ML25262A143
| ML25262A143 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/14/2025 |
| From: | Alexandra Siwy NRC/NRR/DNRL/NLRP |
| To: | Basta L Duke Energy Progress |
| References | |
| EPID L-2025-SLR-0000 | |
| Download: ML25262A143 (1) | |
Text
Laura Basta Site Vice President H.B. Robinson Steam Electric Plant Duke Energy Progress, LLC 3581 West Entrance Road, RNPA11 Hartsville, SC 29550
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2025-SLR-0000)
Dear Laura Basta:
By letter dated April 1, 2025 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. [ML25091A290]), Duke Energy Progress, LLC (Duke) submitted an application for subsequent license renewal of Renewed Facility Operating License No. DPR-23 for H.B. Robinson Steam Electric Plant (Robinson), Unit 2 to the U.S. Nuclear Regulatory Commission (NRC, staff). Duke submitted the application pursuant to Title 10 of the Code of Federal Regulations Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, for subsequent license renewal.
The NRC staff completed its aging management audit from April 28, 2025 - August 22, 2025, in accordance with the audit plan (ML25113A162). The audit report is enclosed. If you have any questions, please contact me by email at Andrew.Siwy@nrc.gov.
Sincerely, Andrew Siwy, Senior Project Manager License Renewal Projects Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket No: 50-261
Enclosure:
Audit Report November 14, 2025 Signed by Siwy, Andrew on 11/14/25
C. Wilson 2
SUBJECT:
H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 - REPORT FOR THE AGING MANAGEMENT AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2025-SLR-0000)
DATED: November 14, 2025 DISTRIBUTION:
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PUBLIC ListServ RidsNrrDnlr Resource RidsACRS_MailCTR Resource RidsRgn2MailCenter Resource RidsNrrOd Resource RidsNrrPMRobinson Resource ASiwy, NRR/DNRL MYoo, NRR/DNRL LBauer, NRR/DNRL SKoenick, NMSS/REFS KLoomis, NMSS/REFS MSampson, NRR/DNRL RPenmetsa, NRR/DNRL DWrona, NRR/DORL NJordan, NRR/DORL SBurnell, HQ/OPA CWolf, OCA LMcKown RII/DORS MFannon, RII/DORS JZeiler, RII/DORS CDorman, RII/DORS JPelchat, RII/RGLO KHenry, RII/ RGLO DGasperson RII/PAO EMAIL:
Mark.Pyne@duke-energy.com Daniel.Roberts2@duke-energy.com Elizabeth.Glenn@duke-energy.com ADAMS Accession No; ML25262A143 via e-concurrence NRR-106 OFFICE LA:NRLP:DNRL BC:SNSB:DSS BC:NCSG:DNRL NAME EDavidson NDifrancesco SBloom DATE 8/6/25 8/15/25 8/26/25 OFFICE BC:ELTB:DEX BC:NPHP:DNRL BC:NVIB:DNRL NAME JPaige MMitchell ABuford DATE 8/28/25 9/3/25 9/2/25 OFFICE BC:ESEB:DEX BC:NRLP:DNRL PM:NRLP:DNRL NAME ITseng LBauer ASiwy DATE 9/11/25 10/01/2025 11/14/25
Enclosure Aging Management Audit Report H.B. ROBINSON STEAM ELECTRIC PLANT, Unit 2 Subsequent License Renewal Application April 28, 2025 - August 22, 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:
50-261 License No:
DPR-23 Licensee:
Duke Energy Progress, LLC (Duke)
Facility:
H.B. Robinson Steam Electric Plant (Robinson), Unit 2 Location:
Hartsville, SC Dates:
April 28, 2025 - August 22, 2025 Approved By:
Laurel Bauer, Acting Chief License Renewal Projects Branch Division of New and Renewed Licenses 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 Nicholas Difrancesco, Chief Nuclear Systems Performance Branch Division of Safety Systems Matthew A. Mitchell, Chief Piping and Head Penetrations Branch Division of New and Renewed Licenses Jason Paige, Chief Long Term Operations and Modernization Branch Division of Engineering and External Hazards Ian Tseng, Chief Structural, Civil, Geotech Engineering Branch B Division of Engineering and External Hazards
iii NRC Staff Reviewers:
Name Organization Jennifer Beaton PRA Licensing B (APLB)/Division of Risk Assessment (DRA)
Naeem Iqbal APLB/DRA Adakou Foli Long Term Operations & Modernization (ELTB)/Division of Engineering and External Hazards (DEX)
Brian Correll ELTB/DEX Jorge Cintron-Rivera ELTB/DEX Kenn Miller ELTB/DEX Landen Kwan ELTB/DEX Liliana Ramadan ELTB/DEX Matt McConnell ELTB/DEX Aaron Gallman Structural, Civil, Geotech Engineering (ESEB)/DEX Andrew Prinaris ESEB/DEX Dan Hoang ESEB/DEX George Wang ESEB/DEX Shao Lai ESEB/DEX Si-Hwan Park ESEB/DEX Andrew Johnson Corrosion and Steam Generator (NCSG)/DNRL Brian Allik NCSG/DNRL Dev Ray NCSG/DNRL Greg Makar NCSG/DNRL Joel Jenkins NCSG/DNRL James Gavula NCSG/DNRL Leslie Terry NCSG/DNRL Lydiana Alvarado NCSG/DNRL Matthew Yoder NCSG/DNRL Miranda McGuire NCSG/DNRL Paul Klein NCSG/DNRL Reena Boruk NCSG/DNRL Tony Gardner NCSG/DNRL Ali Rezai Piping and Head Penetrations (NPHP)/DNRL Bart Fu NPHP/DNRL Eric Reichelt NPHP/DNRL Karen Sida NPHP/DNRL Seung Min NPHP/DNRL Varoujan Kalikian NPHP/DNRL David Dijamco Vessels and Internals (NVIB)/DNRL Emma Haywood NVIB/DNRL Eric Palmer NVIB/DNRL John Tsao NVIB/DNRL
iv On Yee NVIB/DNRL Angelo Stubbs Containment and Plant Systems (SCPB)/Division of Safety Systems (DSS)
Benjamin Rothberg SCPB/DSS Brian Lee SCPB/DSS Derek Scully SCPB/DSS Jack Vande Polder Nuclear Methods and Fuels/DSS Joseph Messina SFNB/DSS Jo Ambrosini Nuclear Systems Performance/DSS Andrew Siwy License Renewal Projects (NLRP)/DNRL Chris Tyree NLRP/DNRL
v TABLE OF CONTENTS TABLE OF CONTENTS................................................................................................................v ACRONYMS AND ABBREVIATIONS.........................................................................................viii 1.
Introduction..............................................................................................................................1 2.
Audit Activities.........................................................................................................................2 SLRA Section 2.1, Scoping and Screening Methodology 3
SLRA AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD 3
SLRA AMP B.2.1.2, Water Chemistry 4
SLRA AMP B.2.1.3, Reactor Head Closure Stud Bolting Program 6
SLRA AMP B.2.1.4, Boric Acid Corrosion 7
SLRA AMP B.2.1.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components 8 SLRA AMP B.2.1.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) 9 SLRA AMP B.2.1.7, PWR Vessel Internals 9
SLRA AMP B.2.1.8, Flow-Accelerated Corrosion 13 SLRA AMP B.2.1.9, Bolting Integrity 14 SLRA AMP B.2.1.10, Steam Generators 15 SLRA AMP B.2.1.11, Open-Cycle Cooling Water System 16 SLRA AMP B.2.1.12, Closed Treated Water Systems 17 SLRA AMP B.2.1.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 17 SLRA AMP B.2.1.14, Compressed Air Monitoring 19 SLRA AMP B.2.1.15, Fire Protection 20 SLRA AMP B.2.1.16, Fire Water System 21 SLRA AMP B.2.1.17, Outdoor and Large Atmospheric Metallic Storage Tanks 23 SLRA AMP B.2.1.18, Fuel Oil Chemistry 24 SLRA AMP B.2.1.19, Reactor Vessel Material Surveillance 25 SLRA AMP B.2.1.20, One-Time Inspection 26 SLRA AMP B.2.1.21, Selective Leaching 27 SLRA AMP B.2.1.22, ASME Code Class 1 Small-Bore Piping Program 28 SLRA AMP B.2.1.23, External Surfaces Monitoring of Mechanical Components 28 SLRA AMP B.2.1.24, Flux Thimble Tube Inspection 29 SLRA AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components 30
vi SLRA AMP B.2.1.26, Lubricating Oil Analysis 31 SLRA AMP B.2.1.27, Buried and Underground Piping and Tanks 32 SLRA AMP B.2.1.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchanger, and Tanks 33 SLRA AMP B.2.1.29, ASME Section XI, Subsection IWE 35 SLRA AMP B.2.1.30, ASME Section XI, Subsection IWL 36 SLRA AMP B.2.1.31, ASME Section XI, Subsection IWF 37 SLRA AMP B.2.1.32, 10 CFR Part 50, Appendix J 38 SLRA AMP B.2.1.33, Masonry Walls 39 SLRA AMP B.2.1.34, Structures Monitoring 40 SLRA AMP B.2.1.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants 45 SLRA AMP B.2.1.36, Protective Coating Monitoring and Maintenance 47 SLRA AMP B.2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 48 SLRA AMP B.2.1.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits 51 SLRA AMP B.2.1.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 53 SLRA AMP B.2.1.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 54 SLRA AMP B.2.1.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 55 SLRA AMP B.2.1.42, Metal Enclosed Bus 56 SLRA AMP B.2.1.43, Fuse Holders 58 SLRA AMP B.2.1.44, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 59 SLRA AMP B.3.1, Fatigue Monitoring 60 SLRA AMP B.3.2, Neutron Fluence Monitoring 62 SLRA AMP B.3.3, Environmental Qualification of Electric Equipment 63 SLRA AMP B.4.1, Concrete Containment Bonded Tendon Prestress 65 SLRA TLAA Section 4.1, Identification of Time-Limited Aging Analyses (TLAAs) 66 SLRA TLAA Section 4.2.1, Reactor Pressure Vessel Neutron Fluence 67 SLRA TLAA Section 4.2.2, Reactor Pressure Vessel Upper-Shelf Energy 68 SLRA TLAA Section 4.2.3, Reactor Pressure Vessel Pressurized Thermal Shock 68 SLRA TLAA Section 4.2.4, Reactor Pressure Vessel Pressure-Temperature Limits 70 SLRA TLAA Section 4.2.5, Reactor Pressure Vessel Low Temperature Overpressure Protection 70
vii SLRA TLAA Section 4.3.1, Transient Cycle Projections for 80 Years 71 SLRA TLAA Section 4.3.2, Class 1 Fatigue Analyses 72 SLRA TLAA Section 4.3.3, Non-class 1 Fatigue Analyses 73 SLRA TLAA Section 4.3.4, Environmentally Assisted Fatigue 74 SLRA TLAA Section 4.3.5, High-Energy Line Break 76 SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment 76 SLRA TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetration Fatigue Analysis 78 SLRA TLAA Section 4.7.1, Crane Fatigue 78 SLRA TLAA Section 4.7.2, Reactor Coolant Pump Flywheel Analyses 79 SLRA TLAA Section 4.7.3, Leak-Before-Break 80 SLRA TLAA Section 4.7.4, Reactor Coolant Pump Code Case N-481 81 SLRA TLAA Section 4.7.5, Reactor Vessel Underclad Cracking 82 SLRA TLAA Section 4.7.6, Foundation Pile Corrosion 84 SLRA TLAA Section 4.7.7, Concrete Containment Bonded Tendon Prestress Analysis 84 AMR Items Not Associated with an AMP 85 3.
Supplements to the SLRA.....................................................................................................89 4.
Audit Questions Provided to Duke.........................................................................................89 5.
Applicant Personnel Contacted During Audit........................................................................90 6.
Exit Meeting...........................................................................................................................91
viii ACRONYMS AND ABBREVIATIONS ADAMS Agencywide Documents Access and Management System AISI Augmented inservice inspection ALE Adverse localized environments AMP Aging Management Program AMR Aging management review AR Action report ASME American Society for Mechanical Engineers CAP Corrective Action Program CASS Cast austenitic stainless steel CBSE Common basis stress evaluation CRD Control rod drive CST Condensate storage tank CUF Cumulative usage factor EAF Environmentally assisted fatigue EC Engineering change EDG Emergency diesel generator EFPY Effective full power years EPRI Electric Power Research Institute EQ Environmental Qualification FAC Flow-accelerated corrosion FE Further evaluation FW Feedwater HELB High-energy line break ILRT Integrated leak-rate test IPA Integrated plant assessment ISI Inservice Inspection I&C Instrumentation and control LR License renewal MEB Metal enclosed bus NRC Nuclear Regulatory Commission OE Operating experience PBD Program basis document PWR Pressurized water reactor RAI Requests for Additional Information RCA Radiological control area RCI Requests for Confirmation of Information RCS Reactor coolant system
ix RHR Residual heat removal RPV Reactor pressure vessel RVI Reactor vessel integrity RWST Refueling water storage tank SBO Station blackout SC Structures and components SCC Stress corrosion cracking SIA Structural Integrity Associates SIT Structural integrity test SLR Subsequent license renewal SLRA Subsequent license renewal application SNM Susceptible non-modeled SSC Systems, structures, and components TLAA Time-Limited Aging Analyses UFSAR Updated final safety analysis report USE Upper-Shelf Energy UT Ultrasonic testing
1 Report for the Aging Management Audit H.B. Robinson Steam Electric Plant, Unit 2 Subsequent License Renewal Application 1.
Introduction The U.S. Nuclear Regulatory Commission (NRC) staff conducted an aging management audit of Duke Energy Progress, LLC (Duke, the applicant) of (1) plant-specific operating experience (OE), (2) methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal (LR) and subject to an aging management review (AMR) (Scoping and Screening Portion), and (3) aging management programs (AMPs),
AMR items, Time-Limited Aging Analyses (TLAAs), and associated bases and documentation as applicable (AMP and TLAA Portion) for the subsequent license renewal (SLR) of Renewed Facility Operating License No. DPR-23 for H.B. Robinson Steam Electric Plant (Robinson), Unit 2.
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 (CAP) 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. Duke searched their OE database and provided the results for the associated AMPs and TLAAs for NRC staff review.
Additional searches were performed by Duke upon the NRC staffs request, and the results were provided to the NRC staff for review.
The purpose of the Scoping and Screening portion of the audit is to evaluate the scoping and screening process as documented in the SLR 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; and 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 Dukes AMPs, AMR items, and TLAAs for Robinson, Unit 2; Verify Dukes claims of consistency with the corresponding NUREG-2191, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, issued in July 2017, AMPs, and AMR items; and 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 staff also considered the guidance contained in NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR), dated July 2017, and NUREG-2191. The SRP-SLR allows an applicant to reference in its SLR application the AMPs described in the GALL-SLR Report. By referencing the GALL-SLR Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and
2 approved in the GALL-SLR Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL-SLR Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL-SLR 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, licensing-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted 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 Robinson, Unit 2, subsequent license renewal application (SLRA) states that every AMP in the SLRA is consistent with the program elements of the GALL-SLR Report. To verify this claim of consistency, the staff audited each AMP, including any enhancements or exceptions associated with an AMP.
The SLRA 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 SLRA is consistent with the further evaluation (FE) information in the SRP-SLR.
Furthermore, the staff audited the updated final safety analysis report (UFSAR) supplement descriptions for each AMP and TLAA for consistency with the SRP-SLR. During its audit, the staff interviewed the applicants staff and reviewed documentation contained in the SLRA 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 SLRA and ePortal.
From June 3, 2025, to June 5, 2025, the staff participated in an on-site audit at Robinson, Unit 2 in Hartsville, SC to gain a general overview of current conditions of the structures compared to the provided OE. While on-site, the staff engaged with the applicant staff, conducted walkdowns, and reviewed documents provided by the applicant.
For the OE review, the staff conducted its review of the applicants methodology and OE by reviewing documentation contained in the SLRA 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 SLRA areas reviewed by the staff.
3 SLRA Section 2.1, Scoping and Screening Methodology Summary of Information in the Application. SLRA Section 2.1 describes the process for identifying and determining the Robinson SSCs included within the scope of LR and subject to an AMR. 10 CFR 54.21, Contents of Application - Technical Information, requires that each application for LR contain an integrated plant assessment (IPA). The IPA must list, for SSCs within the scope of LR, the structures and components (SCs) that are subject to an AMR. 10 CFR 54.4(a), Scope, provides the criteria for inclusion of SSCs within the scope of LR. 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.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to SLRA Section 2.1, Scoping and Screening Methodology. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-SCOP-0009 Subsequent License Renewal Scoping and Screening Methodology and Plant-Level Scoping Results Revision 0 SLR-RNP-SCOP-0002 Subsequent License Renewal Scoping for Criteria 10 CFR 54.4(A)(2) (Non-Safety Affecting Safety Related Equipment)
Revision 1 SLR-RNP-SCOP-0001 Subsequent License Renewal Scoping for Criteria 10 CFR 54.4(A)(1) Safety Related Criteria Revision 0 SLR-RNP-SCOP-0003 Subsequent License Renewal Scoping for Fire Protection (10 CFR 50.48)
Revision 1 SLR-RNP-SCOP-0007 Subsequent License Renewal Scoping for Station Blackout (10 CFR 50.63)
Revision 0 SLR-RNP-SCOP-0006 Subsequent License Renewal Scoping for Anticipated Transients Without SCRAM (10 CFR 50.62)
Revision 0 SLR-RNP-SCOP-0005 Subsequent License Renewal Scoping for Pressurized Thermal Shock (10 CFR 50.61)
Revision 0 SLR-RNP-SCOP-0004 Subsequent License Renewal Scoping for Environmental Qualification (10 CFR 50.49)
Revision 0 During the audit, the staff verified that the applicants scoping and screening process was performed in accordance with its written requirements and was consistent with the guidance provided in the SRP-SLR and NEI 17-01. The staff determined that the scoping and screening methodology was consistent with the requirements of 10 CFR Part 54 for the identification of SSCs that meet the scoping and screening criteria.
SLRA AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Summary of Information in the Application. The SLRA states that AMP B2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. 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.
4 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M1 ASME Section XI Inservice Inspection, Subsections, IWB, IWX, and IWD AMP Evaluation Report Revision 1 4/15/2025 SLR-RNP-OPEX-0100 Subsequent License Renewal Operating Experience Review Methodology and Results Revision 2 RNP-PM6-001 Sixth Interval Inservice Inspection Basis Document, H.B Robinson Steam Electric Plant Revision 0 2/15/2023 RNP-PM6-002 Sixth Interval Inservice Inspection (ISI) Plan Revision 0 2/15/2023 RNP-PM6-004 Augmented Inservice Inspection (AISI) Plan and Schedule Revision 0 2/15/2023 AR00752805 RHR Mixing Tee MRP-192 Weld 174 NDE Indication Evaluation 6/04/2015 AR00752805 RHR Mixing Tee MRP-192 Weld 174 NDE Indication Evaluation 6/04/2015 AR0210466 RPV BMI Inspection Coverage 3/02/2017 AR02359059 ISI Visual Examination of RPV A, B, and C Nozzle Supports 11/21/2020 AR02403669 Discolored Boric Acid on RVLIS Line from RPV Head 10/30/2021 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP or will be consistent after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.2, Water Chemistry Summary of Information in the Application. The SLRA states that AMP B2.1.2, Water Chemistry, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M2, Water Chemistry, as modified by SLR-ISG-2021-02-MECHANICAL, SLR-ISG-2021-02-MECHANICAL, dated February 2021 (ADAMS Accession No. ML20181A434).
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M2 Water Chemistry AMP Evaluation Report Revision 000
5 CSD-CP-RNP-0001 Robinson Primary Chemistry Strategic Plan Revision 5 CSD-CP-RNP-0002 Robinson Secondary Water Chemistry Strategic Plan Revision 3 AR-01989024 Elevated Iron Transport during unit start up 01/07/2016 OP-403 Feedwater System Revision 65 AR-02185680 Review of Fleet Chem & Ops Abnormal Sec Water Chem Procedure 2/19/2018 Self-Assessment-2185680 Review of Fleet Chemistry and Abnormal Secondary Water Chemistry Procedures 2/19/2018 AR-02177014 Secondary Chemistry Action Level 3 for Steam Generators 1/13/2018 AR-02309293 Unexpected increase in SG sodium concentrations 1/6/2020 PI 2309293-02 Support/refute HXs that communicate to condenser for potential cause of 0.05 ppb Na increase during significant rain events Not specified AR-02317414 Steam Generator Chlorides Elevated 2/22/2020 OR-02317414-01 Organizational Programmatic Checklist 2/22/2020 NCR-2317414 FIP Documentation 2/24/2020 NCR-2317414 Fault Table Not Specified AR-02364023 R2R32 Post Outage Critique Self-Assessment 01/06/2021 Self-Assessment-2364023-05 RO32 Chemistry Outage Self-Assessment 12/22/2020 AR-02443909 B RCP Narrow Range Seal Leakoff Fell Below Minimum Value 10/2/2022 CR-2443909 Adverse Trend in RCP Seal Failures 10/13/2022 N/A Root Cause Evaluation Report: Cycle 33 Coolant Pump Seal Performance Revision 2 N/A IRIS External Op Ex Reporting: Outage Critical Path Loss due to Reactor Collant Pump Seal Performance 10/2/2022 AR-02472290 Fuel Vendor Lithium Limit Exceeded During Downpower 5/10/2023 OEEV-02472290-01 Operating Experience Evaluation: Fuel Vendor Lithium Level Exceeded During Downpower Not Specified FCE-02472290-02 Flex Cause Evaluation 5/10/2023 N/A Corrective Action Closure Documentation Not Specified N/A Clarification to PWR Fuel Reactor Chemistry Supplemental Guidelines 8/14/2023 OEEV-02486551-01 OE Evaluation-FS1-0068903-Clarification to PWR Fuel Reactor chem Supp Guidelin Not Specified
6 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptancecriteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLRReport AMP.
