit questions to CPS to facilitate the audit discussions (ML25050A270 and ML25050A269), for the non-proprietary and proprietary versions, respectively.
Subject Area Meeting Date Breakout Session: ASME Section III, Class 1 Fatigue Exemptions 9/25/2024 Breakout Session: ASME Section III, Class 2, Class 3, and ANSI B31.1 Allowable Stress Analyses 9/25/2024 Breakout Session: Plant-Specific TLAA - Hydraulic Control Units 9/25/2024 Breakout Session: Plant-Specific TLAA - Fuel Pool Cleanup System, Flow Control Valves 9/25/2024
106 Subject Area Meeting Date Breakout Session: Internal Coatings 9/26/2024 Breakout Session: Selective Leaching 9/30/2024 10/1/2024 10/9/2024 10/18/2024 10/28/2024 Breakout Session: Buried and Underground Piping and Tanks 9/30/2024 10/9/2024 12/6/2024 Breakout Session: Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements 10/1/2024 Breakout Session: Water Chemistry 10/3/2024 Breakout Session: Fire Protection 10/7/2024 Breakout Session: Monitoring of Neutron-Absorbing Materials Other Than Boraflex 10/7/2024 10/10/2024 10/21/2024 Breakout Session: BWR Stress Corrosion Cracking 10/9/2024 Breakout Session: Structures Monitoring Program 10/10/2024 10/24/2024 Breakout Session: Plant-Specific TLAA - Reactor Shield Wall Fluence 10/10/2024 Breakout Session: RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants 10/11/2024 10/16/2024 Breakout Session: Concrete 10/11/2024 10/16/2024 Breakout Session: Inaccessible Areas 10/11/2024 10/16/2024 1/8/2024 Breakout Session: Settlement 10/11/2024 10/16/2024 Breakout Session: Transient Cycle and Cumulative Usage Projections for 60 Years 10/15/2024 Breakout Session: ASME Section III, Class I and Environmentally Assisted Fatigue Analyses 10/15/2024 Breakout Session: ASME Section III, Class 1 Components 10/15/2024 Breakout Session: Reactor Vessel Internals 10/15/2024 10/17/2024 Breakout Session: Closed Treated Water System 10/17/2024 Breakout Session: Containment Liner Plate, Metal Containments, and Penetrations Fatigue Analysis 10/18/2024 Breakout Session: Fire Water System 10/22/2024 10/28/2024 12/9/2024 12/13/2024 Breakout Session: Bolting Integrity 10/23/2024 Breakout Session: Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 10/23/2024 Breakout Session: Plant-Specific TLAA - Clinton Power Station Crane Cyclic Loading Analysis 10/23/2024
107 Subject Area Meeting Date Breakout Session: Flow-Accelerated Corrosion 10/23/2024 12/13/2024 1/28/2025 Breakout Session: ASME Section XI, Subsection IWF 10/24/2024 Breakout Session: Lubrite 10/24/2024 Breakout Session: Reactor Pressure Vessel Adjusted Reference Temperature 10/31/2024 Breakout Session: Reactor Pressure Vessel Upper-Shelf Energy Analyses 10/31/2024 Breakout Session: Copper Alloy 11/14/2024 Breakout Session: Closed Treated Water 1/28/2025 5.
Applicant Personnel Contacted During Audit Name Affiliation Adam Andriano Constellation Alexander Psaros Constellation Bashar Jabri Constellation Behrooz Khorsandi Constellation Blake Torres Constellation Brandon De Graaf Constellation Casey Muggleston Constellation Christopher Pragman Constellation Evan Apke Constellation Francis McGuire Constellation Iba Ello Fletcher Constellation Jake Levea Constellation James Annett Constellation Jennifer Lytle Constellation Joseph Vacante Constellation Joshua Sarrafian Constellation Joy Rexshell Constellation Kelsi Eiane Constellation Kenneth Leffel Constellation Ketan Patel Constellation Kieren Kearns Constellation Kurt Lindeman Constellation Lydia Dworakowski Constellation Michael Smith Constellation Nicholas Lynch Constellation Patrick Lewis Constellation Peter Tamburro Constellation Peter Weidinger Constellation Sarah Clark Constellation Sarah Swienton Constellation
108 Sarika Malani Constellation Scott Kauffman Constellation Sharida Ullah Constellation Tyler Ziegler Constellation William Ford Constellation Zachary Schwartz Constellation Mark Miller Enercon Jeff Hren GE Verona Name Affiliation Mehrdad Zoroufi GE Verona Shawn Kliensmith GE Verona Yil Kim GE Verona Dan Denis Structural Integrity 6.
Exit Meeting An exit meeting was held with the applicant on February 11, 2025, 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.