The staff also audited the description of the SLRA AMP Water Chemistry provided in the UFSAR supplement. The staff verified this descriptionisconsistent with the description provided in the GALL-SLRReport.
SLRA AMP B.2.1.3, Reactor Head Closure Stud Bolting Program Summary of Information in the Application. The SLRA states that AMP B2.1.3, Reactor Head Closure Stud Bolting is an existing program with enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.M3, Reactor Head Closure Stud Bolting.
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.
Relevant Documents Reviewed Document Title Revision / Date CL-PBD-AMP-XI.M3 HBR 2 Updated Final Safety Analysis Report Revision 35 SLR-RNP-AMPR-XI.M3 Reactor Head Closure Stud Bolting AMP Evaluation Report Revision 0 MRP-003-1 Reactor Vessel Stud Removal and Installation Using Hydranuts Revision 2 RNP-L/LR-0619 Aging Management Program Reactor Head Closure Studs Program Revision 2 AE-NE-ALL-1107 Evaluation of Indications and Relevant Conditions Revision 4 AD-EG-ALL-1702 ASME Section XI Inservice Inspection Program Administration Revision 9 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, and acceptance criteria program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements. The staff also verified the applicants claim that aspects of the preventive actions and corrective actions" program elements not associated with the enhancement identified in the SLRA are consistent with the corresponding program elements in the GALL-SLR Report AMP.
During the audit, the staff made the following observations:
The staff verified that for Robinson, Unit 2, the bolting material used for the reactor pressure vessel closure studs are fabricated from ASTM A-540, Grade B23, the nuts and washers for the closure studs are A540 Grade B24 Grade 4 (E4340) and have an ultimate tensile strength of less than 170 ksi and that replacement studs have an actual measured yield strength of less than 150 ksi (SLR-RNP-AMPR-XI.M3).
The staff verified the Code of Record for Robinson is the 2017 Edition of ASME Boiler &
Pressure Vessel Section XI and that Robinson is in the 6th ISI internal with beginning and end dates of February 2023 and February 2033, respectively (SLR-RNP-AMPR-XI.M3).
The staff noted the extent and schedule for inspecting the reactor head closure studs, nuts, flange threads, bushings, and washers are consistent with those specified in ASME
7 Code Section XI Table IWB-2500-1 for examination categories B-G-1 and B-P (AD-EG-ALL-1702).
The staff noted that a phosphate surface treatment was applied to the reactor vessel studs, nuts, and washers during fabrication and that after each refueling outage, the studs are cleaned and lubricated with N5000 upon reinstallation, which mitigates the potential for stress corrosion cracking (SCC) or intergranular stress corrosion cracking (IGSCC) to occur. (AD-EG-ALL-1702).
The staff noted that in 2001, a recordable indication was identified, and the stud was subsequently replaced (SLR-RNP-AMPR-XI.M3).
The staff also audited the description of the SLRA AMP, Reactor Head Closure Stud Bolting, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR Report.
SLRA AMP B.2.1.4, Boric Acid Corrosion Summary of Information in the Application. The SLRA states that AMP B2.1.4, Boric Acid Corrosion, is an existing program that is consistent with the program elements in GALL-
-SLR Report AMP XI.M10, Boric Acid Corrosion.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M10 Boric Acid Corrosion AMP Evaluation Report Revision 0 PD-EG-PWR-1611 Boric Acid Corrosion Program Revision 2 AD-EG-PWR-1611 Boric Acid Corrosion Control Program Implementation Revision 6 AD-MN-ALL-0006 Fluid Leak Management Revision 6 TE-MN-PWR-0006 Inspection, Assessment, and Cleanup of Boric Acid on Plant Materials Revision 2 NDE-NE-ALL-7201 VT-2 Visual Examination Revision 5 NDE-NE-ALL-7202 Visual Examination of PWR Reactor Pressure Vessel Upper Head Penetrations Revision 6 NDE-NE-ALL-7203 Visual Examination of PWR Reactor Pressure Vessel Bottom Mounted Instrument Penetrations Revision 4 AD-OP-ALL0109 Operator Rounds Revision 7 AD-OP-ALL0109 Conduct of Operations Revision 26 OST-013 Weekly Checks and Operations Revision 185 OST-051 Reactor Coolant System Leakage Evaluation Revision 57
8 OST-052 RCS Leakage Test and Examination Prior to Startup Following Opening of the Primary System Revision 27 OST-053 Inspection for Reactor Coolant System Leakage Revision 20 AR 01990963 Boric Acid in WGDT Rm below the Spent Fuel Pool 01/13/2016 AR 02118017 INPO Materials Review Visit to RNP 04/19/2017 AR 02222785 Inactive Dry Boric Acid Leak on RHR Pump B 08/04/2018 AR 02359059 ISI Visual Examination of RPV A, B and C Nozzle Supports 11/21/2020 AR 02402785 RCP-B Discolored Boric Acid Around Pump Bowl and Insulation 10/24/2021 AR 02332207 License Renewal Self-Assessment 05/27/2020 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 SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP Boric Acid Corrosion provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components Summary of Information in the Application. The SLRA states that AMP B2.1.5, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-induced Corrosion in Reactor Coolant Pressure Boundary Components.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M11B Cracking of Nickel-Alloy Components and Loss of Material due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components AMP Evolution Report Revision 0 /
07/2024 AD-EG-ALL-1630 Alloy 600 Program Implementation Revision 4 /
03/2023 AD-EG-PWR-1611 Boric Acid Corrosion Control Program Implementation Revision 3 /
08/2020 OPEX AR 02248993
[Regulatory Issue Summary] RIS 18-06 [Reactor Pressure Vessel Upper Head] RPV UH Bare Visual Exam 12/14/2018
9 Document Title Revision / Date OPEX AR 02307465
[Material Reliability Program] MRP-384, Revision 1 12/16/2019 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 SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-induced Corrosion in Reactor Coolant Pressure Boundary Components, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)
Summary of Information in the Application. The SLRA states that AMP B2.1.6, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS), is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS).
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M12 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)
Revision 1 / 12/2024 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 SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS), provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.7, PWR Vessel Internals Summary of Information in the Application. The SLRA states that AMP B.2.1.7, PWR Vessel Internals, is an existing program that will be consistent with the program elements in GALL-SLR Report AMP XI.M16A, PWR Vessel Internals, as modified by SLR-ISG-2021-01-PWRVI, Updated Aging Management Criteria for Reactor Vessel Internal Components for Pressurized-Water Reactors.
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.
10 Relevant Documents Reviewed Document Title Revision / Date Robinson UFSAR Section 18.1.30 Rev. 27 MRP-227, Rev 0 Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, (ML12017A193, x194, x195, x196, and x197)
Rev. 0 MRP-227, Rev 1-A Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, 2019 edition, (ML19339G350) and 2020 edition (ML20175A112)
Rev. 1-A MRP-227, Rev 2 Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, (ML22129A141)
Rev. 2 MRP 2023-005 MRP-227, NEI 03-08 Needed Interim Guidance for WEC/CE Core Barrel Inspections, (ML23290A020)
Rev. 1 MRP 2024-019 2024 Biennial Report of Recent MRP-227-A Reactor Internals Inspection Results, (ML24270A195) 9/26/2024 MRP 2024-008 Interim Guidance for Ultrasonic Testing (UT) of Core Barrel Welds in Supplement to MRP-227, Rev 1-A Inspection Guidelines 7/16/2024 Robinson gap analysis Robinson Gap Analysis for the PWR Vessel Internals February 2025 WCAP-17451-P Reactor Internal Guide Tube Wear Westinghouse Domestic Fleet Operational Projections, (ML15041A107)
Rev. 1 OG-21-160 PWROG NEI 03-08 Needed Guidance: PWR Lower Radial Support Clevis Insert X-750 Bolt Inspection Requirements 9/1/2021 NSAL-16-1 Nuclear Safety Advisory Letter: Baffle-Former Bolts Revision 1, 8/1/2016 NSAL-17-1 Nuclear Safety Advisory Letter: Guide Tube Card Wear Attributed to Ion Nitride Rod Cluster Control Assembly 1/16/2017 MRP 2019-009 Transmittal of NEI-03-08 Good Practice Interim Guidance Regarding MRP-227-A and MRP-227, Revision 1 PWR Core Barrel and Core Support Barrel Inspection Requirements 7/17/2019 Westinghouse Technical Bulletin TB 19-5--Westinghouse NSSS PWR Thermal Shield Degradation Revision 0, 10/9/2019, and Revision 2 OG-20-31 Guidance Westinghouse NSSS PWR Thermal Shield Degradation Westinghouse Technical Bulletin TB 19-5 1/23/2020 OG-21-101 Guidance Westinghouse NSSS PWR Thermal Shield Degradation Westinghouse Technical Bulletin TB 19-5, Rev 1 5/12/2021 MRP 2019-017 Notification of Recent PWR Thermal Shield Attachment Bolting Failures and Flexure Cracking Operating Experience and Recommended Plant Actions 5/31/2019 Westinghouse TB-16-4 Fuel Alignment Pin Malcomized surface Degradation 8/15/2016 MRP 2019-009 Interim Guidance Regarding MRP-227-A and MRP-227, Revision 1 PWR Core Barrel and Core Support Barrel Inspection Requirements, August 2019 9/3/2019 Westinghouse TB-12-5 -- Baffle Bolt Degradation in a Westinghouse plant with downflow Reactor Internal design 3/7/2012 Westinghouse issued TB-14-5--Reactor Internals Lower Radial Support Clevis Insert Cap Screw Degradation (ML14302A072) 8/25/2014 MRP-2017-024 Notification of Recent Operating Experience (OE) Related to PWR Clevis Insert Bolting Fabricated from X-750 9/19/2017 MRP 2020-011 Notification of Recent Operating Experience (OE) Related to Displaced PWR Clevis Insert Assembly 4/28/2020
11 NSAL-18-1 Thermal Sleeve Flange Wear Leads to Struck Control Rods (ML18198A275) 7/17/2018 WCAP-17096-NP-A Reactor Internals Acceptance Criteria Methodology and Data Requirements, (ML16279A320)
Rev 2 WCAP-17096-NP-A Reactor Internals Acceptance Criteria Methodology and Data Requirements, (ML23248A257)
Rev 3 MRP-228 Inspection Standard for Pressurized Water Reactor Internals 2020 Update, (ML21019A003)
Rev 4 MRP 2017-009 Transmittal of NEI 03-08 Needed Interim Guidance Regarding Baffle Former Bolt Inspection for Westinghouse Plant as Defined in NSAL 16-01, Rev 1 3/15/2017 Inservice Inspection Report Robinson Inservice Inspection Program Ninety Day Owners Activity Report and Analytical Evaluations, (ML23089A212) 2023 NEI 03-08 Guideline for the Management of Materials Issues Rev 4 MRP 2023-005 MRP-227 NEI 03-08 Needed Interim Guidance for WEC/CE Core Barrel Inspections (ML23290A020) 5/19/2023 B2.1.7 OE Example 8 Robinson disposition of OE on the baffle former bolts 12/10/2022 B2.1.7 OE Example 9 Corrective Action Program -- control rod guide tube assembly examination 2/10/2012 B2.1.7 OE Example 11 Corrective Action Program --examination of the thermal shield support blocks 12/10/2022 B2.1.7 OE Example 12 Corrective Action ProgramExamination of reactor vessel lower radial support clevis inserts 12/10/2022 B2.1.7 OE Example 13 Corrective Action Program -- reactor vessel upper core plate alignment keys 12/7/2022 B2.1.7 OE Example 14 Corrective Action Program-- Malcomized surface degradation of the higher and lower core plates fuel alignment pins 10/19/2016 AD-EG-ALL-1911 Reactor Internals Program Implementation 12/13/2021 INR-UGW-2024-1 Examination of Upper Girth Weld of the Core Barrel 11/16/2024 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 SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP as modified by SLR-ISG-2021-01-PWRVI.
During the audit, the staff made the following observations:
The applicants pressurized water reactor (PWR Vessel Internals Program meets Section 2.4 of MRP-227, Revision 1-A, which contains a set of general plant operation assumptions that a PWR plant should meet in order to use the guidelines of MRP-227, Revision 1-A.
The applicant examined the clevis insert bolts - Item Number W14 in Table 4-9 of MRP-227, Revision 1-A, which was supplemented by the guidance of Westinghouse Bulletin TB 14-5 and PWROG Letter OG-21-160.
12 The applicant examined the baffle-former bolting (Item Number W6 in Table 4-3 of MRP-227, Revision 1-A), which was supplemented by the guidance of Westinghouse Letter NSAL-16-1.
The applicant examined the control rod guide tube assembly (Item Number W1 in Table 43 of MRP-227, Revision 1-A) which was supplemented by the guidance of Westinghouse Letter NSAL 17-1.
The applicant examined upper core plate alignment keys and found small indications.
The applicant examined the core barrel (Item Numbers W3 and W4 in Tables 4-3 and 4-6 of MRP-227, Revision 1-A), which was supplemented by the guidance of EPRI Letters MRP 2019-009 and MRP 2023-005, as supplemented by MRP 2024-004. The applicant detected indications in the core barrel upper girth weld.
The applicant examined the thermal shield support block bolts (Item Number W9 in Table 5-3 of MRP-227, Revision 1-A), which were supplemented by Westinghouse Letter TB 19-5.
On May 31, 2019, EPRI issued MRP 2019-017, Notification of Recent PWR Thermal Shield Attachment Bolting Failures and Flexure Cracking Operating Experience and Recommended Plant Actions. On October 9, 2019, Westinghouse issued Technical Bulletin TB-19-5, Revision 2, based on the continuing OE and industry response for thermal shield components.
Westinghouse Technical Bulletin TB-16-4 discusses an international nuclear plant that identified Malcomized surface degradation on its lower core plate and upper core plate fuel alignment pins.
Westinghouse issued Technical Bulletin TB-12-5 to address broken baffle-former bolts observed at D.C. Cook Unit 2 in fall 2010. Westinghouse also issued Advisory letter NSAL-16-1, Baffle-former Bolts, in which Robinson is designated as a Tier 2b plant.
For Tier 2b plants, NSAL-16-1 recommends that records of previous UT inspections of bolting be reviewed to identify any indication for the onset of clustering in the bolt failure patterns.
EPRI issued MRP 2019-009, Interim Guidance Regarding MRP-227-A and MRP-227, Revision 1 PWR Core Barrel and Core Support Barrel Inspection Requirements, which addresses core support barrels in Combustion Engineering plants and core barrels in Westinghouse plants.
Westinghouse issued Technical Bulletin TB-14-5 (ML14302A072) to provide new information regarding clevis insert cap screw bolt degradation observed during a 10-year ISI.
The applicant performed a gap analysis for the PWR Vessel Internals Program. This gap analysis includes incorporating the guidance in MRP-227, Revision 2, MRP-2023-005, Revision 01, and MRP 2024-008. At the time of the audit, the staff had not approved the generic use of MRP-227, Revision 2. However, the staff reviewed the applicants gap
13 analysis and its incorporation of MRP-227, Revision 2, on a plant-specific basis in the AMP.
The staff also audited the description of the SLRA AMP, PWR Vessel Internals, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report as modified by SLR-ISG-2021-01-PWRVI.
SLRA AMP B.2.1.8, Flow-Accelerated Corrosion Summary of Information in the Application. The SLRA states that AMP B2.1.8, Flow-Accelerated Corrosion, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M17, Flow-Accelerated Corrosion. 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 and in the SLRA.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M17 Flow-Accelerated Corrosion AMP Evaluation Report Rev 0 7.3.5 BP-2022-0001 TR FAC System Susceptible Non-Modeled (SNM) Program FAC System Susceptible Non-Modeled (SNM) Program Update Rev 0 CSD-EG-ALL-1610-05 Erosion Degradation Mechanisms Rev 0 CSD-EG-ALL-1610-01 Outage Inspection Planning Rev 0 CSD-EG-ALL-1610-04 Susceptible Non-modeled Program Selection and Inspection of FAC SNM Components Rev 0 AD-EG-ALL-1610 Flow Accelerated Corrosion Implentation Rev 7 7.3.4 BP-2022-0001 TR_Robinson System Susceptibility Analysis Update Report FAC System Susceptibility Analysis (SSA) Update Rev 0 7.3.3 BP-2022-0001 TR Erosion Susceptibility Analysis Erosion Susceptibility Analysis Rev 0 R2R31 Post Outage Report RNP FAC Program R2R31 Post Outage Report 2/14/2019 R2R32 Post Outage Report RNP FAC Program R2R32 Post Outage Report 2/17/2021 R2R34 Post Outage Report RNP FAC Program R2R34 Post Outage Report 4/29/2025 R2R33 Post Outage Report RNP FAC Program R2R33 Post Outage Report 4/17/2023 AR00720504 Steady stream leak coming from pipe 11/25/2014 AR00754191 Erosion of heater drain pump foundation 6/13/2015 AR02402372 AFW Trench flooding 10/20/2021 AR02184577 Aux boiler C-Steam leak 2/14/2018
14 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and corrective actions program elements of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements. In addition, the staff found that for the detection of aging effects and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR 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-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Flow-Accelerated Corrosion, provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP, Flow-Accelerated Corrosion. The staff will consider issuing RAIs in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
SLRA AMP B.2.1.9, Bolting Integrity Summary of Information in the Application. The SLRA states that AMP B2.1.9, Bolting Integrity is an existing program with enhancements that is consistent with the program elements in GALL-SLR Report AMP XI.M18, Bolting Integrity.
Audit Activities. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-M18 BOLTING INTEGRITY AMP EVAUATION REPORT Revision 0 WO 11039252 ROBINSON NUCLEAR PLANT QC TO PERFORM VT-1 ON BODY TO BONNET BOLTING 03/01/2009 AR 00849333 COMMITMENT IN RNP-RA/03-0031 BOLTING INTEGRITY PROGRAM 06/14/2002 WO 11512498 EXCESS LETDOWN H GASKET LEAK REPAIR DURING RO26 04/17/2010 AR 00400395 DEGRADED TUD ON EXCS-LTDN-HTX REF. WO 1512498 05/20/2010 AR 00523934 RF-73 LEAK FOUND AT FOUR HOLE FLANGE 03/13/2012 WO 12056529 RF-73 LEAK FOUND AT FOUR HOLE FLANGE 04/09/2013 WO 12274240 CONTINGENCY: REPLACE SERVICE WATER PUMP B FOR HIGH VIBES 10/24/2014 CM-010 SERVICE WATER PUMP MAINTENANCE Revision 29 WO 20007845 REMOVE AND REPLACE C SERVICE WATER PUMP 05/28/2017
15 WO 11618508 REMOVE AND REPLACE A SERVICE WATER PUMP 03/10/2014 WO 20078382 CCW PUMP A HAS LEAKING DISCHARGE FLANGE BOLT 07/08/2018 AR 020226822 CCW PUMP A HAS LEAKING DISCHARGE FLANGE BOLT 05/05/2016 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 elements of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements During the on-site audit, the staff made the following observations during walkdowns:
During the walkdown, the staff noted that the adverse conditions in the Bolting Integrity AMP were consistent with the descriptions in the OE documents provided in the ePortal.
The staff also audited the description of the SLRA AMP, Bolting Integrity, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR Report.
SLRA AMP B.2.1.10, Steam Generators Summary of Information in the Application. The SLRA states that AMP B2.1.10, Steam Generators, is an existing program that is consistent with the program elements in NUREG-2191 (GALL-SLR Report) AMP XI.M19, Steam Generators.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M19 Steam Generators AMP Evaluation Report Rev. 1 PD-EG-PWR-1801 Steam Generator Management Program Rev. 11 AD-EG-PWR-1811 Steam Generator Disposition Guidelines Rev. 3 AD-EG-PWR-1813 Steam Generator Degradation Assessments Rev. 5 AD-EG-PWR-1814 Steam Generator Condition Monitoring Rev. 4 AD-EG-PWR-1815 Steam Generator Operational Assessments Rev. 4 AD-MN-ALL-0002 Foreign Material Exclusion Rev. 16 ML23095A059 Refueling Outage 32 Steam Generator Tube Inspection Report Supplement Pursuant to TSTF Traveler TSTF-577, Revision 1 April 5, 2023
16 ML21147A263 Refueling Outage 32 Steam Generator Inspection Report May 26, 2021 ML22294A092 H.B. Robinson Steam Electric Plant, Unit 2 Issuance of Amendment 273 Regarding Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections December 15, 2022 CSD-CP-RNP-0020 Primary-to-Secondary Leak Rate Monitoring Rev. 2 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptancecriteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
During the audit, the staff made the following observation:
The staff identified the reference of updated versions of EPRI Steam Generator Management Program guidelines that were not yet referenced in the GALL-SLR Report AMP. The applicant indicated it would revise the SLRA. The staff notes that after the audit observation, NUREG 2191, Revision 1 was issued, which endorses updated editions/revisions of industry generated technical references.
The staff also audited the description of the SLRA AMP, Steam Generators, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.11, Open-Cycle Cooling Water System Summary of Information in the Application. The SLRA states that AMP B2.1.11, Open-Cycle Cooling Water System, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M20, Open-Cycle Cooling Water System.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M20 Open-cycle Cooling Water System AMP Evaluation Report Revision 1 AD-EG-ALL-1312 Raw Water Program Implementation Revision 0 CM-201 Safety Related and Non-Safety Related Heat Exchanger Maintenance Revision 60 CM-632 EDG Heat Exchanger Maintenance Revision 25 EST-116 Service Water Piping Inspection Revision 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 elements of the SLRA AMP
17 will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, Open-Cycle Cooling Water System, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.12, Closed Treated Water Systems Summary of Information in the Application. The SLRA states that AMP B2.1.12, Closed Treated Water Systems, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M21A, Closed Treated Water Systems, as modified by SLR-ISG-2021-02-MECHANICAL.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M21A Closed Treated Water Systems AMP Evaluation Report Revision 0 CP-001 Chemical Monitoring Program Revision 145 AR00428181 A EDG Jacket Cooling Water pH Remains Low 10/20/2010 AR484836484836A EDG Jacket Cooling Water pH Remains Low - Operational Decision-Making Evaluation 08/29/2011 EC 000247222 CC-775 and downstream piping replacement 02/21/2007 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, Closed Treated Water Systems, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. The SLRA states that AMP B2.1.13, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing program with enhancements that is consistent with the program elements in GALL-SLR Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling)
Handling Systems.
18 Audit Activities. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M23 Inspection of overhead Heavy Load and Light Load (Related to Refueling) Handling Systems AMP Evaluation Report Revision 0 AD-EG-RNP-1614 CONDITION MONTORING OF STRUCTURES Revision 9 MST-M-SFCRN-001 SPENT FUEL CASK HANDLING CRANCE SURVEILLANCE TESTING Revision 1 AD-MN-ALL-0010 NUCLEAR CRANES AND HOISTS Revision 8 PM-132 CONTAINMENT POLAR GANTRY CRANE INSPECTION Revision 23 PM-127 BRIDGE CRANES (SEMI-ANNUAL)
Revision 13 PM 131 SPENT FUEL CASK HANDLING CRANE INSPECTION Revision 19 PM-130 TURBINE GENERATOR CANTILEVER GANTRY CRANE SEMIANNUAL Revision 31 MMM-009 OPERATION, TESTING AND INSPECTION OF CRANES AND EQUIPMENT USED FOR HANDLING HEAVY LOADS Revision 88 AR 00151930 DEGRADED RAIL CLIP STUD ON SPENT FUEL CASK CRANE RUNWAY 02/24/2005 AR 00389605 ADVERSE CONDITION INVESTIGATION - EQUIPMENT REPORT 03/26/10 AD-PL-ALL-0400 OPERATING EXPERIENCE EVALUATION for AR 698326-Ensure Exterior Cranes are Protected From Corrosion Revision 0 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
During the audit, the staff made the following observations:
During the walkdown of the Fuel Handling Building and Turbine Building, the staff noted that the conditions of the corrosion and loss of material in overhead heavy load and light load (related to refueling) handling systems were consistent with the descriptions in the OE documents provided in the ePortal.
The staff also audited the description of the SLRA AMP, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
19 SLRA AMP B.2.1.14, Compressed Air Monitoring Summary of Information in the Application. The SLRA states that AMP B.2.1.14, Compressed Air Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M24, Compressed Air Monitoring. 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 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M24 Compressed Air Monitoring Program AMP Evaluation Report GALL-SLR Program XI.M.24 Revision 0 SOER 88-01 Instrument Air System Failures Revision 1 CP-COA-648 Technical Procedure (Testing) Instrument Air Sampling with Aircheck Kit Revision 4 SLR-RNP-OPEX-0100 Subsequent License Renewal Operating Experience Review Methodology and Results Revision 1 AD-PI-ALL-0100 Corrective Action Program Revision 30 AD-TQ-ALL-0010 Maintenance Training and Qualification Program Revision 14 Action Request-00188860 SOER 88-1 Instrument Air System Failures 03/24/2006 CP-COA-645 Chemistry Analysis Procedure Particle Size Analysis for Gaseous Samples Revision 3 Action Request-00498831 SOER 88-01, REC #4 Statuses as UNSAT during 2011 INPO Evaluation 11/20/2011 Action Request-00669402 Adress SOER 88-01 INPO/WANO Concerns for IA Quality Testing 02/18/2014 WO Planner 142283 Investigate Instrument Air Elevated Moisture Content 08/15/2022 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptancecriteria, and corrective actions program elements of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, Compressed Air Monitoring, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
20 SLRA AMP B.2.1.15, Fire Protection Summary of Information in the Application. The SLRA states that AMP B2.1.15, Fire Protection, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M26, Fire Protection.
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.
Relevant Documents Reviewed Document Title/Description Revision / Date SLR-RNP-AMPR-XI.M26 Fire Protection AMP Evaluation Report Revision 0 PD-FP-ALL-1500 Fleet Fire Protection Program Manual Revision 3 AD-EG-ALL-1214 Condition Monitoring of Structures Revision 1 AD-EG-RNP-1214 Condition Monitoring of Structures Revision 8 OST-693 Inspection of Miscellaneous Fire Protective Barriers Revision 10 OST-623 Fire Barrier Penetration Seal Inspection (markup)
Revision 28 OST-624 Fire Damper Inspection (markup)
Revision 30 OST-625 Fire Door Inspections (markup)
Revision 42 OST-626 Functional Test of Cable Vault CO2 Suppression System (markup)
Revision 28 OST-627-1 Functional Test of EDG A CO2 Cardox Suppression System (markup)
Revision 5 OST-628 Function Test of Halon 1301 System (markup)
Revision 27 OST-648 Fire Barrier Wrap Inspection (markup)
Revision 8 OST-696 Clean Agent Suppression System Annual Testing Hagan Room (markup)
Revision 3 FP-014 Control of Fire Barrier Penetrations Revision 15 AR01967154 Partially Closed Damper Blades October 22, 2015 WO20028641-02 Remove Broken Damper Blade WO20028641-07 Install New Damper ML18026A871 H.B. Robinson Steam Electric Plant Unit 2 - NRC Triennial Fire Protection Inspection Report 05000261/2017008 January 25, 2018 AR02304824 Missing Grout Filler November 27, 2019
21 Document Title/Description Revision / Date WO20350108-01 Replace fire door ML20274A286 H.B. Robinson Steam Electric Plant-Fire Protection Team Inspection Report 05000261/2020012 September 30, 2020 AR02357267 Tear in Fire Wrap November 10, 2020 WO20434035 Repair Tear in Fire Wrap (Information Report and Completion Report)
AR02199899 Holes in Fire Door Leaf and Latching Flushbolt Not Working April 19, 2018 AR02027612 Gap in Fire Protection Insulation May 9, 2016 AR02129493 Fire Door Not Closing or Latching Properly June 6, 2017 AR02271914 Door Frame Grout Needs to be Replaced May 9, 2019 AR02288928 Insulation Detached from Wall August 27, 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, Fire Protection, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.16, Fire Water System Summary of Information in the Application. The SLRA states that AMP B2.1.16, Fire Water System, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M27, Fire Water System. 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.
Relevant Documents Reviewed Document Title/Description Revision / Date SLR-RNP-AMPR-XI.M27 Fire Water System AMP Evaluation Report Revision 000 PD-FP-ALL-1500 Fleet Fire Protection Program Manual Revision 3 AD-FP-ALL-1551 Fire Protection Impairments Revision 2
22 Document Title/Description Revision / Date AD-EG-ALL-1211 System Performance Monitoring and Trending Revision 12 FP-013 Fire Protection Systems Surveillance Requirements Revision 21 OST-601-1 Turbine Lube Oil Pre-Action System Flow Test Revision 13 OST-609 Inspection and Flushing of the Interior Fire Hose Stations Revision 31 OST-629-12 Pre-Action Sprinkler System Functional Test Zone 12 Aux Bldg 1st Floor Center Hallway Revision 4 OST-629-23 Dry Standpipe System Functional Test Zone 23 Hagan Room Revision 3 OST-632 Unit 2 Fire Suppression Water System Flow Test Revision 28 OST-636 Flow Test for RCP B Pre-Action Sprinkler System Revision 25 OST-638 Pre-Action Sprinkler System Electrical Penetration Area Revision 18 OST-641 Flushing CV Hose Stations Revision 11 OST-647 Exterior Hose Station and Hose House Hydrostatic Testing, Flushing and Valve Cycling Revision 36 OST-656 CCW Pump Room Sprinkler Drain and Alarm Test Revision 12 OST-950 Multi-Cycle Preaction Sprinkler System Drain and Alarm Test Building 469 Revision 5 AR02075484 Unit 1 Fire Pump Suction Screen Unattached from Pump November 2, 2016 WO20051059 Unit 1 Fire Pump Suction Screen Unattached from Pump (deteriorated mounting bolts)
November 2, 2016 AR02143300 Leakage Observed During Motor Driven Fire Pump Test August 13, 2017 AR02090742 Unit 1 Fire Water Piping Leak (underground/buried piping)
January 10, 2017 AR00726507 Two Pinhole Leaks in Unit 1 Water Piping January 8, 2015 AR02091664 Unit 1 Fire Water Leak (underground/buried)
January 12, 2017 WO20517236 Replace Jockey Fire Pump AR02084957 Fire System Test Failure December 8, 2016 AR02469592 Jockey Fire Pump - No Discharge Flow/Pressure or Seal Leakage April 20, 2023 AR02182762 Underground Water Leak at Potable Water Isolation Valve February 6, 2018 AR02502660 Fitting Leak - Cooling Water to Engine Driven Fire Pump Pressure Indicator January 28, 2024
23 Document Title/Description Revision / Date AR00707695 Degraded Spool Piece, Tie Rods, and Bolts September 10, 2014 AR02437086 Piping Downstream of Jockey Pump Orifice has Leaking Fitting August 8, 2022 AR02433409 Leak in Underground Firewater Piping July 7, 2022 AR02501734 Unit 1 Fire Water Leak at Hydrogen Shed (underground)
January 20, 2024 AR00310386-07 Operating Experience Evaluation - Preaction Sprinkler System Internal Corrosion N/A AR00310386-08 Operating Experience Evaluation - Preaction Sprinkler System Internal Corrosion N/A N/A 2022 LR AMP Effectiveness Review - Fire Water September 29, 2022 AR00425434 Fire Water Pipe Coupling Broke October 7, 2010 AR00425434 Fire Protection System Training Slides Revision 8 AR02560734 Fire Pump Relief Valve Service Life July 9, 2025 AR02247668 Intake Cooling Water Blockage December 7, 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 element(s) of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, Fire Protection, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.17, Outdoor and Large Atmospheric Metallic Storage Tanks Summary of Information in the Application. The SLRA states that AMP B.2.1.17, Outdoor and Large Atmospheric Metallic Storage Tanks Program, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks Program. 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 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.
Relevant Documents Reviewed
24 Document Title Revision / Date SLR-RNP-AMPR-XI.M29 Outdoor and Large Atmospheric Metallic Storage Tanks AMP Evaluation Report Revision 0 API-653 #22654 Diesel Fuel Oil Tank #2 Modified API-653 Tank Inspection and Integrity Assessment 11/ 30/2022 API-653 #6241 VRT-FO-TNK-1 Turbine Fuel Oil Area R411 Modified API-653 Tank Inspection & Integrity Assessment 10/10/2019 API-653 #6241 VRT-FO-TNK-2 (Turbine Fuel Oil) Chemical Storage Area R412 Modified API-653 Tank Inspection & Integrity Assessment 10/09/2019 API-653 #6241 VRT-FO-TNK-3 (Turbine Fuel Oil) Chemical Storage Area R412 Modified API-653 Tank Inspection & Integrity Assessment 10/08/2019 API-653 #6241 VRT-FO-TNK-4 Diesel Fuel Tank (2 Fuel Oil) R-145-4 Modified API-653 Tank Inspection & Integrity Assessment 11/05/2015 AD-EG-RNP-1213 RNP Specific Requirements for System Walkdowns Revision 9 CM-M-Cond_TNK-001 Condensate Storage Tank Bladder Replacement Revision 0 OST-408 Technical procedure Testing Diesel Fuel Oil Storage Tank Drain Revision 18 SP-1085 Diesel Fuel Oil Storage Tank 10-year Cleaning Interval Revision 6 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLRReport AMP after implementation of the identified enhancements with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Outdoor and Large Atmospheric Metallic Storage Tanks, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.18, Fuel Oil Chemistry Summary of Information in the Application. The SLRA states that AMP B.2.1.18, Fuel Oil Chemistry, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M30, Fuel Oil Chemistry. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M30 Document Fuel Oil Chemistry Aging Management Program Evaluation Report Revision 0
25 API-653 #6241 VRT-FO-TNK-1 (Turbine Fuel Oil) Chemical Storage Area R411 Modified API-653 Tank Inspection & Integrity Assessment 10/10/2019 API-653 #6241 VRT-FO-TNK-2 (Turbine Fuel Oil) Chemical Storage Area R411 Modified API-653 Tank Inspection & Integrity Assessment 10/09/2019 API-653 #6241 VRT-FO-TNK-3 (Turbine Fuel Oil) Chemical Storage Area R411 Modified API-653 Tank Inspection & Integrity Assessment 10/08/2019 API-653 #22954 VRT-FO-TNK-4 (Turbine Fuel Oil) Chemical Storage Area R411 Modified API-653 Tank Inspection & Integrity Assessment 11/05/2015 Technical Procedure CP-001 Chemistry Monitoring program Revision 151 Technical Procedure (Testing)
CP-064 Water and Sediment in Oil Revision 19 Technical Procedure (Testing)
CP-DSL-402 Diesel Fuel Oil Storage Tank Sampling Revision 15 NGD-G-0001 Common Diesel Fuel Oil (Grade 2-D) Specification Revision 004 OST-401-1 EDG A Slow Speed Start Revision 86 OST-408 Diesel Fuel Oil Storage Tank Drain Revision 18 Picture #1 DFOST1 Diesel Fuel Oil Storage Tank 05/2025 DFOST Inspection Report Fuel Tank Maintenance CO. LLC For Robinson Nuclear Hartsville, South Carolina 11/30/2022 Inspection Report with Pictures API-653 Inspection (VRT-FO-TNK-1) 10/10/2019 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, Fuel Oil Chemistry, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.19, Reactor Vessel Material Surveillance Summary of Information in the Application. The SLRA states that AMP B2.1.19, Reactor Vessel Material Surveillance, is an existing program with an enhancement that will be consistent with the program elements in GALL--SLR Report AMP XI.M31, Reactor Vessel Material Surveillance. 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.
26 Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M31 Reactor Vessel Material Surveillance AMP Evaluation Report Revision 001 Action Request - 02391188 Incorrect T.S. Fig 3.4.3-2 PT Limit Cooldown Curve Action Request - 02103645 Ex Vessel Dosimeters Not in Expected Location 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 SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Reactor Vessel Material Surveillance, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.20, One-Time Inspection Summary of Information in the Application. The SLRA states that AMP B2.1.20, One-Time Inspection, is a new program that will be consistent with the program elements in GALL-
-SLR Report AMP XI.M32, One-Time Inspection. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M32 One-Time Inspection AMP Evaluation Report Revision 0 AR 00607952 Thru-Wall Boric Acid Leak Condition At CVC-349C TEE Location 05/22/2013 AR 00396747 License Renewal Inspection of C-53 Identified Cracked Welds 04/30/2010 AR 00085012 Commitment in RPN-RA/03-0031 One-Time Inspection Program 06/14/2002 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 SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, One-Time Inspection, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
27 SLRA AMP B.2.1.21, Selective Leaching Summary of Information in the Application. The SLRA states that AMP B2.1.21, Selective Leaching, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M33, Selective Leaching. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M33 Selective Leaching AMP Evaluation Report Revision 0 L2-C-007 Field Coatings Revision 1 AR 85018 License Renewal Commitment #35 - Selective Leaching - Site Fire Protection System 01/28/2004 AR 2364078-06 IN 2020-04: OE Related to Failure of FP Main Yard Piping 02/22/2021 AD-EG-ALL-1651 License Renewal Selective Leaching Aging Management Program Revision 1 EC 077281 Selective Leaching Inspection Report for Service Water System 06/28/2010 RNP-L/LR-0633 Selective Leaching of Materials Program Revision 7 NCR 399508 Potential Selective Leaching on Service Water Valves 05/15/2010 During the audit, the staff verified the applicants claim that the preventive actions, parameters monitored or inspected, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the scope of program and detection of aging effects program elements, sufficient information was not available to verify whether they were consistent with the corresponding program elements of the GALL-SLR 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-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Selective Leaching, provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP, Selective Leaching. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
28 SLRA AMP B.2.1.22, ASME Code Class 1 Small-Bore Piping Program Summary of Information in the Application. The SLRA states that AMP B2.1.22, ASME Code Class 1 Small-Bore Piping is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M35, ASME Code Class 1 Small-Bore Piping.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M35 ASME Code Class 1 Small-Bore Piping AMP Evaluation Report Revision 1 SLR-RNP-OPEX-0100 Subsequent License Renewal Operating Experience Review Methodology and Results Revision 2 AR00387229 CVC-121D Leak (PLP-111) 03/16/2010 AR00755955 Greater Than 60 DP Leak at PT-444 (Drain Line Fitting) 06/24/2015 AR02234909 FT-414 Boric Acid at Fitting 10/03/2018 AR02287473 R2F32A Addition; WO 20318082, LC-1530 Steam Leak 08/17/2019 AR02289406 Active leakage from PS-969B When Sampling the Pressurizer 08/29/2019 AR02403669 Discolored Boric Acid on RVLIS Line from RPV Head 10/30/2021 AR02438722 Near CVC-288 B Charging Pump Discharge Leakage 08/19/2022 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 the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, ASME Code Class 1 Small-Bore Piping, provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.23, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The SLRA states that AMP B2.1.23, External Surfaces Monitoring of Mechanical Components, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M36, External Surfaces Monitoring of Mechanical Components. 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.
29 Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M36 External Surfaces Monitoring of Mechanical Components Revision 0 AD-EG-ALL-1213 System Walkdowns Revision 6 AD-OP-ALL-0109 Operator Rounds Revision 4 AD-MN-ALL-0006 Fluid Leak Management Revision 6 AD-EG-RNP-1213 RNP Specific Requirements for System Walkdowns Revision 9 AR 00420279 FP-74 Leaks Under the Insulation When the MDFP is Running 09/06/2010 AR 02146842 Water Leaking from HVA-2 Enclosure Relay and Cable Room 08/29/2017 AR 02357814 HVH-9B Flexible Ductwork Seal Degraded 11/13/2020 AR 00734330 UT Pipe 4-FW-1502N-32 Due to External Corrosion 02/23/2015 AR 02046426 Water Accumulation on AHU-1, Control room AHU, SE Corner 07/18/2016 AR 00607952 Thru-Wall Boric Acid Leak Condition at CVC-349C Tee Location 05/22/2013 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, External Surfaces Monitoring of Mechanical Components, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.24, Flux Thimble Tube Inspection Summary of Information in the Application. The SLRA states that AMP B2.1.24, Flux Thimble Tube Inspection, is an existing program with an enhancement that will be consistent with the program elements in GALL-SLR Report AMP XI.M37, Flux Thimble Tube Inspection. 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.
Relevant Documents Reviewed
30 Document Title Revision / Date SLR-RNP-AMPR-XI.M37 Flux Thimble Tube Inspection Revision 000 EST-108 Robinson Unit 2 - Technical Procedure (Testing) - Flux Thimble Eddy Current Inspection Revision 14 ML091100397 H.B. Robinson Steam Electric Plant, Unit No. 2, Status Update for NRC Bulletin 88-09, "Thimble Tube Thinning in Westinghouse Reactors."
April 13, 2009 EST-108 - RO 29 Record May 2015 EST-108 - RO 34 Record November 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancement.
During the audit, the staff made the following observations:
The plant procedure for the Flux Thimble Tube Inspection Program (EST-108, Rev
- 14) indicates that the acceptance criterion for the calibration (inner) tube is consistent with the results of the analysis conducted to support the applicant's response to NRC Bulletin 88-09 (i.e., the calibration tube at HBR2 can lose 65 percent of its wall thickness without exceeding ASME Code material allowables under design condition).
The results of the applicants most recent inspections (documented in EST-108 - RO 29 and 34 Record) were consistent with those identified during the previous inspections (i.e., no detectable degradation).
The staff also audited the description of the SLRA AMP, Flux Thimble Tube Inspection, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The SLRA states that AMP B2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components AMP Evaluation Report Revision 0
31 AD-EG-ALL-1652 License Renewal Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program Revision 0 AD-CP-ALL-003 Closed Cooling Water Chemistry Program Revision 5 AR 00515464 HVH-3 is Leaking at the Fan Cooler Covers 02/08/2012 AR 00593710 Replace HVE-15A Suction and Discharge Flexible Connection 03/07/2013 AR 02168416 IA-472 Found Degraded During IA-CMP-B Overhaul 11/29/2017 AR 02410339 FD-56 Bolts Rusted Closed and One Snapped Off 12/29/2022 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 SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.26, Lubricating Oil Analysis Summary of Information in the Application. The SLRA states that AMP B.2.1.26, Lubricating Oil Analysis, is an existing program that is consistent with the program elements in GALL-SLR Report AMP XI.M39, Lubricating Oil Analysis.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M39 Lubricating Oil Analysis AMP Evaluation Revision 0 OP-506 Robinson Unit 2 Technical Procedure (Operating) Turbine Lube Oil Revision 76 PMR# 670028 Due to Declining Trend in Turbine Lube Oil RPVOT Results, it is Recommended that the Frequency of PMID-RQ 71756-01 (Lube Oil Sampling and Analysis) be Increased to Quarterly 06/02/2014 Engineering Change 0000403742 Correction-Quick Drain Valve Alternatives on Plant Equipment for Improved 05/18/2017 Revision 0 Work Order Package 13365885-38 Oil in TLO System Reaching End of Us 06/08/2015 TMM-117 Robinson Unit 2 Administrative Procedure Lube Oil Analysis Program Revision 12 PDM-001 Robinson Unit 2 Technical Procedure (Maintenance)
Revision 102 CP-DSL-403 R000 This PRR is for a new procedure for Chemistry to Take EDG Lube Oil Samples 11/02/2023
32 Action Request: 00671216 Oil in TLO System Reaching End of Useful Life 02/26/2014 Action Request 02491098 Emergency Diesel Generator Lube Oil Sampling 10/19/2023 Action Request 00699625 FME Found in Kaydon System During Maintenance 07/24/2014 During the audit, the staff verified applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, detection of aging effects, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Lubricating Oil Analysis, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.27, Buried and Underground Piping and Tanks Summary of Information in the Application. The SLRA states that AMP B2.1.27, Buried and Underground Piping and Tanks, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M41 Buried and Underground Piping and Tanks AMP Evaluation Report Revision 1 HBR2-07701 General Arrangement - Partial Plan Locations w/ Fuel Oil, and Cooling Water Piping Arrangements Revision 3 HBR2-11760, Sheet 1 Cathodic Protection System Underground Fuel Oil and Natural Gas Piping Units 1 and 2 Revision 6 L2-C-007 Field Coatings Revision 1 TE-MN-ALL-0510 Excavation and Backfill Revision 2 RNP-24-0003 Re-Route Dedicated Shutdown D/G Pipe Above Ground 02/15/2024 AD-EG-ALL-1613 Buried Piping Integrity Program Implementation Revision 7 PM-E-CATH-MISC-001 Cathodic Protection System Soil to Structure Potential Measurement Test Revision 3 PM-E-CATH-RCTFR-001 Cathodic Protection System Rectifier Inspection and Cleaning Revision 3 AR 02369685 Cathodic Protection System Survey Results 02/11/2021
33 AR 00634893 EDG B FO-60B Buried Pipe Inspection Found OD Corrosion 10/13/2013 AR 00634909 EDG A FO-60A Buried Pipe Inspection Found OD Corrosion 10/13/2013 AR 00576099 Pitting Identified on FP Pipe Sample from FP-356-10 12/04/2012 AR 02109173 Suspected Air Leak at Intake on 2-IA-1 IA Supply to Intake 03/17/2017 AR 02309732 Buried Piping Program Procedural Adequacy and Implementation 07/30/2020 During the audit, the staff verified the applicants claim that the monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements. In addition, the staff found that for the scope of program, preventive actions, parameters monitored or inspected, and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR 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-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Buried and Underground Piping and Tanks, provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP, Buried and Underground Piping and Tanks. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
SLRA AMP B.2.1.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchanger, and Tanks Summary of Information in the Application. The SLRA states that AMP B2.1.28, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers and Tanks, is a new program with exception that will be consistent with the program elements in GALL-SLR Report AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers and Tanks, as modified by SLR-ISG-2021-02-MECHANICAL, Updated Aging Management Criteria for Mechanical Portions of the Subsequent License Renewal Guidance. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M42 Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers and Tanks Rev. 1
34 AR 19617 Adverse Condition Investigation (3-CW-50A Exciter Cooler Return Piping Leak) 05/12/2000 AR 229429229429Adverse Condition Investigation (Exciter Cooler Supply Piping Leak)
Undated (event 4/13/2007)
AR 291412291412Adverse Condition Investigation (Liner Failure on Service Water Piping) 08/12/2008 AR 362306362306Adverse Condition Investigation (Leak in Service Water Return Line)
Undated (event 2009)
AR 00364121 RNP Needs Proactive Program for SW Pipes 11/03/2009 AR 00750869 North Service Water Underground Header Inspection 05/25/2015 AR 00633134 Pipe Inspection for South Header Identified Missing Concrete 10/05/2013 AR 00399276 CC-748A Missing Part of Seating Area 05/13/2010 AR 00399593 CC-748B Missing Approx. 12 Inches of Rubber Seat 05/16/2010 AR 00424086 Unplanned LCO 3.7.6 Entry for B CCW Pump 09/29/2010 AR 00719666 LR-ISG-2013-01 Aging Mgmt Loss Coating Lining Integrity 11/19/2014 AR 00728466 Coatings Program Enhancements 01/21/2015 AR 00751111 Rubber Liner Repair on 30 Service Water Pipe in Pit #3 05/27/2015 AR 02105259 NOS Identified WO-20016230-01 PRT Cleanliness Unsat 03/05/2017 WO 20016230 Open PRT and Perform Video Inspection and Close PRT Using NE 03/07/2017 AR 02247520 2018 NRC LR Inspection: SW Piping Inspection 12/06/2018 AR 02433409 Leak in Underground Firewater Piping 07/07/2022 AR 0630381 Coating Degradation Identified During H2 Side SO Clr Insp 11/21/2013 (event 9/24/2013)
SLR-RNP-FERR-0200 Subsequent License Renewal Further Evaluation Required Report-Engineered Safety Features Rev. 0 SLR-RNP-FERR-0300 Subsequent License Renewal Further Evaluation Required Report-Auxiliary Systems Rev. 0 NTM 02036020 Action Request Details Report LR-ISG-2012-02 Internal Corrosion subsequent review 12/08/2020 AR 02106632 SW-561 SWBP A DISCH CHECK VALVE shows internal corrosion 03/16/2017 EC 407787 SW-561 Hinge Support Corrosion Rev. 0 DFOST Inspection Report Diesel Fuel Oil Tank #2 Modified API-653 Tank Inspection and Integrity Assessment 11/29/2022 to 11/30/2022 VRT-FO-TNK-4 Final Report Diesel Fuel Tank (#2 Fuel Oil) R-145-4 Modified API-653 Tank Inspection and Integrity Assessment 11/05/2015
35 WO-20171926-01 VRT-FO-TNK-4 Repair Belzona Coating (Inside Tank) 7/16/2019 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP. The staff also verified the applicants claim that aspects of the corrective actions and detection of aging effects program element not associated with the exceptions identified in the SLRA or by the staff during the audit are consistent with the corresponding program elements in the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers and Tanks, provided in the UFSAR supplement.
The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.29, ASME Section XI, Subsection IWE Summary of Information in the Application. The SLRA states that AMP B2.1.29, ASME Section XI, Subsection IWE, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S1, ASME Section XI, Subsection IWE.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.S1 IWE ASME Section XI, Subsection IWE AMP Evaluation Report Revision 1 RNP-PM3-001 Third Ten-Year Interval IWE/ IWL Inspection Program Basis Document Revision 0 RNP-PM3-006 Third Ten-Year Interval Inservice IWE/IWL Inspection Plan Revision 1 RNP-PM3-007 Third Ten-Year Interval Inservice IWE/IWL Inspection Schedule Revision 1 CSD-EG-ALL-1702-01 ASME SECTION XI INSERVICE INSPECTION PROGRAM WORKPLACE PROCESSES AND INSTRUCTIONS Revision 1 CM-764 INSPECTION AND REPAIR OF CV LINER AND INSULATION Revision 25 NDE-NE-ALL-7402 VISUAL EXAMINATION OF IWE COMPONENTS Revision 3 RNP-C/STRU-1128 MINIMUM ALLOWABLE CONTAINMENT LINER THICKNESS Revision 9 EC 272699 CV liner eval EVALUATION OF CONTAINMENT BUILDING LINER, INSULATION, SHEATHING, AND COATING Revision 1 AR 0202994-07 NRC Regulatory Issue Summary #2016-07, Containment Shell or Liner Moisture Barrier Inspection 08/2/2016 WO 20101655 Robinson RO31 Construction Joint 09/26/2018
36 AR 02109909 IN 2014-07 Incomplete Resolution 03/21/2017 AR 02360094 Containment Moisture Barrie Repair Scope Deferral 12/02/2020 AR 02358916 ISI Containment Moisture Barrier Visual Examination 11/19/2020 EC 418734 CV Moisture Barrier Inspection Results (R2R32)
Revision 0 L-2021-LLR-0064 H.B. ROBINSON STEAM ELETRIC PLANT, UNIT 2 - REQUEST OF ALTERNATIVES TO ASME CODE SECTION XI SUBSECTION IWE REQUIREMENTS FOR CONTAINMENT INSPECTIONS 08/04/2022 AD-PI-ALL-0300 2021 Inservice Inspection Five Year Self-Assessment Revision 5 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
During the on-site audit, the staff made the following observations during walkdowns:
During the walkdown, the staff noted that the adverse conditions in the ASME XI-IWE AMP were consistent with the descriptions in the OE documents provided in the ePortal.
The staff also audited the description of the SLRA AMP, ASME Section XI, Subsection IWE, provided in the USAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.30, ASME Section XI, Subsection IWL Summary of Information in the Application. The SLRA states that AMP B2.1.30, ASME Section XI, Subsection IWL, is an existing program with enhancements that is consistent with the program elements in GALL--SLR Report AMP XI.S2, ASME Section XI, Subsection IWL.
Audit Activities. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision/Date SLR-RNP-AMPR-XI.S2 ASME SECTION XI, SUBSECTION IWL AMP EVALUATION REPORT Revision 1 RNP-PM3-006 Third Ten-Year Interval Inservice IWE/IWL Inspection Plan Revision 1 RNP-PM3--001 Third Ten-Year Interval IWE/IWL Inservice Inspection Program Basis Document Revision 0 RNP-PM3-007 Third Ten-Year Interval IWE/IWL Inservice Inspection Program Basis Document Revision 1
37 NDE-NE-ALL-7401 VIUSAL EXAMINATION OF IWL COMPONENTS Revision 2 CSD-EG-ALL-1702-01 ASME SECTION XI INSERVICE INSPECTION PROGRAM WORKSPACE PROCESSES AND INSTRUCTIONS Revision 1 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
During the on-site audit, the staff made the following observations during walkdowns:
During the walkdown, the staff noted that the adverse conditions in ASME Section XI, Subsection IWL were consistent with the descriptions in the OE documents provided in the ePortal.
The staff also audited the description of the SLRA AMP, ASME Section XI, Subsection IWL, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.31, ASME Section XI, Subsection IWF Summary of Information in the Application. The SLRA states that AMP B2.1.31, ASME Section XI, Subsection IWF, is an existing program with enhancements that is consistent with the program elements in GALL-SLR Report AMP XI.S3, ASME Section XI, Subsection IWF.
Audit Activities. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision/Date SLR-RNP-AMPR-XI.S6 IWE ASME Section XI, Subsection IWF AMP Evaluation Report Revision 1 AR 02233921 ISI Visual Examination of Support RC-3-159 09/28/2018 RO 24 NIS-1 INSERVICE INSPECTION REPORT INTERVAL 4, PERIOD 2, OUTAGE 2 (2006On-Line & RO #24) 07/26/2007 AR 00749705 ENGINEERING EVALUATION REQUIRED ON COMPONENT SUPPORT 05/18/2015 CR 749705 INSERVICE INSPECTION OF COMPONENT SUPOORTS IDENTIFIED 05/18/2015 CONDITIONS THAT REQUIRE EVALUATION BY DESIGN ENGINEERING FOR ACCEPTANCE OF FUNCTIONALITY 05/18/2015 AR 02359031 ISI Visual Examination of Variable Spring Support 262/FW-3A 11/21/2020 AR 02357078 ISI Visual Examination of Component Support 313/SW-1-H-1 11/09/2020 EC 418668 SW-1/H-1 Supoort Discrepancy Revision 0
38 AD-PI-ALL-0300 2021 Inservice Five Year Self-Assessment Revision 5 NCR 02450773 N/A N/A RA-23-0300 Fifth Ten-Year Inservice Inspection Interval Limited Examinations 02/15/2024 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
During the on-site audit, the staff made the following observations during walkdowns:
During the walkdown, the staff noted that the adverse conditions in ASME Section XI, Subsection IWF were consistent with the descriptions in the OE documents provided in the ePortal.
The staff also audited the description of the SLRA AMP, ASME Section XI, Subsection IWF, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.32, 10 CFR Part 50, Appendix J Summary of Information in the Application. The SLRA states that AMP B2.1.32, Appendix J, is an existing program that is consistent with the program elements in GALL--SLR Report AMP XI.S4. 10 CFR Part 50, Appendix J.
Audit Activities. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision/Date SLR-RNP-AMPR-XI.S4 10 CFR PART 50, APPENDIX J AMP EVALUATION REPORT Revision 0 AR 00632968 WD-1713 FAILED LOCAL LEAK RATE TEST 10/04/2013 AR 00634565 WD-1793 VSLVE SUSPECTED OF LEAKING BY 10/10/2013 AR 02111102 OST-014 completed Unsat due to leakage 03/23/2017 ML16201A195 H.B. ROBINSON STEAM ELETRIC PLANT, UNIT NO.2 -
ISSUANCE OF AMENDMENT TO EXTEND CONTAINMENT LEAKAGE RATE TEST FREQUENCIES (CAS NO. MF7102) 10/11/2016 EST-085 CONTAINMENT INTERGRATED LEAK RATE TEST Revision 024 EST-064 CONTAINMENT ISOLATION VALVE LOCAL LEAKAGE RATE SURVEY Revision 017
39 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Appendix J, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.33, Masonry Walls Summary of Information in the Application. The SLRA states that AMP B2.1.33, Masonry Walls, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S5, Masonry Walls. 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. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision/Date SLR-RNP-AMPR-XI.S5 Masonry Walls AMP Evaluation Report Revision 0 UFSAR H. B. Robinson Steam Electric Plant, Unit 2 Updated Final Safety Analysis Report (UFSAR); NRC Docket No. 50-261 Revision 30 AD-EG-ALL-1214 Nuclear Operating Fleet Administrative Procedure - Condition Monitoring of Structures Revision 1 DUKE-QAPD-001-A Duke Energy Corporation Topical Report - Quality Assurance Program Description - Operating Fleet Amendment 45 AD-PI-ALL-0100 Corrective Action Program Revision 30 AD-PI-ALL-0200 Performance Trending Revision 15 AD-EG-RNP-1214 Robinson Unit 2 Administrative Procedure - Condition Monitoring of Structures Revision 8 SLR-RNP-AMPR-XI.S6 Structures Monitoring AMP Evaluation Report Revision 0 SLR-RNP-AMPR-XI.M26 Fire Protection AMP Evaluation Report Revision 0 MWO 11136886 Engineering to Verify Structural Inspections - Containment Vessel N/A MWO 20648369 License Renewal Structural Inspection of Turbine Building In Accordance With EGR-NGGC-0351 N/A MWO 11658110 License Renewal Inspection of Radwaste Building per AD-EG-ALL-1214 N/A
40 MWO 11136901 Verify Structural Inspections per EGR-NGGC-0351 - Building 220 N/A MWO 11783577 Structural Inspections of Building 225 per AD-EG-ALL-1214 N/A MWO 11782160 Structural Inspections of Building-215 per EGR-NGGC-0351 N/A MWO 11136889 Verify Structural Inspections per AD-EG-ALL-1214 - Building 205N/A MWO 11136890 Verify Structural Inspections per AD-EG-ALL-1214 - Control Room N/A AR 00718536 Cracks in Turbine Building Masonry Block Wall 13 Noted 11/13/2014 EC 99440 Masonry Block Wall 13 Seismic Interaction with Common MDAFW Pump Suction Line 6-C-425 From CST 4/9/2015 AR 00716302 Cracks around Masonry Walls in the Waste Gas Decay Tank Room 10/31/2014 EC 98814 Masonry Block Wall Crack Evaluation for WGDT Room BL-80-11 Walls 7A, 7B, 7C, 7D 3/16/2015 RNP-C/STRU-1038 Evaluation of Block Wall at Gas Decay Tank Revision 0 AR 02469492 Install of HRA Door #10 Did Not Consider Impact to Safety Related Block Wall #1 4/19/2023 EC 422496 Robinson Cycle 34 Permanent Shielding Requests Revision 0 EC 422741 Evaluate Historical Impact of HRA Door #10 on Block all #1 Revision 0 RNP-C/RAB-1049 Evaluation of Masonry Block Walls for Review Level Earthquake Revision 1 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
During the on-site audit, the staff made the following observations during walkdowns:
During the walkdown of the Fuel Handling Building and Turbine Building, the staff noted that the conditions of the cracking and loss of material in masonry walls were consistent with the descriptions in the OE documents provided in the ePortal.
The staff also audited the description of the SLRA, Masonry Walls, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.34, Structures Monitoring Summary of Information in the Application. The SLRA states that AMP B2.1.34, Structures Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.S6, Structures Monitoring. At the time of the audit, the
41 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. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.S6 Structures Monitoring AMP Evaluation Report Revision 0 UFSAR H. B. Robinson Steam Electric Plant, Unit 2 Updated Final Safety Analysis Report (UFSAR); NRC Docket No. 50-261 Revision 30 AD-EG-ALL-1214 Nuclear Operating Fleet Administrative Procedure - Condition Monitoring of Structures Revision 1 AD-PI-ALL-0100 Nuclear Operating Fleet Administrative Procedure - Corrective Action Program Revision 30 DUKE-QAPD-001-A Duke Energy Corporation Topical Report - Quality Assurance Program Description - Operating Fleet Amendment 45 AD-EG-ALL-1132 Nuclear Operating Fleet Administrative Procedure - Preparation and Control of Engineering Changes Revision 26 AD-CP-ALL-0017 Radiological Groundwater Protection Revision 8 AD-EN-ALL-0045 Nuclear Operating Fleet Administrative Procedure - Nuclear Chemical Control Revision 13 AD-EG-RNP-1214 Robinson Unit 2 Administrative Procedure - Condition Monitoring of Structures Revision 8 SLR-RNP-IPAR-S501 Subsequent License Renewal Integrated Plant Assessment of the Reactor Containment Building Revision 1 SLR-RNP-IPAR-S502 Subsequent License Renewal Integrated Plant Assessment of the Reactor Auxiliary Building Revision 0 SLR-RNP-IPAR-S503 Subsequent License Renewal Integrated Plant Assessment of the Turbine Building Revision 0 SLR-RNP-IPAR-S504 Subsequent License Renewal Integrated Plant Assessment of the Yard Structures Revision 0 SLR-RNP-IPAR-S505 Subsequent License Renewal Integrated Plant Assessment of the Miscellaneous Structural Commodities Revision 0 SLR-RNP-OPEX-0100 Subsequent License Renewal Operating Experience Review Methodology and Results Revision 2 MWO 11781905 Structural Inspection of the 4 kV Non-Segregated Bus Duct Yard Support Structures / Structural Inspection of the Isolated Phase Bus Duct Yard Support Structures N/A MWO 11135808 Structural Inspection of Switchyard Relay Building and Switchyard and Transformer Structures N/A MWO 11658169 Structural Inspection of Manholes M-35 and M-36 N/A MWO 11136886 Structural Inspection of Containment Building Interior Structures/Commodities, Equipment Hatch Missile Shield Area, Personnel Access Hatch Area, and the Purge Inlet Valve Area N/A
42 MWO 11136887 Structural Inspection of Turbine Building N/A MWO 10056816 Structural Inspection of Fuel Oil Containment Structures N/A MWO 11743790 Structural Inspection of the Dedicated Shutdown Diesel Generator Building and Cooling Unit Structures N/A MWO 11658110 Structural Inspection of Radwaste Building N/A MWO 11136901 Structural Inspection of Fuel Handling Building N/A MWO 11783577 Structural Inspection of the Hot Machine Shop Building (BLDG-225)
N/A MWO 11782160 Structural Inspection of the Spent Fuel Pool Heat Exchanger Room (BLDG-215)
N/A MWO 11658091 Structural Inspection of Support for Fuel Oil Piping from Unit 1 Fuel Oil Storage Tanks to Unit 2 N/A MWO 11136889 Structural Inspection of Auxiliary Building and North Service Water Header Enclosure N/A MWO 11136890 Structural Inspection of the Control Room N/A MWO 20084177 Structural Inspection of N2 and H2 Storage Shed (BLDG-365)
N/A AR 00510935 Implement Process Improvement Related to Roof Leaks 1/23/2012 AR 02434297 CST: Inspect, Clean, and Apply Grout over Exposed CST Rebar 7/14/2022 AR 00380722 Repair of Switchyard Structures 2/10/2010 WO 20497750-03 Verify Structural Inspections - Containment Vessel 12/9/2024 WO 20694957-01 License Renewal Inspection of Vertical Fuel Oil Tank per AD-EG-ALL-1650 5/5/2025 WO 20532093-01 Verify Structural Inspections per EGR-NGGC-0351 - Dam 8//28/2024 WO 13516812-01 Verify Structural Inspections per EGR-NGGC-0351-Turbine Building 12/21/2021 WO 20094272-01 Verify Structural Inspections per AD-EG-ALL-1214 - Building 205 4/14/2019 AR 02397107 Crack Identified in Radwaste Building Ceiling 9/9/2021 AR 00744467 Monitor Turbine Building Slab for Settlement 4/19/2015 WO 20663497-01 Trend Groundwater and Lake Water per AD-EG-ALL-1214 4/14/2025 BCP-Duke-RNP-2023-RPT-001 H. B. Robinson Nuclear Power Plant Containment In-Service Inspection Program Inaccessible Concrete Condition Evaluation Plan 1/19/2024 OST-013 Robinson Unit 2 Technical Procedure (Testing) - Weekly Checks and Operations Revision 185
43 AR 01990963 Boric Acid in Waste Gas Decay Tank Room Below the Spent Fuel Pool 1/13/2016 WO 13412561-01 Visually Inspect LLD-01 through LLD-12 Lines for Boric Acid/Blockage 9/24/2015 AR 00696522 LLD-12 Quarter Cup Dry White Boric Acid Build Up 7/5/2014 AR 121653121653White crystalline residue (dry) was found on the ceiling of the waste decay tank room and on items located directly under the area of the leak N/A AR 617835617835A new area of dry boric acid has been identified in the Waste Gas Decay Tank Room 7/23/2013 AR 2040345-01 On 06/21/16 water was noted dripping from the ceiling and north wall of the Waste Gas Decay Tank Room 6/21/2016 WO 13412561-01 Visually inspect LLD-01 through LLD-12 Linces for Boric Acid/Blockage 09/24/2015 WO 20098467-01 LLD-01, Run Tubing per Sketch FMS-164 10/27/2017 AR 02191697 Electrical Pull Box with Water and Rust Damage 3/15/2018 AR 00750869 North Service Water Underground Header Inspection 5/25/2015 AR 00708807 Surface Water Erosion North Unit 1 Circulating Water Intake Structure 9/18/2014 AR 00735748 Add Repair to Turbine Bay Sink Hole in 15W12 3/3/2015 AR 00751476 Design Engineering to Evaluate the As Found Condition for IWL 5/28/2015 WO 13533477-01 Inspection and Repair of Outside Concrete at Azimuth 337° N/A AR 00751724 Repair Spalled Concrete in the North Intake Bay 5/29/2015 AR 02264022 Investigate/Repair Concrete Spalling on Reactor Auxiliary Building Wall 3/20/2019 AR 02276486 Degraded Concrete on Stilling Basin Slab H. B. Robinson Steam Electric Plant, Unit 2 (RNP) Dam 6/10/2019 WR 20188780 Containment Vessel Grout Repair 11/14/2020 AR 00730182 North Demineralizer Bunker Inspection 1/29/2015 AR 01987771 Pipe Support on Line 1-WD-152R-186 Has Fastener Corrosion 1/2/2016 AR 00740082 A Boric Acid Storage Tank Southwest Heater (BA-TNK-A-HTR-B) Flange Bolts As Found Condition 3/25/2015 AR 02019765 2015 Ground Water Monitoring Results 4/12/2016 WR 20130731 Junction Box for Emergency Lighting Unit is Corroded 1/7/2019 AR 02550640 License Renewal Structural Inspections for RWST not documented 4/10/2025 WO 20721721 Inspect and Refurbish RWST Anchorage N/A
44 EQE Calculation 52212-C-065 Atmospheric Storage Tanks / Refueling Water Storage Tank (RWST)
Revision 0 During the audit, the staff verified the applicants claim that the preventive actions and monitoring and trending program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the scope of program, parameters monitored or inspected, detection of aging effects, 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-SLR 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-SLR Report AMP.
During the audit, the staff made the following observations:
The staff noted that no explicit Table 2 items are presented in the SLRA for pipe whip restraints, jet impingement shields, transmission towers, and tube tracks.
The staff noted that Enhancements 2, 5, 7, 10, and 12 to the Structures Monitoring program may be implemented through additional program elements described in GALL-SLR Report.
The staff noted inconsistencies in the descriptions of Alkali-Silica Reaction in Enhancement 6 to the Structures Monitoring program and SLRA Sections 3.5.2.2.2.1 and 3.5.2.2.2.3.
The staff was unable to verify which Table 1 AMR item is used to address AMR Item 3.3.1-111, which relates to the aging effect of loss of material for steel components of new fuel storage racks, since this Table 1 AMR item was not cited in the SLRA.
The staff noted from OE documents (AR 01990963 and other associated documents on boric acid leakages) that significant boric acid leakages have been observed in multiple areas of the Waste Gas Decay Tank room located below the Spent Fuel Pool. In addition, the staff identified that the existing Structures Monitoring program does not have implementing procedures to manage aging effects of boric acid attack on reinforced concrete structures, as recommended in the aging management program template of the EPRI Technical Report 3002007348.
The staff also audited the description of the SLRA AMP, Structures Monitoring, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
The staff made the following observations during walkdowns:
During the walkdown of the Turbine Building, the staff observed cracks at the joint where the column meets the intersecting slab.
During the walkdown of the Reactor Containment Building, the staff observed areas of efflorescence on the exterior surface of the cylinder wall.
During the walkdown of the Reactor Auxiliary Building, the staff noted that a catch basin is not installed at the Spent Fuel Pit Leak Detection Header Isolation and the boric acid buildup has been removed as described in the OE documents provided in the ePortal.
During the walkdown of the Refueling Water Storage Tanks, the staff observed corrosion on the nuts in the foundation anchorage bolting. The staff noted in AR 02550640 that there are no operability issues resulting from the corrosion.
45 During the walkdown of the SCs within the scope of subsequent license renewal, the staff noted that the observed degradations were found to be consistent with the OE for which the GALL-SLR Report program was evaluated.
SLRA AMP B.2.1.35, Inspection of Water-Control Structures Associated with Nuclear Power Plants Summary of Information in the Application. The SLRA states that AMP B2.1.35, 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-SLR Report AMP XI.S7, Inspection of Water-Control Structures Associated with Nuclear Power Plants. 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. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.S7 Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP Evaluation Report Revision 0 UFSAR H. B. Robinson Steam Electric Plant, Unit 2 Updated Final Safety Analysis Report (UFSAR); NRC Docket No. 50-261 Revision 30 AD-EG-ALL-1214 Nuclear Operating Fleet Administrative Procedure - Condition Monitoring of Structures Revision 1 AD-PI-ALL-0100 Nuclear Operating Fleet Administrative Procedure - Corrective Action Program Revision 30 DUKE-QAPD-001-A Duke Energy Corporation Topical Report - Quality Assurance Program Description - Operating Fleet Amendment 45 AD-EN-ALL-0045 Nuclear Operating Fleet Administrative Procedure - Nuclear Chemical Control Revision 13 AD-EG-ALL-1132 Nuclear Operating Fleet Administrative Procedure - Preparation and Control of Engineering Changes Revision 26 AD-EG-RNP-1214 Robinson Unit 2 Administrative Procedure - Condition Monitoring of Structures Revision 8 SLR-RNP-AMPR-XI.S6 Structures Monitoring AMP Evaluation Report Revision 0 SLR-RNP-IPAR-S504 Subsequent License Renewal Integrated Plant Assessment of the Yard Structures Revision 0 MMM-016 H. B. Robinson Steam Electric Plant, Unit No. 2 Plant Operating Manual - Torquing Procedure Revision 40 CPL-XXXX-C-001 Carolina Power & Light Company - Specification for Procurement of Miscellaneous Structural Fasteners (Safety Related and Non-Safety Related)
Revision 0 CM-407 Robinson Unit 2 Technical Procedure (Maintenance) - Concrete Expansion Anchor Bolt Installation Revision 22
46 CPL-HBR2-M-046 Progress Energy Nuclear Generation Group - Specification for Procurement of Pipe and Piping Related Products (ANSI B31.1 Only) (Safety Related and Non-Safety Related)
Revision 3 CPL-XXXX-M-004 Carolina Power & Light Company - Specification for Procurement of Piping Support Components Revision 0 MMM-052 H. B. Robinson Steam Electric Plant, Unit No. 2 Plant Operating Manual - Installation and Inspection of Equipment, Supports, and Components Revision 13 MWO 10852383 Lake Robinson Dam Inspection & Report N/A MWO 20193336 Verify Structural Inspection in accordance with AD-EG-ALL-1214, Intake North Bay N/A MWO 20193338 Verify Structural Inspection in accordance with AD-EG-ALL-1214, Intake Middle Bay N/A MWO 20193339 Verify Structural Inspection in accordance with AD-EG-ALL-1214, Intake South Bay N/A AR 02043826 East Tainter Gate Chains Binding 7/7/2016 AR 00245643 Corrective Maintenance Required for the Tainter Gates 9/6/2007 AR 02034590 2016 License Renewal Dam Inspection Findings (Submerged Portion) 6/2/2016 AR 00542230 OE36112 - (Update to OE34348) Alkali-Silica Reaction (ASR) 6/11/2012 AR 00338322 Potential Impact of Degraded Intake Structure Support 6/1/2009 OP-218 Robinson Unit 2 Technical Procedure (Operating) - Lake Robinson Spillway Equipment Revision 27 PMCR 02177534 Revise the Frequency of PMID 45675-01, Lake Robinson Dam Inspection and Report, from 5 years to 2 years N/A PMCR 02501225 Dam Frequency Chage to 5 years 7/22/2024 N/A Robinson Nuclear Plant Spillway - 2022 Underwater Inspection Summary 5/2022 N/A Report of Spillway Gates Inspection and Functional Testing -
Duke Energy Robinson Nuclear Plant 9/16/2022 N/A Robinson Cooling Lake Dam - 2022 Independent Consultant Dam Inspection Report - Draft 10/20/2022 AD-EG-RNP-1650 Robinson Unit 2 Administrative Procedure - License Renewal Aging Management Activities Revision 7 PM-569 Dam, Tainter Gate and Spillway Inspection Revision 2 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 elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP. In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to verify whether it was consistent with the corresponding program elements of the GALL-SLR Report AMP. The staff will consider issuing RAIs or use a voluntary SLRA supplement in order to obtain
47 the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL-SLR Report AMP.
During the audit, the staff made the following observations:
The staff noted that a provision on visual inspection of submerged structural elements at least once every 5 years is not found in the SLRA.
The staff also audited the description of the SLRA AMP, Inspection of Water-Control Structures Associated with Nuclear Power Plants, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
During the on-site audit, the staff performed walkdowns of the Intake Structure and Lake Robinson Dam. The staff made the following observations during walkdowns:
During the walkdown of Lake Robinson Dam, the staff observed areas of efflorescence on the spillway concrete walls and piers.
SLRA AMP B.2.1.36, Protective Coating Monitoring and Maintenance Summary of Information in the Application. The SLRA states that AMP B.2.1.36, Protective Coating Monitoring and Maintenance, is an existing program with enhancements that will be consistent with the program elements in GALL-SLRReport AMP XI.S8, Protective Coating Monitoring and Maintenance, as modified by SLR-ISG-Structures-2021-03-STRUCTURES, Updated Aging Management Criteria for Structures Portions of the Subsequent License Renewal Guidance.
Audit Activities. 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.
Relevant Documents Reviewed Document Title Revision / Date RPN-C/CONT-1003 RNP Containment Coatings Exempt Log Rev 16 SLR-RNP-AMPR-XI.S8 Protective Coatings Monitoring and Maintenance AMP Evaluation Report Rev 0 AD-EG-ALL-1640 Nuclear Coatings Program Implementation Rev 5 AD-EG-ALL-1641 Primary Containment Coatings Condition Assessment Rev 2 AR:02241647 Action Request Details Report: Reactor Containment Sump Coatings 11/06/18 AR:02357174 Action Request Details Report: Containment Sump Coating Degradation 11/10/20 AR:02233968 Action Request Details Report: Degraded Coatings Identified in the CV by Coatings Walkdown 09/28/18 AR:02358785 Action Request Details Report: R232 Containment Coatings Condition 11/19/20 AR:02450622 Action Request Details Report: R2R33 Coatings Condition Assessment Revealed Unqualified Coatings 11/23/22
48 Document Title Revision / Date WO 20570529 Work Order Rev 01 WO 20570527 Work Order Rev 01 WO 20570525 Work Order Rev 01 WO 20570524 Work Order Rev 01 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, Protective Coating Monitoring and Maintenance, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.E1, Electrical Insulation for Electrical Cables and Connections Not Subject to10 CFR 50.49 Environmental Qualification Requirements. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.
Audit Activities. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.E1 Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP Evaluation Report Revision 1 UFSAR section 18.1.33 Non-EQ Insulated Cables and Connections Program Revision 29 RNP-L/LR-0390, Att. G License Renewal Aging Management Program for Non-EQ Insulated Cables and Connections Revision 4 AR85019 License Renewal Transition Package Non-EQ Cable Aging Management Program 8/12010 WO 11691073 01 E, BLDG-205, Walkdown Non-EQ Cable in the Aux Building Printed 4/10/2025
49 WO 20648371 Walkdown Non-EQ Cable in the Turbine Building Printed 4/15/2025 WO 11691057 Walkdown Non-EQ Cable in CV Printed 4/15/2025 PM-RQ 18064-22 Walkdown Non-EQ Cable in the Aux Building Printed 4/10/2025 AD-EG-RNP-1615 Cable Aging Management Program Revision 0 EGR-NGGC-0507 Cable Aging Management Program Revision 4 PM-519 Tan-Delta Testing of Aged/Wetted Cables Revision 5 AD-EG-ALL-1615 Cable Aging Management Program - Implementation Revision 5 649975 Cable Aging Management Program 9/10/2014 00649975 Focused Self-Assessment Cable Aging Management 4/24/2015 WO 20057811-01 Walkdown Non-EQ Cable in the Aux Building 7/05/2018 WO 20057812 01 E, CV, Walkdown Non-EQ Cable in CV 10/02/18 WO 20057813 01 E, Turb-Bldg, Walkdown Non-EQ Cable in the Turbine Building 09/05/2017 2167161 License Renewal Aging Management Programs 11/15/2018 AR 02531400 Further Research needed for Suspected ALE in RAB Pipe Alley 1/23/2025 WO 1126106-01 Inspect Cables in R025 For Degradation 1/19/2009 WO 1126106-02 Inspect Cables in R025 For Degradation 1/13/2010 WO 1126106-03 Inspect Cables in R025 For Degradation 1/13/2010 EC 0000252696 Engineering Change: Service Water Pump Cable Project 157 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
During the audit, the staff made the following observations:
During its review of Robinson SLRA AMP B2.1.37 and the basis document SLR-RNP-AMPR-XI.E1 Revision 1, the staff identified that the program description and certain elements of the AMP were not consistent with the corresponding element in GALL-SLR Report AMP XI.E1. Specifically, the program description element for AMP B2.1.37 did not include the possibility of using scaffolding or other means (e.g., opening of
50 junction boxes, pull boxes, accessible pull points, panels, terminal boxes, and junction boxes) to assess cable and connector electrical insulation aging degradation in potential adverse localized environments. In response to the staffs breakout question, the applicant stated that scaffolding or other means (e.g., opening of junction boxes, pull boxes, accessible pull points, panels, and terminal boxes) can be used to help assess cable and connector electrical insulation aging degradation in potential adverse localized environments (ALEs). The applicant will revise the SLRA AMP B2.1.37 and the basis document SLR-RNP-AMPR-XI.E1 for consistency with GALL-SLR Report AMP XI.E1 in a future supplement. The applicant will provide the revised SLRA AMP B2.1.37 in a future supplement.
The staff identified that the Robinson basis document SLR-RNP-AMPR-XI.E1 Rev 1, Parameters Monitored or Inspected element did not 1) define the most limiting temperature, radiation, and moisture environments and their basis, and 2) state if Robinson will inspect for ALEs for each of the most limiting cable and connection electrical insulation plant environments (e.g., caused by temperature, radiation, moisture, or contamination). In response to the staffs breakout question, the applicant stated that 1) the most limiting temperature, radiation, and moisture environments and their bases will be defined in AMP implementation documents (e.g., a contractors plan for initial SLR inspection), and a supplement to the Robinson SLRA AMP B2.1.37 will include an enhancement to inspect ALEs for each of the most limiting cable and connection electrical insulation plant environments (e.g. caused by temperature, radiation, moisture, or contamination). The applicant will revise the SLRA AMP B2.1.37 for consistency with GALL-SLRReport AMP XI.E1 in a future supplement.
The staff identified that the Robinson Program basis document SLR-RNP-AMPR-XI.E1 Rev 1, Detection of Aging Effects element did not to include the evaluation of cable and connection insulation to confirm that the dispositioned corrective actions continue to support in-scope cable and connection intended functions during the subsequent period of extended operation. In response to the staffs breakout question, the applicant stated that the Detection of Aging Effects element in SLR-RNP-AMPR-XI.E1 Rev 1, will be revised for consistency with GALL-SLRReport AMP XI.E1. The applicant will also revise the program description of SLRA AMP B2.1.37 to add an enhancement for the evaluation of cable and connection insulation to confirm that the dispositioned corrective actions continue to support in-scope cable and connection intended functions during the subsequent period of extended operation, in a future supplement.
The staff identified that cables inside the trays covered with flame-retardant coating are inaccessible, but they are not discussed in the basis document SLR-RNP-AMPR-XI.E1 Rev 1 or in any other Robinson electrical AMPs. In response to the staffs breakout question, the applicant stated that if cables covered by fire-retardant material are found in an ALE, they will be assessed by other methods, e.g. testing, referring to similar cables with uncovered jackets in same or more severe environments, and/or potential temporary removal of the fire-retardant coating for improved accessibility. The applicant will revise the basis document SLR-RNP-AMPR-XI.E1 Rev 1 and SLRA AMP B2.1.37 to include the inspection of cables covered with fire-retardant material. The applicant will provide the revised SLRA AMP B2.1.37 in a future supplement.
The staff also audited the description of the SLRA AMP, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA AMP, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. The staff
51 will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
The staff made the following observations during walkdowns:
During the on-site audit, the staff performed a walkdown of various in-scope electrical cables and connections managed by AMP B2.1.37. The staff did not observe any signs of adverse or abnormal age-related degradation with in-scope electrical insulation for electrical cables and connections not subject to 10 CFR 50.49 environmental qualification requirements.
The staff also reviewed pictures of cables covered with fire-retardant material and did not notice any signs of age-related degradation.
The staff noticed that there are service water cables in a trench above service water piping. The staff asked the applicant if there was a means of prevention of water intrusion in the trench or a provision (guidance or designs) for water drainage from the trench. The applicant provided the service water trench drawings and the EC 0000252696, Revision 157. The EC stated that The newly installed 10 trench sections have weep holes to allow water to enter and to drain out. The trench also includes cable supports allowing water to drain underneath the cable and to prevent the cables from becoming dams.
SLRA AMP B.2.1.38, Electrical Insulation 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 SLRA states that AMP B2.1.38, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, is an existing program that will be consistent with the program elements in GALL-SLR Report AMP XI.E2, Electrical 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 program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.
Audit Activities. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.E2 Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits AMP Evaluation Report Revision 0 UFSAR section 18.1.34 Aging Management Program for Non-EQ Electrical Cables Used in Instrumentation Circuits Revision 29 UFSAR section 18.1.35 Aging Management Program for Neutron Flux Instrumentation Circuits Revision 29 RNP-L/LR-0390, Att. X License Renewal Aging Management Program for Non-EQ Electrical Cables Used in Instrumentation Circuits Revision 4
52 RNP-L/LR-0390, Att. AA License Renewal Aging Management Program for Non-EQ Electrical Cables Used in Neutron Flux Instrumentation Circuits Revision 4 MWO 11284017 Work Order Task Instructions Perform Condition Monitoring of Cables, Connectors and Detector for N-51 Revision 0 MWO 11284029 Work Order Task Instructions Perform Condition Monitoring of Cables, Connectors and Detector for N-52 Revision 1 PM-496 Source Range Cable/Connector/Detector Condition Monitoring (Shutdown)
Revision 3 LP-256-1 Containment High Range Radiation Monitor (Area) RMS 32B Revision 3 LP-256 Containment High-Range Radiation Monitor (Area) RMS 32A Revision 17 PM-498 Power Range Cable/Connector/Detector Condition Monitoring (Shutdown)
Revision 3 PM-497 Intermediate Range Cable/Connector/Detector Condition Monitoring (Shutdown)
Revision 3 02332207 RNP License Renewal Self-Assessment 11/08/2022 WO 11410926 01 R-32A&B Review Calibration Results 12/17/2008 WO 20175976 01 E, R-32A&B Review Calibration Results for Age Degradation 12/11/2018 EC 409422 R-32A & R-32B TIC (Thermally Induced Currents) Cable Replacement Revision 8 AR 316141316141Unexpected Degradation in NIS Power Range Detectors 07/03/2012 ML14017A289 H.B. Robinson Steam Electric Plant, Unit 2 Aging Management Program Effectiveness Audit (TAC NO. ME6075) 8/5/2014 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report.
During the audit, the staff made the following observations:
During its review of Robinson SLRA AMP B2.1.38, the staff identified that Robinson basis document SLR-RNP-AMPR-XI.E2 for SLRA Section B2.1.38 referred to Oconee Nuclear Station (ONS) AMP instead of Robinson AMP for the description of the ALEs and their identification in the Scope of Program element. In response to the staffs breakout question, the applicant will revise Robinson basis document SLR-RNP-AMPR-XI.E2 by replacing ONS AMP with Robinson AMP for the ALEs and their identification.
The staff identified that Robinson basis document SLR-RNP-AMPR-XI.E2 did not provide a definition for an unacceptable indication because SLR-RNP-AMPR-XI.E2, Acceptance Criteria, does not use the term elsewhere in that section. In response to the staffs breakout question, the applicant will revise Robinson AMP basis document SLR-RNP-AMPR-XI.E2 to state that An unacceptable indication is defined as a noted
53 condition or situation that, if left unmanaged, could potentially lead to a loss of intended function.
The staff also audited the description of the SLRA AMP, Electrical Insulation for Electrical Cables and Connections Not Subject to 10CFR 50.49 Environmental Qualification Requirements, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
The staff made the following observations during walkdowns:
During the walkdown of the in-scope electrical cables and connections managed by AMP B2.1.38, the staff did not observe any signs of adverse or abnormal age-related degradation with in-scope electrical insulation for electrical cables and connections not subject to 10 CFR 50.49 environmental qualification requirements.
SLRA AMP B.2.1.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.39, Electrical Insulation for Inaccessible Medium-Voltage 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-SLR Report AMP B2.1.39, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG-2021-04-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of Subsequent License Renewal Guidance. 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 June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.E3A Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP Evaluation Report Revision 0 AD-EG-ALL-1615 Cable Aging Management Program - Implementation Revision 5 PD-EG-ALL-1615 Cable Aging Management Program Revision 2 AP-053 Severe Weather Response Revision 10 PM-519 Tan Delta Testing of Aged/Wetted Cables Revision 5 AR 00649975 Focused Self-Assessment Cable Aging Management January 24, 2023 AR 305575305575Quick Hit Self-Assessment Report - License Renewal Implementation November 2009
54 AR 00686039 Offsite Power Transformer Phase Lost October 20, 2015 AR 00618826 Manholes M-20 & M-27 Have Submerged CW Cables August 26, 2013 AD-EG-RNP-1650 License Renewal Aging Management Activities Revision 7 MWO 12095480 / PMID-RQ88690-02 Perform Manhole Inspection of M-35 and M-36 Revision 0 EPRI 1020805 Plant Support Engineering: Aging Management Program Guidance for Medium-Voltage Cable Systems for Nuclear Power Plants Final Report, June 2010 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 elements of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP, as modified by SLR-ISG-2021 ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of Subsequent License Renewal Guidance.
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 SLRA or by the staff during the audit will be consistent with the corresponding program element inthe GALL-SLR Report AMP, as modified by SLR-ISG-2021-04-ELECTRICAL.
During the audit, the staff made the following observations:
During the walkdown, the staff discussed the exception to the GALL-SLR guidance for inaccessible medium-voltage cables that have been replaced within 20 years of entering the subsequent period of extended operation (aka new cables). The staff verified the program requirement to test these new cables on a periodic ten-year frequency versus the six-year frequency for older cables. The program will test new cables on a ten-year periodicity, starting at the subsequent period of extended operation.
The staff also audited the description of the SLRA AMP, Electrical Insulation for Inaccessible Medium-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report, as modified by SLR-ISG-2021-04-ELECTRICAL.
SLRA AMP B.2.1.40, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.40, Electrical Insulation for Inaccessible Instrument And Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL-SLR Report AMP XI.E3B, Electrical Insulation for Inaccessible Instrument And Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG-2021-04-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of Subsequent License Renewal Guidance. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new
55 program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.
Audit Activities. An on-site audit was performed June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.E3B Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP Evaluation Report Revision 0 AD-EG-ALL-1615 Cable Aging Management Program - Implementation Revision 5 AP-053 Severe Weather Response Revision 10 MMM-053 Electrical Installation Revision 12 ML22349A145 Safety Evaluation Report - Oconee Nuclear Station Issued December 2022 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 SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP, as modified by SLR-ISG-2021-04-ELECTRICAL.
The staff also audited the description of the SLRA AMP, Electrical Insulation for Inaccessible Instrument and Control Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report, as modified by SLR-ISG-2021-04-ELECTRICAL.
SLRA AMP B.2.1.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.41, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program with exceptions that will be consistent with the program elements in GALL-SLR Report AMP XI.E3C, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, as modified by SLR-ISG-2021-04-ELECTRICAL, Updated Aging Management Criteria for Electrical Portions of Subsequent License Renewal Guidance. 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 June 3, 2025, to June 5, 2025. 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.
56 Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.E3C Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Revision 000 AP-053 Severe Weather Response Revision 10 MMM-053 Electrical Installation Revision 12 AD-EG-ALL-1615 Cable Aging Management Program - Implementation Revision 5 AR 00649975 Focused Self Assessment Cable Aging Management Printed 1/24/2023 AR 00618826 Manholes M-20 & M-27 Have Submerged CW Cables 8/26/2013 AR 00576676 Water Present In Manholes M-35 & M-36 2/5/2016 Task Instructions WO 11658169 Removal of Manhole Covers M-35 and M-36 Revision 00 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria, is consistent with the program elements of the GALL-SLR Report AMP, as modified by SLR-ISG-2021-04-ELECTRICAL.
The staff also verified the applicants claim that aspects of the detection of aging effects and corrective actions program elements not associated with the exceptions identified in the SLRA or by the staff during the audit are consistent with the corresponding program elements inthe GALL-SLR Report AMP, as modified by SLR-ISG-2021-04-ELECTRICAL.
During the audit, the staff made the following observation:
Table 3.6.2-2, Electrical and Instrumentation and Controls - Cable and Connections -
Aging Management Evaluation, AMR item 5323 lists Note A for this AMP. Note A is defined as Consistent with NUREG-2191 item for component, material, environment, and aging effect. AMP is consistent with NUREG-2191 AMP. The Robinson B.2.1.41 AMP lists two exceptions taken, and AMR item 5323 should list this as Note B for this AMP. The applicant addressed this item by supplementing the application to change the Note to indicate Note B.
The staff also audited the description of the SLRA AMP, Electrical Insulation for Inaccessible Low-Voltage Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report, as modified by SLR-ISG-2021-04-ELECTRICAL.
SLRA AMP B.2.1.42, Metal Enclosed Bus Summary of Information in the Application. The SLRA states that AMP B2.1.42, Metal Enclosed Bus, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.E4, Metal Enclosed Bus. At the time of the audit, the
57 applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the applicants basis document, available procedures, and referenced documents.
Audit Activities. An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.E4 Metal Enclosed Bus AMP Evaluation Report Revision 1 SLR-RNP-AMPR-XI.S6 Structures Monitoring AMP Evaluation Report Revision 0 UFSAR section 18.1.37 Aging Management Program for Bus Ducts Revision 29 TE-MN-ALL-0211 Performing Thermographic Inspections Revision 3 AR 02332207-22 License Renewal Aging Management Program Effectiveness Assessment Revision 0 AR 02306205 OE463274R20191206 Automatic Reactor Scram Due to Generator T 9/17/2020 PM-143 Auxiliary Transformer Bus Duct Inspection Revision 15 PM-144-2 115KV Startup Transformer To 4KV Bus 8 Bus Duct Inspection Revision 1 PM-144-1 115KV Startup Transformer To 4KV Bus 6 and Bus 7 Bus Duct Inspection Revision 4 PM-144-6 4KV Bus 3 Cubicle 17 to 4KV Bus 8 Cubicle 45 Bus Duct Inspection Revision 1 PM-128 Main Generator Isophase Bus Duct Inspection Revision 15 PM-013 480V Nonseg Bus Duct Inspection Revision 6 PM-144-3 230KV Startup Transformer To 4KV Bus 7 Bus Duct Inspection Revision 1 PM-144-4 230KV Startup Transformer To 4KV Bus 8 and Bus 9 Bus Duct Inspection Revision 2 AD-EG-RNP-1650 License Renewal Aging Management Activities Revision 7 AR 02306205-06 Automatic Reactor Scram Due To Generator Trip from Ground Relay 5/27/2020 WO 20156682 Clean the insulators on the Isophase Bus 9/12/2023 AR 02384889 PMAD - 480V Busway visual inspection - ER 1 NON SPV 8/4/2021 AR 02362309 HNP Reactor Trip 9/19/2023 AR 02112964 Additional Testing and Maintenance on Isophase Bus 3/29/2018
58 AR 02336412 Gaps identified during OEEV - CNS Oil in Generator 6/23/2021 AR 02332207 License Renewal Self-Assessment 3/30/2023 During the audit, the staff verified the applicants claim that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report after implementation of the identified enhancements.
During the audit, the staff made the following observations:
During its review of Robinson SLRA AMP B2.1.42, the staff identified that the Metal Enclosed Bus (MEB) AMP Basis document SLR-RNP-AMPR-XI.E4 Parameters Monitored or inspected, for AMP B2.1.42 did not discuss any segments of the MEB that may be considered inaccessible due to close proximity to other permanent structures, as provided in NUREG 2191 AMP XI.E4. The applicant stated that Robinson does not have any MEB segments that are considered inaccessible due to close proximity to other permanent structures.
The staff also audited the description of the SLRA AMP, Metal Enclosed Bus, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
The staff made the following observations during walkdowns:
During the on-site audit, the staff performed a walkdown of in-scope MEB sections. The staff verified how Robinson checks for water intrusion and other internal inspections or tests in their MEB procedures. The staff also noted missing bolts on MEBs at the Unit Auxiliary Transformer. The applicant wrote a work order (20289217) to replace the bolts.
SLRA AMP B.2.1.43, Fuse Holders Summary of Information in the Application. The SLRA states that AMP B2.1.43, Fuse Holders, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP XI.E5, Fuse Holders. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this enhanced program, and the staffs audit addressed only the applicants basis document, implementing procedures, and OE documents.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the program. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.E5 Fuse Holders AMP Evaluation Report Revision 0 UFSAR section 18.1.36 Fuse Holder Program Revision 29
59 WO 11350429 Perform Thermography on DSDG Fuse 3/21/2024 TE-MN-ALL-0211 Performing Thermographic Inspections Revision 3 11351332 Perform Thermography on DSDG Fuse 3/17/2009 13526850 EL, Perform Thermography on DSDG Fuse 8/24/2017 WO 20179853 Investigate Fuse 44 (CRD-2BD) For Loose Connection 6/20/2018 20151828-01 Repair Blowdown PLC Power Supply Will Not Reset 08/03/17 20350097 EL: FU2-E-07727-01, Remove Degrade Fuse Finger Safety Clips 8/02/2021 WO 20179854 Investigate Fuse 54 (CRD-2BD) For Loose Connection 6/20/2018 AR 02288331 Fuse Clip Insertion/Removal Device Degraded 8/27/2019 AR 02134080 Thermography Discovered Temperature Differences on Fuses 7/5/2017 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report after implementation of the identified enhancements.
The staff also audited the description of the SLRA AMP, Fuse Holders, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.2.1.44, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The SLRA states that AMP B2.1.44, 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-SLR 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 June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date
60 SLR-RNP-AMPR-XI.E6 Electrical Cable Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements AMP Evaluation Report Revision 000 AD-EG-ALL-1615 Cable Aging Management Program - Implementation Revision 6 EPRI Technical Report 3002010401 Long-Term Operations: Subsequent License Renewal Electrical Handbook April 2018 WR 20079824 ERFIS Trouble Alarm 6/26/2018 AR 02139892 Unexpected Alarm in Control Room Printed 9/13/2023 WO 20287504 Thermography - Intake Motors & MCC-7 Printed 9/13/2023 WO 20361322 MCC-7(1G) Possible Loose Connection Printed 9/13/2023 AR 02299935 MCC-7(1G) Possible Loose Connection Printed 9/13/2023 During the audit, the staff verified the applicants claim that the scope of program preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
The staff made the following observation during walkdowns:
The staff questioned whether the program has controls in place for an unacceptable condition or situation identified in the selected sample and whether a determination will be made as to whether the same condition or situation is applicable to other connections that are not tested. The GALL-SLR requires this determination in XI.E6. The applicant plans to supplement the application to include extent-of-condition acknowledgement per the GALL-SLR XI.E6 program description.
SLRA AMP B.3.1, Fatigue Monitoring Summary of Information in the Application. The SLRA states that AMP B3.1, Fatigue Monitoring, is an existing preventive program with enhancements that is consistent with the program elements in GALL-SLR AMP X.M1, Fatigue Monitoring. 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.
Relevant Documents Reviewed
61 Document Title Revision / Date N/A OE Data from New or Different Aging Effect Review 5/8/2025 N/A H.B. Robinson Unit 2 SLRA Operating Experience Review 5/8/2025 SLR-RNP-OPEX-0100 Subsequent License Renewal Operating Experience Review Methodology and Results Revision 2 SLR-RNP-AMPR-X.M1 Fatigue Monitoring AMP Evaluation Report Revision 2 3/17/2025 AR 00180925 Repair, Replace, or Reanalyze 3 AFW to FW Connections 1/13/2006 AR 02486489 Transient Accounting (PLP-109 Att. 1) Inaccuracies (Fatigue Monitoring Program) 9/12/2023 AR 00508590 RIS 2011-14 Metal Fatigue Analysis Performed by Computer 1/11/2012 AR 00313617 RIS 2008-30 Fatigue Analysis of Nuclear Power Plant Components 1/8/2009 AD-EG-ALL-1632 Integrated Fatigue Management Revision 3 8/16/2022 PLP-109 Cycle and Transient Monitoring Revision 13 CPL-MC000-TR-LR-000009 Robinson Nuclear Plant Subsequent License Renewal:
Environmentally Assisted Fatigue Evaluations Summary Report Revision 0 3/18/2025 CPL-RV000-TR-CF-000001 H.B. Robinson Unit 2 Subsequent License Renewal: Reactor Vessel Outlet Nozzle to Shell Weld Flaw Tolerance Reconciliation Revision 0 December 2024 WCAP-16168-NP-A Risk-informed Extension of the Reactor Vessel In-service Inspection Interval Revision 3 October 2011 PWROG-17031-NP-A Update for Subsequent License Renewal: WCAP-15388-A, A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants Revision 1 May 2020 Structural Integrity Associates (SIA) 1501603.325 Charging Nozzle Flaw Tolerance Evaluation Revision 0 9/24/2024 WCAP-18901-P H.B. Robinson Unit 2 Subsequent License Renewal:
Pressurizer Surge Nozzle to Surge Line Weld and Hot Leg Surge Nozzle to Surge Line Weld Flaw Tolerance Evaluations Utilizing ASME Section XI Appendix L Methodology Revision 0 WCAP-17830-P Determination of Acceptable Baffle-Former Bolting for H. B.
Robinson Unit 2 Revision 2-A 4/6/2023
62 During the audit, the staff verified the applicants claim that the preventive actions program element of the SLRA AMP will be consistent with the corresponding element of the GALL-SLR Report AMP after implementation of the identified enhancements.
In addition, the staff found that for the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL-SLR 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-SLR Report AMP.
During the audit, the staff made the following observations. Enhancement 1 of the program indicates that the program will be enhanced to require that monitoring and tracking of transient cycles associated with the ASME Code,Section XI, Appendix L analysis be performed between the inspections for each of the ASME Code,Section XI, Appendix L locations. In comparison, SLRA Section 4.3.4 regarding environmentally assisted fatigue (EAF) analysis indicates that for the reactor vessel outlet nozzle to shell weld, the applicant uses a flaw tolerance analysis per ASME Code,Section XI, Appendix A to manage the aging effect of EAF.
However, it is not clear to the staff whether Enhancement 1 of the program includes the monitoring and tracking of transient cycles associated with the Appendix A flaw tolerance analysis for the reactor vessel outlet nozzle weld.
The staff also audited the description of the SLRA AMP, Fatigue Monitoring, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.3.2, Neutron Fluence Monitoring Summary of Information in the Application. The SLRA states that AMP B3.2, Neutron Fluence Monitoring, is an existing program that is consistent with NUREG-2191, Chapter X.M2, Neutron Fluence Monitoring, as modified by SLR-ISG-2021-02-MECHANICAL, Updated Aging Management Criteria for Mechanical Portions of Subsequent License Renewal Guidance, Interim Staff Guidance.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-X.M2 Neutron Fluence Monitoring AMP Evaluation Report Revision 1 WCAP-18751-NP Analysis of Ex-Vessel Neutron Dosimetry from H.B. Robinson Unit 2 - Cycle 32 March 2022 AR 2048737 Fleet Reactor Vessel Integrity Program QHSA AR 2391188 Incorrect TS Fig. 3.4.3-2 PT Limit Cooldown Curve
63 AR 485877485877Error found in regulatory submittal 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 SLRA AMP are consistent with the corresponding elements of the GALL-SLR Report AMP.
The staff also audited the description of the SLRA AMP, Neutron Fluence Monitoring, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
SLRA AMP B.3.3, Environmental Qualification of Electric Equipment Summary of Information in the Application. The SLRA states that AMP B3.3, Environmental Qualification of Electric Equipment, is an existing program with enhancements that will be consistent with the program elements in GALL-SLR Report AMP X.E1, Environmental Qualification of Electric Equipment. 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, available procedures, and referenced documents.
Audit Activities. An on-site audit was performed June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-X.E1 Environmental Qualification of Electric Equipment AMP Evaluation Report Rev. 001 AD-EG-ALL-1612 Environmental Qualification (EQ) Program Rev. 9 AD-EG-ALL-1117 Design Analyses and Calculations Rev. 10 TMM-036 Environmental Qualified (EQ) Electrical Equipment Required Maintenance Rev. 51 GID/R87038/0001 Generic Issues Document Environmental Qualification Rev. 11 AR 02137576 EQ Self-assessment AFI #3 - EQDPs require revisions 07/18/2017 AR 02150104 Rosemount 1154 Transmitter EQ Qualified Life Revision 9/12/2017 AR 00750856 Work Orders Not Planned / Scheduled to Support EQ Compliance 05/25//2015 AR 02351964 2020 RNP NRC DBAI EQ EDB Update 10/03/2020 AR 02531400 Further Research Needed for Suspected ALE in the RNP RAB Pipe Alley 10/09/2024 AR 00712575 Instrument Accuracy / IR Calculations Not Revised in EC80767 10/09/2014
64 EQDP-0801 Westinghouse Motors Rev. 12 EQDP-0404 3150-N Series Rosemount Transmitters Rev. 004 EQDP-0401 Rosemount 1154 Pressure Transmitter Rev. 020 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 SLRA AMP will be consistent with the corresponding elements of the GALL-SLR Report AMP after implementation of the identified enhancements.
During the audit, the staff made the following observations:
The staff interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The applicant explained how the data for environmental parameters were monitored and how ALEs were identified. The applicant also provided a sample of EQ binders that have been revised to extend the qualified life of electrical components for the subsequent period of extended operation.
For these EQ binders, the staff observed that the applicant utilized analytical techniques to extend the qualification of the electrical components (reanalysis).
The staff requested the applicant to explain how it has addressed concerns with lack of technical references for activation energies for certain materials that were initially provided in Electric Power Research Institute (EPRI) Report NP-1558, A review of Equipment Aging Theory and Technology, Revision 0. NP-1558, Revision 1, resulted in the removal of about 30% of the referenced activation energies due to lack of supporting documentation. During the on-site audit, the applicant noted that they were aware of the issues related to the removal of activation energies in this revision and has confirmed that for Robinson, none of the EQ packages use Revision 0 of NP-1558.
The staff also audited the description of the SLRA A3.3, Environmental Qualification of Electric Equipment, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the GALL-SLR Report.
The staff made the following observations during walkdowns:
During the on-site audit of the Radiological Control Area (RCA), the staff walked down a representative sample of EQ electrical equipment subject to this AMP, including the safety injection pump motors, Rosemount 1154 transmitters, and a Rosemount 3150-N series unit. The applicant also supplemented the walkdown utilizing site cameras to show additional electrical equipment subject to EQ located in areas not accessible during the walkdowns. During the walkdown, the staff did not identify any indications of material degradation in the EQ equipment observed.
During the on-site audit, staff inquired whether the applicant had conducted any reanalysis of the equipment qualification packages as part of implementing the enhanced program. The applicant stated that the reanalysis is currently underway and that the updated packages will be available six months prior to entering the period of extended operation.
65 SLRA AMP B.4.1, Concrete Containment Bonded Tendon Prestress Summary of Information in the Application. The SLRA states that AMP B4.1, Concrete Containment Bonded Tendon Prestress, is an existing plant-specific management program.
The staff audited theSLRAAMPto determine consistency withSRP-SLR SectionA.1.2.3, Aging Management Program Elements.
Audit Activities. An on-site audit was performed June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date RNP Initial LRA - RAI-SER on Bonded Tendons Response to Request for Additional Information Regarding Application for Renewal of Operating License 4/28/2003 AR 00373992 Action Request Details Report - LR Commit. To Perform Structural Integrity Test 1/6/2010 SLR-RNP-AMPR-PS.1 Bonded Tendons Concrete Containment Bonded Tendon Prestress AMP Evaluation Report 7/2/2024 EST-085 Containment Integrated Leak Rate Test Rev. 25 SP-1068 Containment Structural Integrity Test Rev. 2 RNP-C-STRU-1416 Rev 1 part 1 of 4 Structural Integrity Test - Evaluation Data 1 of 4 Rev. 1 RNP-C-STRU-1416 Rev 1 part 2 of 4 Structural Integrity Test - Evaluation Data 2 of 4 Rev. 1 RNP-C-STRU-1416 Rev 1 part 3 of 4 Structural Integrity Test - Evaluation Data 3 of 4 Rev. 1 RNP-C-STRU-1416 Rev 1 part 4 of 4 2020 Containment Structural Integrity Test Concrete Surface Examination Report Rev. 1 Ebasco WELC-5379-Ch 7
Ebasco Specification WELC 5379-CH 7 Containment Structure Structural Proof Test 6/1/1970 G-190353 Reactor Building Cylinder-Prestressing Details 1/20/1970 G-190345 Reactor Building Trench Details & Misc. M&R 1/20/1970 G-190355 - Reactor Building Dome-Plan-Reinf Reactor Building Dome - Plan - Reinf Rev. 3 Responses to NRC questions from 5-12-25 presentation Responses to questions from the Bonded Tendons Prestress presentation/discussion on 5/12/25 5/12/25 1996 Tech Spec Section 4.4.4 Operational Surveillance Program Amd No. 163 During the audit, the staff verified that the applicant addressed the guidance in SRP-SLR SectionA.1.2.3 for the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the SLRA AMP.
66 During the audit, the staff made the following observations:
The acceptance criteria limits for the structural integrity testing on the containment basemat displacement, wall elongation, crack width, and crack spacing are identified in the Ebasco Specification WELC-5379-Ch 7, Containment Structure Structural Proof Test,Section IV, Acceptance Criteria.
The applicant will include in a supplement revised station procedures to include corrective actions if acceptance criteria are not met.
The applicant will include in a supplement a description that the structural integrity test (SIT) will be performed in conjunction with the Appendix J program integrated leak-rate test (ILRT) test. The next schedule testing is planned for 2035 and 2050.
The Appendix J ILRT tests were performed in 1970, 1974, 1992, 2007, and 2020, and the SIT was performed during the same years except that it was not performed in 2007.
The applicant shared the 1996 Amendment No. 163 to the TS Section 4.4.4.2, which described the containment structural test that will be performed 3 and 20 years after operation.
The staff also audited the description of the SLRA AMP, Concrete Containment Bonded Tendon Prestress, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.1, Identification of Time-Limited Aging Analyses (TLAAs)
Summary of Information in the Application. SLRA Section 4.1, Identification of Time-Limited Aging Analyses (TLAAs), discusses the methodology for the identification of TLAAs in the SLRA. The staff performed an audit to verify the implementation of the applicants methodology to identify TLAAs in accordance with 10 CFR Part 54.
Audit Activities. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0100 Subsequent License Renewal Time-Limited Aging Analysis (TLAA) Identification - Includes Attachments 1 through 4 Revision 2 Updated Final Safety Analysis Report Revision 13 SLR-RNP-AMPR-XI.M12 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) AMP Evaluation Report Revision 001 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).
The staff reviewed SLR-RNP-TLAA-0100, and confirmed that current licensing basis and design basis documentation were searched to identify potential TLAAs.
The staff reviewed the SLR-RNP-TLAA-0100, and confirmed that each potential TLAA was reviewed against the TLAA criteria of 10 CFR 54.3(a) and those that met all six criteria were identified as TLAAs.
67 o of SLR-RNP-TLAA-0100 contains the applicants complete documentation of dispositioning any potential analyses against the criteria of a TLAA in 10 CFR 54.3.
The staff reviewed the SLR-RNP-TLAA-0100 and confirmed that a search of docketed licensing correspondence, the operating license, and the UFSAR identified whether there were any active exemptions currently in effect pursuant to 10 CFR 50.12.
The staff reviewed SLR-RNP-TLAA-0100 and confirmed that these exemptions were then reviewed to determine whether it was based on a TLAA.
o of SLR-RNP-TLAA-0100 contains the applicants complete documentation of assessing each exemption granted in accordance with 10 CFR 50.12.
o The staff confirmed that there are no identified 10 CFR 50.12 exemptions that are currently in effect that is based upon a TLAA.
SLRA TLAA Section 4.2.1, Reactor Pressure Vessel Neutron Fluence Summary of Information in the Application. SLRA Section 4.2.1, Neutron Fluence, discusses the analyses for the reactor pressure vessel and reactor pressure vessel internals. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii).
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0302 Reactor Vessel Neutron Embrittlement Time-Limited Aging Analysis Evaluation for Subsequent License Renewal Revision 1 WCAP-18751-NP Analysis of Ex-Vessel Neutron Dosimetry from H.B. Robinson Unit 2 - Cycle 32 March 2022 RNP-2077-03-SLR-0510 Projection of Effective Full Power Years (EFPY) for Use in 80-Year Time-Limited Aging Analysis Evaluations for H.B. Robinson Unit 2 Subsequent License Renewal Revision 0 WCAP-18766-NP H.B. Robinson Unit 2 Subsequent License Renewal: Time-Limited Aging Analyses (TLAA) on Reactor Vessel Integrity (RVI)
Revision 1 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(ii).
The staff also audited the description of the SLRA TLAA, Neutron Fluence Projections, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.2.2, Reactor Pressure Vessel Upper-Shelf Energy Summary of Information in the Application. SLRA Section 4.2.2, Upper-Shelf Energy, discusses the analysis for the reactor pressure vessel. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
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.
68 Relevant Documents Reviewed Document Title Revision / Date WCAP-18766-NP H.B. Robinson Unit 2 Subsequent License Renewal: Time-Limited Aging Analyses (TLAAs) on Reactor Vessel Integrity (RVI)
Revision 1 WCAP-13892 New Measurement of the USE of Archival and Surveillance Plate Material Representative of the H.B. Robinson Unit No. 2 Reactor Vessel Beltline Plates Revision 0 WCAP-18939-P H.B. Robinson Unit 2 Subsequent License Renewal: Fracture Mechanics Assessment of Reactor Pressure Vessel Structural Steel Supports, January 2025 Revision 1 ML14181A451 RVID - Letter from 92-01 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 verified that the material information (i.e., initial USE and %Cu) for the materials identified in SLRA Table 4.2.2-1 is consistent with the applicants current licensing basis (e.g., UFSAR, and official correspondence with the staff related to Generic Letter 92-01).
The staff noted discrepancies associated with components being addressed by Table 4-9 of WCAP 18944, Revision 1, and the information presented in Table 3-8 and Appendix A (Table A2-1b) and Footnote 1 of Table 3-8. The staff will consider issuing an RAI in order to obtain the information necessary.
The staff also audited the description of the SLRA TLAA, Upper-Shelf Energy, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.2.3, Reactor Pressure Vessel Pressurized Thermal Shock Summary of Information in the Application. SLRA Section 4.2.3, Pressurized Thermal Shock, discusses the analysis for the reactor pressure vessel. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(ii).
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the TLAA. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date WCAP-18766-NP H.B. Robinson Unit 2 Subsequent License Renewal: Time-Limited Aging Analyses (TLAAs) on Reactor Vessel Integrity (RVI)
Revision 1 ML18038B289 H. B. Robinson Steam Electric Plant, Unit 2 - License Amendment Request Proposing to Revise Technical Specification 3.4.3, "RCS Pressure and Temperature (P/T) Limits ML18200A042 Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendment No. 260 Regarding Request to Revise Technical Specification Reactor Coolant System Pressure and Temperature Limits to Reflect 24-Month Fuel Cycles
69 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 verified that the material information (e.g., initial RTNDT, %Cu, and %Ni) for the materials identified in SLRA Table 4.2.3-1 is consistent with the applicants current licensing basis (e.g., UFSAR, license amendments and official correspondence with the staff related to Generic Letter 92-01).
o Additionally, based on this verification, the staff observed that the appropriate margin value consistent with 10 CFR 50.61, were applied for each reactor vessel material identified for the purposes of addressing pressurized thermal shock.
The staff verified that the applicant assessed relevant surveillance data to determine its credibility per the criteria in 10 CFR 50.61 and Regulatory Guide 1.99, Rev. 2, and considered whether it is appropriate to use the surveillance data when calculating RTPTS values for Intermediate Shell Plates with Heat Nos. W10201-4, W10201-5 and W10201-6, and Weld Heat No. 5214.
o The staff verified when considering only plant-specific surveillance data for:
W10201-4 and W10201-6, the surveillance data was non-credible in accordance with 10 CFR 50.61 and Regulatory Guide 1.99, Rev 2.
W10201-5, the surveillance data was credible in accordance with 10 CFR 50.61 and Regulatory Guide 1.99, Rev 2.
o The staff verified when considering available surveillance data for W-5214, which included data available from sister-plants (i.e., material with a heat-to-heat match) in accordance with 10 CFR 50.61(c)(2), the surveillance data was partially credible, and the applicant applied the full margin consistent with previous NRC precedence. The staff will address this topic in its SE.
The staff also verified that the applicants assessment of available surveillance data (i.e., plant-specific and sister-plant) for Heat No. W-5214 considered the operating temperature and chemical composition of the sister-plant data in order to appropriately consider it in the evaluation of pressurized thermal shock.
The staff also audited the description of the SLRA TLAA, Pressurized Thermal Shock, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.2.4, Reactor Pressure Vessel Pressure-Temperature Limits Summary of Information in the Application. SLRA Section 4.2.4, Pressure-Temperature Limits, discusses the analysis for the reactor pressure vessel. 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 TLAA. The staff will document its review of this information in the SE.
Relevant Documents Reviewed
70 Document Title Revision / Date Duke Energy Progress. LLC - Docket No. 50-261 H. B.
ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 - Renewed Facility Operating License No DPR Technical Specifications
- Section 3.4.3 Amendment No.
260 and 271 SLR-RNP-TLAA-0302 Robinson Nuclear Plant Unit 2 - Reactor Vessel Neutron Embrittlement Time-Limited Aging Analysis Evaluation for Subsequent License Renewal Revision 1 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
During the audit, the staff made the following observations:
Current P-T limits are contained in Technical Specification Section 3.4, "REACTOR COOLANT SYSTEM (RCS) - Section 3.4.3 RCS Pressure and Temperature (P/T)
Limits o
Current P-T limits are applicable though 46.3 EFPY The staff also audited the description of the SLRA TLAA, Reactor Pressure Vessel Pressure-Temperature Limits, provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the SLRA TLAA, Reactor Pressure Vessel Pressure-Temperature Limits. The staff will consider issuing an RAI in order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description.
SLRA TLAA Section 4.2.5, Reactor Pressure Vessel Low Temperature Overpressure Protection Summary of Information in the Application. SLRA Section 4.2.5, Low Temperature Overpressure Protection discusses the analysis for the reactor pressure vessel. 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 TLAA. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date Duke Energy Progress. LLC - Docket No. 50-261 H. B.
ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 - Renewed Facility Operating License No DPR Technical Specifications
- Section 3.4.12 Amendment No.
176, 203 and 265 SLR-RNP-TLAA-0302 Robinson Nuclear Plant Unit 2 - Reactor Vessel Neutron Embrittlement Time-Limited Aging Analysis Evaluation for Subsequent License Renewal Revision 1 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii).
During the audit, the staff made the following observations:
71 Current P-T limits are contained in Technical Specification Section 3.4, "REACTOR COOLANT SYSTEM (RCS) - Section 3.4.12 Low Temperature Overpressure Protection System o
Applicable to MODES 4 and 5. MODE 6 when the reactor vessel head is on.
TS Table 1.1-1 defines the modes of operation The staff also audited the description of the SLRA TLAA, Low Temperature Overpressure Protection, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.3.1, Transient Cycle Projections for 80 Years Summary of Information in the Application. SLRA Section 4.3.1, Transient Cycle Projections for 80 Years, discusses the 80-year transient cycle for fatigue analyses. The applicant did not identify the transient cycle projections as a TLAA because (1) the transient cycle projections were used only as input to fatigue TLAAs and (2) the specific dispositions of fatigue TLAAs, which involve transient cycles, CUF or CUFen, were separately described in SLRA Sections 4.3.2 through 4.3.5. To verify the adequacy of the projections of transient cycles, the staff audited the 80-year projections.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0300 Time-Limited Aging Analysis of Mechanical Systems Thermal Fatigue for Subsequent License Renewal Revision 1 RNP2-M-0002 Design Specification for the Replacement Reactor Vessel Closure Head Revision 0 4/18/2005 UFSAR Table 3.9.1-1 Thermal And Loading Cycles Revision 21 Technical Specifications 5.5.5 Component Transient or Cyclic Limits Amendment Number 176 PLP-109 Cycle and Transient Monitoring Revision 13 WCAP-16694-P, Supplement 1 Environmental Fatigue Evaluations for H. B. Robinson Unit 2 Pressurizer and Surge Line December 2024 WCAP-17830-P Determination of Acceptable Baffle-Former Bolting for H. B.
Robinson Unit 2 Revision 2-A April 2023 CPL-MC000-TR-LG-000005 H. B. Robinson Unit 2 Subsequent License Renewal: 80-Year Fatigue and Fatigue Exemption Summary Revision 0 12/18/2024 During the audit of the Transient Cycle Projections for 80 Years, the staff verified that the applicant has provided its basis that supports the adequacy of cycle projections. However, the
72 staff found that sufficient information was not available to complete its review of the applicants projections. In order to obtain the necessary information, the staff will consider issuing an RAI.
During the audit, the staff made the following observations.
SLRA Section 4.3.1 explains that the maximum rate of transient cycle (occurrence) accumulation over a recent 10-year interval (October 2008 - September 2018) was used to extrapolate the projected number of future transient cycles. In relation to the transient cycle projections and baseline 10-year cycle data, the meaning of the maximum rate of transient cycle accumulation was not clear to the staff.
SLRA Table 4.3.1-1 describes the observed transient cycles up to September 30, 2018 and the 80-year projected cycles based on the observed cycles. The table also describes the design cycles (equivalent to original 40-year design cycles) for each transient and the percentage of design cycles for the 80-year projected cycles. For the hydrostatic test -
pressure 3110 psig, temperature 100 F transient, SLRA Table 4.3.1-1 indicates the following: (1) the number of the observed transient cycles is zero and accordingly the number of 80-year projected cycles is zero; and (2) the number of design cycles is one (i.e.,
one preoperational cycle). In contrast, the SLRA table indicates that the percentage of design cycles for the 80-year projected cycles of the hydrostatic test transient is 100 percent suggesting that one cycle may have occurred already during the preservice testing or previous operation.
The staff also audited the description of the Transient Cycle Projections for 80 Years provided in the UFSAR supplement. The staff verified this description is consistent with the guidance in SRP-SLR.
SLRA TLAA Section 4.3.2, Class 1 Fatigue Analyses Summary of Information in the Application. SLRA Section 4.3.2, Class 1 Fatigue Analysis discusses the fatigue analysis for ASME Code Section III Class 1 components for 80 years of operation. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0300 Time-Limited Aging Analysis of Mechanical Systems Thermal Fatigue for Subsequent License Renewal Revision 1 SLR-RNP-TLAA-0703 Class 1 Mechanical Plant Specific TLAAs Revision 0 WCAP-12962 Supplement 1 Structural Evaluation of the H. B. Robinson Unit 2 and Shearon Harris Pressurizer Surge Lines Considering the Effects of Thermal Stratification October 1995 WCAP-16694-P Supplement 1 Environmental Fatigue Evaluations for H. B. Robinson Unit 2 Pressurizer and Surge Line Revision 0 December 2024
73 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its disposition of 10 CFR 54.21(c)(1)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing an RAI.
The staff also audited the description of the SLRA TLAA, Class 1 fatigue, provided in the UFSAR supplement. The staff verified this description is consistent with the guidance in the SRP-SLR.
SLRA TLAA Section 4.3.3, Non-class 1 Fatigue Analyses Summary of Information in the Application. SLRA Section 4.3.3, Non-Class 1 Fatigue Analyses discusses analysis for the allowable stress TLAAs for non-Class 1 piping systems. The applicant dispositioned the TLAAs 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0300 Time-Limited Aging Analysis of Mechanical Systems Thermal Fatigue for Subsequent License Renewal Revision 1 SLR-RNP-TLAA-0301 Subsequent License Renewal Non-Class 1 Mechanical Metal Fatigue TLAA Revision 2 RNP-M/MECH-1207 Projection of Thermal Cycles of Select Non-Class 1 Piping Revision 1 8/15/2024 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 its TLAA disposition. In order to obtain the necessary information, the staff will consider issuing an RAI.
During the audit, the staff made the following observations. SLRA Table 4.3.3-2 describes the 80-year estimated transient cycles for the non-Class 1 piping systems. However, SLRA Section Document Title Revision / Date WCAP-17830-P Determination of Acceptable Baffle-Former Bolting for H. B.
Robinson Unit 2 Revision 2-A 4/6/2023 CPL-MC000-TR-LG-000005 H. B. Robinson Unit 2 Subsequent License Renewal: 80-Year Fatigue and Fatigue Exemption Summary Revision 0 12/18/2024 WCAP-10322 Stress Report of 312 Standard Reactor Core Support Structures and Internal Structures Structural and Fatigue Analysis Revision 1 October 1984
74 4.3.3 does not clearly describe how the 80-year cycles were determined (e.g., based on piping system design information, plant operation procedures, test requirements, UFSAR information and specific system-level knowledge).
The staff also audited the description of the SLRA TLAA, Non-Class 1 Fatigue Analyses, provided in the UFSAR supplement. The staff verified this description is consistent with the guidance in the SRP-SLR.
SLRA TLAA Section 4.3.4, Environmentally Assisted Fatigue Summary of Information in the Application. SLRA Section 4.3.4, Environmentally Assisted Fatigue, discusses the analysis for the reactor coolant pressure boundary components including the reactor vessel, pressurizer surge line piping, and main coolant loop piping including branch line piping. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0300 Time-Limited Aging Analysis of Mechanical Systems Thermal Fatigue for Subsequent License Renewal Revision 1 SLR-RNP-AMPR-X.M1 Fatigue Monitoring AMP Evaluation Report Revision 2 3/17/2025 CPL-MC000-TR-CF-000002 Robinson Nuclear Plant Subsequent License Renewal: Primary Equipment and Surge Line Piping Environmentally Assisted Fatigue Screening Evaluation Results Revision 1 12/11/2024 Structural Integrity Associates (SIA) 1501603.382 Robinson ANSI B31.1 Piping Scope Thermal Transient Consolidation, Common Basis Stress Evaluation (CBSE)
Screening and Selection of Sentinel Locations for Environmentally Assisted Fatigue (EAF)
Revision 0 12/20/2023 CPL-MC000-TR-LR-000009 Robinson Nuclear Plant Subsequent License Renewal:
Environmentally Assisted Fatigue Evaluations Summary Report Revision 0 SIA 1501603.325 Charging Nozzle Flaw Tolerance Evaluation Revision 0 9/18/2024 WCAP-15363, Revision 1
A Demonstration of Applicability of ASME Code Case N-481 to the Primary Loop Pump Casings of H.B. Robinson Unit 2 for the License Renewal Program Revision 1 CPL-RV000-TR-CF-000001 H.B. Robinson Unit 2 Subsequent License Renewal: Reactor Vessel Outlet Nozzle to Shell Weld Flaw Tolerance Reconciliation Revision 0 December 2024 WCAP-18901-P H. B. Robinson Unit 2 Subsequent License Renewal:
Pressurizer Surge Nozzle to Surge Line Welds and Hot Leg Surge Nozzle to Surge Line Weld Flaw Tolerance Evaluations Utilizing ASME Section XI Appendix L Methodology Revision 0 March 2025
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)(iii). However, the staff found that sufficient information was not available to complete its review of the applicants basis for the TLAA disposition. In order to obtain the necessary information, the staff will consider issuing an RAI.
During the audit, the staff made the following observations. SLRA Section 4.3.4 explains that the Appendix L flaw tolerance analyses use the fatigue crack growth rates described in ASME Code,Section XI, Code Case N-809. In ASME Code Case N-809, the parameter defining the effect of temperature on fatigue crack growth rate (ST) has a minimum value at 300 °F for austenitic stainless steels. Therefore, how the metal temperature is defined in the calculations of ST values may result in non-conservative fatigue crack growth rates. For the pressurizer surge reducer-to-pipe weld, the applicant indicated that bounding ST values were used in the Appendix L flaw tolerance analysis. For the charging nozzle-to-pipe weld, the staff needs similar clarification on whether the applicant determined the ST values for the fatigue transients in a manner to estimate conservative bounding ST values.
The staff also audited the description of the SLRA TLAA, Environmentally Assisted Fatigue, provided in the UFSAR supplement. The staff verified this description is consistent with the guidance in the SRP-SLR.
SLRA TLAA Section 4.3.5, High-Energy Line Break Summary of Information in the Application. SLRA Section 4.3.5, High-Energy Line Break discusses the high-energy line break (HELB) TLAA for non-Class 1 piping systems. 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.
Relevant Documents Reviewed Document Title Revision / Date WCAP-16694-P, Supplement 1 Metal Fatigue Evaluations for H.B. Robinson Unit 2 Pressurizer and Surge Line Revision 0 December 2024 WCAP-16168-NP-A Risk-informed Extension of the Reactor Vessel In-service Inspection Interval Revision 3 October 2011 PWROG-17031-NP-A Update for Subsequent License Renewal: WCAP-15388-A, A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants Revision 1 May 2020 Document Title Revision / Date SLR-RNP-TLAA-0300 Time-Limited Aging Analysis of Mechanical Systems Thermal Fatigue for Subsequent License Renewal Revision 1 SLR-RNP-TLAA-0301 Subsequent License Renewal Non-Class 1 Mechanical Metal Fatigue TLAA Revision 2
76 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 SLRA TLAA, HELB, provided in the UFSAR supplement. The staff verified this description is consistent with the guidance in the SRP-SLR.
SLRA TLAA Section 4.4, Environmental Qualification of Electric Equipment Summary of Information in the Application. SLRA Section 4.4, Environmental Qualification of Electric Equipment, discusses the thermal, radiation, and cyclical aging analyses for the plant electrical and I&C components. The applicant dispositioned the TLAA in accordance with 10 CFR54.21(c)(1)(iii).
Audit Activities. An on-site audit was performed June 3, 2025, to June 5, 2025. 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-X.E1 Environmental Qualification of Electric Equipment AMP Evaluation Report, Appendix D - Input for Robinson SLR Application Section 4.4 (Environmental Qualification of Electrical Equipment)
Rev. 001 AD-EG-ALL-1612 Environmental Qualification (EQ) Program Rev. 9 AD-EG-ALL-1117 Design Analyses and Calculations Rev. 10 TMM-036 Environmental Qualified (EQ) Electrical Equipment Required Maintenance Rev. 51 GID/R87038/0001 Generic Issues Document Environmental Qualification Rev. 11 AR 02137576 EQ Self-assessment AFI #3 - EQDPs require revisions 07/18/2017 AR 02150104 Rosemount 1154 Transmitter EQ Qualified Life Revision 9/12/2017 AR 00750856 Work Orders Not Planned / Scheduled to Support EQ Compliance 05/25/2015 AR 02351964 2020 RNP NRC DBAI EQ EDB Update 10/03/2020 AR 02531400 Further Research Needed for Suspected ALE in the RNP RAB Pipe Alley 10/09/2024 Document Title Revision / Date RNP-M/MECH-1207 Projection of Thermal Cycles of Select Non-Class 1 Piping Revision 1 8/15/2024 UFSAR Section 3.6.2 Postulated Piping Failures in Fluid Systems Outside of Containment Revision 28
77 AR 00712575 Instrument Accuracy / IR Calculations Not Revised in EC80767 10/09/2014 EQDP-0801 Westinghouse Motors Rev. 12 EQDP-0404 3150-N Series Rosemount Transmitters Rev. 004 EQDP-0401 Rosemount 1154 Pressure Transmitter Rev. 020 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 interviewed the applicants staff and reviewed documentation contained in the SLRA and provided by the applicant via the ePortal. The applicant explained how the data for environmental parameters were monitored and how ALEs were identified. The applicant also provided a sample of EQ binders that have been revised to extend the qualified life of electrical components for the subsequent period of extended operation.
For these EQ binders, the staff observed that the applicant utilized analytical techniques to extend the qualification of the electrical components.
The staff requested the applicant to explain how it has addressed concerns with lack of technical references for activation energies for certain materials that were initially provided in EPRI Report NP-1558, A review of Equipment Aging Theory and Technology, Revision 0. NP-1558, Revision 1, resulted in the removal of about 30% of the referenced activation energies due to lack of supporting documentation. During the on-site audit, the applicant noted they were aware of the issues related to the removal of activation energies in this revision and has confirmed that for Robinson, none of the EQ packages uses Revision 0 of NP-1558.
The staff also audited the description of the SLRA TLAA, Environmental Qualification of Electric Equipment, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
The staff made the following observation during walkdowns:
During the walkdown of the RCA, the staff reviewed a representative sample of EQ electrical equipment subject to this AMP, including the safety injection pump motors, Rosemount 1154 transmitters, and a Rosemount 3150-N series unit. The applicant also supplemented the walkdown utilizing site cameras to show additional electrical equipment subject to EQ located in areas not accessible during the walkdowns.
SLRA TLAA Section 4.6, Containment Liner Plate, Metal Containments, and Penetration Fatigue Analysis Summary of Information in the Application. SLRA Section 4.6.3, Containment Penetrations Fatigue Analysis, discusses the analysis for the containment penetration bellows. The applicant disposed of the TLAA in accordance with 10 CFR 54.21(c)(1)(i).
78 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0601 CONTAINMENT PENETRATIONS BELLOWS FATIGUE Revision 0 UFSAR Subsections 18.2.2.4 Containment Penetration Bellows Fatigue RNP-L/LR-0502 Thermal Fatigue TLAA Review for H.B. Robinson - Unit No. 2 Revision 4 NE295P Bellows Design Calculations Revision 1 NE281 P-63 Bellows Design Calculations Revision 2 NE284 Bellows Design Calculations Revision 2 CPL-HBR2-M-056 Reactor Containment Building Piping/Sleeve Penetration Bellows Revision 6 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 SLRA TLAA, Containment Penetrations Fatigue Analysis, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.7.1, Crane Fatigue Summary of Information in the Application. SLRA Section 4.7.1, Crane Fatigue, discusses the analysis for each evaluated crane. The applicant disposed of the TLAA in accordance with 10 CFR 54.21(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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0701 CRANE FATIGUE Revision 0 UFSAR Subsections 9.1.5 15.7.5.2 18.2.3 18.1.14 Revision 30 RNP-L/LR-0503 Crane Fatigue Time Limited Aging Analysis Review Revision1 CMAA-70 Specifications for Electric Overhead Traveling Cranes,1975 Revised 1961
79 MMM-09 Robinson Procedure MMM-09, Operation, Testing, and Inspection of Cranes and Equipment Used for Handling Heavy Loads Revision 88 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 SLRA TLAA, Crane Fatigue, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.7.2, Reactor Coolant Pump Flywheel Analyses Summary of Information in the Application. SLRA Section TLAA 4.7.2, Reactor Coolant Pump Flywheel Analyses, discusses the analyses for the reactor coolant pump flywheel. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(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.
Relevant Documents Reviewed Document Title Revision / Date Robinson SLRA Section 4.7.2 Reactor Coolant Pump Flywheel Analyses Rev. 0 Robinson SLRA Section 4.3.1 Transient Cycle Projections for 80 Years Rev 0 PWROG-17011-NP-A, Update for Subsequent License Renewal: WCAP-14535A, Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination and WCAP-15666-A, Extension of Reactor Coolant Pump Motor Flywheel Examination, PA-MSC-1500, ML19318D189 and ML19318D194 October 2019, Westinghouse Topical Report WCAP-15666-A, Revision 1, P.L. Strauch et al. "Extension of Reactor Coolant Pump Motor Flywheel Examination." Pittsburgh:
Westinghouse, October 2003 (ML18303A413) 10/2023 Robinson UFSAR Updated Final Safety Analysis Report (UFSAR) Chapter 3.5.1.1, Flywheel Design Consideration Rev 27 Robinson Technical Specifications Technical Specifications Section 5.5.7 "Reactor Coolant Pump Flywheel Inspection Program" (ML052860281) 6/25/2025 Westinghouse Topical Report WCAP-14535A, Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination, (ML18312A151) 11/1996 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:
SLRA Table 4.3.1-1, indicates 200 cycles for heatup, 200 cycles for cooldown, and 400 cycles for reactor trip. These cycles are applicable to the fatigue crack growth calculation of the RCP flywheel.
The applicant confirmed that it has not detected relevant indications on the RCP flywheels at Robinson.
80 The most recent RCP flywheel inservice inspections were performed in 2014 during the Robinson Unit 2 Refueling Outage (RFO) 29.
o The A and B reactor coolant pump flywheels were inspected by ultrasonic inspection with no indications identified.
The RCP A flywheel was inspected during RFO 29 (May 2015) as part of the Augmented ISI program.
The RCP B flywheel was inspected during RFO 29 (May 2015) as part of the Augmented ISI program.
o Ultrasonic (UT) and magnetic particle (MT) examinations were performed on the C reactor coolant pump flywheel at the AREVA Pump & Motor Service Center during motor refurbishment in the Fall of 2014. No relevant indications were found.
The staff also audited the description of the SLRA TLAA, Reactor Coolant Pump Flywheel Analyses, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.7.3, Leak-Before-Break Summary of Information in the Application. SLRA Section 4.7.3 Leak-Before-Break, discusses the analysis for the RCS loop piping and the RCS auxiliary piping. The applicant dispositioned the TLAA with 10 CFR 54.21(c)(1)(ii) for the RCS loop piping, and with 10 CFR 54.21(c)(1)(i) for the RCS auxiliary piping.
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.
Relevant Documents Reviewed Document Title Revision / Date NUREG-0800, Section 3.6.3 Leak-Before-Break Evaluation Procedures Revision 1/March 2007 NUREG/CR-4513 Estimation of Fracture Toughness of Cast Stainless Steel During Thermal Aging in LWR Systems Revision 1/May 1994 NUREG/CR-4513 Estimation of Fracture Toughness of Cast Stainless Steel During Thermal Aging in LWR Systems Revision 2/May 2016 H.B. Robinson Steam Electric Plant Subsequent License Renewal Application April 2025 WCAP-15628 Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for the H.B. Robinson Unit 2 Nuclear Power Plant for the License Renewal Program Revision 0 WCAP-15628 Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for the H.B. Robinson Unit 2 Nuclear Power Plant for the Subsequent License Renewal Program Revision 1/May 2024 WCAP-17776-P/NP Technical Justification for Eliminating Pressurizer Surge Line Rupture as the Structural Design Basis for H.B. Robinson, Unit 2 Revision 1/March 2023 WCAP-17778-P/NP Technical Justification for Eliminating Residual Heat Removal (RHR) Line Rupture as the Structural Design Basis for H.B.
Robinson Unit 2 Revision 1/March 2023
81 WCAP-17779-P/NP Technical Justification for Eliminating Accumulator Line Rupture as the Structural Design Basis for H.B. Robinson Unit 2 Revision 1/March 2023 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 the RCS loop piping and 10 CFR 54.21(c)(1)(i) for the RCS auxiliary piping.
The staff also audited the description of the SLRA TLAA, Leak-Before-Break, provided in the UFSAR supplement. The staff verified that this description is consistent with the information provided in the SRP-SLR.
SLRA TLAA Section 4.7.4, Reactor Coolant Pump Code Case N-481 Summary of Information in the Application. SLRA Section 4.7.4, Reactor Coolant Pump Code Case N-481 discusses the applicants basis that this is no longer applicable and not a TLAA for subsequent license renewal.
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.M12 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) AMP Evaluation Report Revision 001 WCAP-13045 Compliance to ASME Code Case N-481 of Primary Loop Pump Casings of Westinghouse Type Nuclear Steam Supply Systems ADAMs Accession No. ML19353B264 SLR-RNP-TLAA-0100 Subsequent License Renewal Time-Limited Aging Analysis (TLAA) Identification - Includes Attachments 1 through 4 Revision 2 During the audit of the TLAA, the staff verified that the applicant has provided its basis that supports its determination that this is no longer applicable and not a TLAA for SLR.
During the audit, the staff made the following observations:
The staff reviewed SLR-RNP-AMPR-XI.M12, including the citations to Certified Material Test Reports contained in WCAP-13405, and confirmed that the delta ferrite content for the RCP casings are less than the screening criteria for thermal embrittlement of CASS contained in GALL-SLR AMP XI.M12.
The staff reviewed SLR-RNP-AMPR-XI.M12, including the citations to design specifications maintained by Westinghouse, that confirm that the design and operating temperatures of the RCP main flange and thermal barrier flange do not exceed the temperature threshold for thermal embrittlement for CASS contained in GALL-SLR and GALL-SLR AMP XI.M12.
The staff also audited the description of the analysis for Reactor Coolant Pump Code Case N-481 provided in the UFSAR supplement. The staff verified that this description provides information supporting the determination that this is no longer applicable and is not a TLAA for SLR.
82 SLRA TLAA Section 4.7.5, Reactor Vessel Underclad Cracking Summary of Information in the Application. SLRA Section TLAA 4.7.5, Reactor Vessel Underclad Cracking, discusses the analyses for the reactor vessel. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
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.
Relevant Documents Reviewed Document Title Revision / Date Robinson SLRA Section 4.7.5. Reactor Vessel Underclad Cracking Rev. 0 Robinson UFSAR Subsection 18.2.2.3, Reactor Vessel Underclad Cracking Rev. 27 Westinghouse Topical Report WCAP-15338-A, A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants, ML083530289 10/2002 NRC Safety Evaluation Revised Safety Evaluation of WCAP-15338, A Review of Cracking Associated with Weld Deposited Cladding in Operating Pressurized Water Reactor (PWR) Plants, ML022690375 2002 PWROG-17031-NP, Revision 1 Letter from Ken Schrader, Pressurized Water Reactor Owners Group, to USNRC Document Control Desk, May 31, 2018, Transmittal of PWROG-17031-NP, Revision 1, "Update for Subsequent License Renewal: WCAP-15338-A, 'A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants,"' ML18164A034 and ML18164A035 5/31/2018 Response to NRC Request for additional Information Letter from Ken Schrader, Pressurized Water Reactor Owners Group, to USNRC Document Control Desk, August 29, 2019, Transmittal of the Response to Request for Additional Information, RAls 1, 2 and 3 Associated with PWROG-17031-NP, Revision 1, "Update for Subsequent License Renewal:
WCA P-15338-A, 'A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants,"' PA-MSC-1497, ML19253B327 8/29/2019 Updated PWROG-17031-NP, Revision 1-A PWROG-17031-NP-A, Revision 1, Update for Subsequent License Renewal: WCAP-15338-A, "A Review of Cracking Associated with Weld Deposited Cladding in Operating PWR Plants," ML20132A219 2020 Response to Request for Additional Information RNP-RA/16-0073, Response to Request for Additional Information Regarding License Amendment Request to Revise Reactor Coolant System Pressure and Temperature Limits, ML16258A343 2016 Applicant Document CPL-MC000-TR-CF-000001, Revision 1, H. B. Robinson Unit 2 Subsequent License Renewal: Disposition of Reactor Vessel Underclad Cracking Rev 1
83 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:
No indications or flaws were detected in the Robinson reactor vessel underclad, as documented in CPL-MC000-TR-CF-000001, Revision 1.
NRC Regulatory Guide 1.43, Revision 1, states that underclad cracking (or hot underclad cracking) has been reported only in forgings and plate material of ASME SA-508, Specification for Quenched and Tempered Vacuum Treated Carbon and Alloy Steel Forgings for Pressure Vessels, Grade 2 Class 1 (formerly known as SA-508 Class
- 2) composition made to coarse-grain practice. Cracking was not observed in clad ASME SA-533 Grade B Class 1 plate material, which is produced to fine-grain practice, regardless of the welding process used.
The Robinson upper, intermediate, and lower shells are fabricated from A302 Grade B material and were quenched and tempered. A comparison of chemical composition and mechanical properties between SA-533 Grade B Class 1 and A302 Grade B material is performed in Appendix D subsection I.B of EPRI document 1014351, Repair and Replacement Applications Center: Topical Report Supporting Expedited NRC Review of Code Cases for Dissimilar Metal Weld Overlay Repairs. It is noted that the Robinson A302 Grade B shells are not nickel modified. Comparing both chemical compositions and mechanical properties of the Robinson A302 Grade B material and the SA-533 Grade B, Class 1 material it may be concluded that these materials are essentially equivalent. Because underclad cracking is not applicable to SA-533 Grade B Class 1 material and underclad cracking has not been detected at Robinson, it is determined that underclad cracking is not applicable to the Robinson upper, intermediate, and lower shells as reported in the Robinson SLRA, Page 4-81.
In addition, WCAP-15338-A (2002) and PWROG-17031-NP-A Revision 1 (2020) both performed an extensive study of industry OE to identify instances of underclad cracking.
This study did not find any instances of underclad cracking occurring in SA-533 Grade B Class 1 or A302 Grade B materials. As such, the analytical evaluations in these topical reports only address ASME SA-508, Class 2 and 3 forgings.
The staff also audited the summary description of the SLRA TLAA, Reactor Vessel Underclad Cracking, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.7.6, Foundation Pile Corrosion Summary of Information in the Application. SLRA Section 4.7.6, Foundation Pile Corrosion, discusses the analysis for the Class 1 foundation piles. The applicant dispositioned the TLAA in accordance with 10 CFR 54.21(c)(1)(ii).
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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0706 Foundation Pile Corrosion Revision 0
84 UFSAR Subsections 3.8.5.4.3, Pile Corrosion Protection 18.2.8 Foundation Pile Corrosion N/A SLR-RNP-TLAA-0100 Subsequent License Renewal Time Limited Aging Identification Rev. 0 RNP-L/LR-0507 Foundation Piles Time Limit Aging Analysis Review for H.B.
Robinson - Unit No.2 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)(ii).
The staff also audited the description of the SLRA TLAA, Foundation Pile Corrosion, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
SLRA TLAA Section 4.7.7, Concrete Containment Bonded Tendon Prestress Analysis Summary of Information in the Application. SLRA Section 4.7.7, Concrete Containment Bonded Tendon Prestress Analysis, discusses the analysis for the loss of prestressing on the containment building vertical grouted tendons. The applicant dispositioned the TLAA in accordance with10 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.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0707 Prestress Concrete Containment with Grouted Tendons TLAA Rev. 0 RNP Tendon Loading calc RNP-C-CONT-1004 Prestress Tendon Loading Rev. 2 25-year Tendon prestress surveillance block Submittal of Containment Surveillance Tendon Test Results 2/4/1998 RNP-C-CONT-1004 Rev 1 Calculations for Prestress Tendon Loading Rev. 1 Ebasco WELC-5379-Ch 4 Ebasco Specification WELC 5379-CH 4 Prestressing Steel Tendons Rev. 1 During the audit of the TLAA, the staff verified that the applicant has provided itsbasis that supports its disposition of 10CFR54.21(c)(1)(iii).
During the audit, the staff made the following observations:
In 2016, Robinson received authorization to extend the frequencies of the Appendix J testing requirements. This allowed Type A testing to be performed every 15 years.
The applicant explained that the 5-year surveillance tendon test that resulted in 40% low reduction in the area of Bar 6 was due to existing corrosion that occurred prior to prestressing and grouting of the surveillance tendon. The applicant further explained the presence of corrodents, such as chloride, can cause steel to fail under high stress, however, Bar 6 did not fail under service conditions and only displayed lower ductility
85 during pull testing while the yield and ultimate strengths compared favorably with other specimens.
The applicant explained that the PCI handbook was used to estimate prestress losses and that 65% concrete creep and shrinkage occurs by 12 months of aging, 30% occurs between 1 year and 50 years, 5% occurs between 50 to 60 years, and 4% occurs between 60 to 80 years.
The TLAA 0707 basis document states the prestress losses to be 27.49ksi after 100 years of aging. The Robinson C-CONT-1004, Rev 2 document calculated the prestress net losses to be 19.68 ksi at 100 years. The applicant stated that the CONT-1004 document utilized a refined analytic approach and the TLAA 0707, Attachment 1, value is more conservative.
The staff also audited the description of the SLRA TLAA, Prestressed Containment With Grouted Tendons, provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-SLR.
AMR Items Not Associated with an AMP SLRA Section 3.1.2.2.1, Cumulative Fatigue Damage Summary of Information in the Application. SLRA Section 3.1.2.2.1 describes the applicants AMR results related to SLRA Item 3.1.1-009. Specifically, SLRA Item 3.1.1-009 describes the AMR results for stainless steel, steel, and nickel-alloy reactor coolant pressure boundary piping.
These piping components are subject to cumulative fatigue damage and managed by using fatigue TLAAs described in SLRA Section 4.3.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to the SLRA AMR item 3.1.1-009 and Section 3.1.2.2.1. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-TLAA-0300 Time-Limited Aging Analysis of Mechanical Systems Thermal Fatigue for Subsequent License Renewal Revision 1 SLR-RNP-AMPR-X.M1 Fatigue Monitoring AMP Evaluation Report Revision 2 3/17/2025 SLR-RNP-IPAR-M100 Subsequent License Renewal Integrated Plant Assessment of the Reactor Vessel, Internals, and Reactor Coolant Systems Revision 0 10/8/2024 During the audit, the staff made the following observations. SLRA Table 3.1.2-1, AMR IDs 9053 and 9054 describe the AMR results for the Class 1 valve bodies fabricated with stainless steel and CASS, respectively, which are associated with AMR item 3.1.1-009. However, it is not clear to the staff which subsection of SLRA Section 4.3 addresses the fatigue TLAA for these valve bodies. The staff will consider issuing an RAI to clarify which subsection of SLRA Section 4.3 addresses the fatigue TLAA for the Class 1 valve bodies.
86 SLRA AMR Further Evaluation (FE) Sections 3.2.2.2.2, 3.2.2.2.4, 3.2.2.2.8, 3.2.2.2.10, 3.3.2.2.3, 3.3.2.2.4, 3.3.2.2.8, 3.3.2.2.10, 3.4.2.2.2, 3.4.2.2.3, 3.4.2.2.7, and 3.4.2.2.9 Summary of Information in the Application. The SLRA addresses FE of cracking due to stress corrosion cracking, and loss of material due to pitting and crevice corrosion, of stainless steel, nickel alloys, and aluminum alloys in the Engineered Safety Features systems, Auxiliary systems, and Steam and Power Conversion systems. The SLRA sections for these FE discussions are: 3.2.2.2.2, 3.2.2.2.4, 3.2.2.2.8, 3.2.2.2.10, 3.3.2.2.3, 3.3.2.2.4, 3.3.2.2.8, 3.3.2.2.10, 3.4.2.2.2, 3.4.2.2.3, 3.4.2.2.7, and 3.4.2.2.9.
Audit Activities. The table below lists documents that were reviewed by the staff and were found relevant to these FE sections. The staff will document its review of this information in the SER.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-FERR-0200 Subsequent License Renewal Further Evaluation Required Report - Engineered Safety Features Rev. 0 9/30/2024 SLR-RNP-FERR-0300 Subsequent License Renewal Further Evaluation Required Report - Auxiliary Systems Rev. 0 9/24/2024 SLR-RNP-FERR-0400 Subsequent License Renewal Further Evaluation Required Report - Steam and Power Conversion Systems Rev. 0 9/18/2024 AR 00370603 Small Leak on Letdown Diversion Piping Downstream LCV-115A 12/11/2009 AR 00607952 Thru-Wall Boric Acid Leak Condition at CVC-349C Tee Location 5/22/2013 Quick Cause Evaluation Report on CR 00607952 6/6/2013 Metallurgy File #5033 RNP Leak in Tee above CVC-349C 9/9/2013 AR 00560007 Inspect and Evaluate Apparent Leak on SI-837 9/7/2012 SLRA AMR 3.6.2.2.2, Reduced Insulation Resistance Due to Age Degradation of Cable Bus Arrangements Caused by Intrusion of Moisture, Dust, Industrial Pollution, Rain, Ice, Photolysis, Ohmic Heating and Loss of Strength of Support Structures and Louvers of Cable Bus Arrangements Due to General Corrosion and Exposure to Air Outdoor Summary of Information in the Application. The SLRA Section 3.6.2.2.2, Reduced Insulation Resistance Due to Aging Degradation of Cable Bus Arrangements Caused by Intrusion of Moisture, Dust, Industrial Pollution, Rain, Ice, Photolysis, Ohmic Heating and Loss of Strength of Support Structures and Louvers of Cable Bus Arrangements due to General Corrosion and Exposure to Air Outdoors, states that AMP B2.1.37, Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, will be used to manage the aging of the cables and connections of the in-scope cable bus.
Audit Activities.
An on-site audit was performed from June 3, 2025, to June 5, 2025. 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.
87 Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-AMPR-XI.E1 Electrical Insulation for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP Evaluation Report Revision 1 EC 284182 230 kV SUT - 4.16 kV Cable Bus and Non-Segregated Bus Duct Installation Revision 26 EC 284184 Switchyard and Electrical Distribution System - New Switchgear Building 469 for Distribution of Power from Startup Transformers Revision 8 PM-144-4 230KV Startup Transformer To 4KV Bus 8 and Bus 9 Bus Duct Inspection Revision 2 PM-144-3 230KV Startup Transformer To 4KV Bus 7 Bus Duct Inspection Revision 1 During the audit, the staff made the following observations:
During its review of Robinson SLRA AMP B2.1.37 and the basis document SLR-RNP-AMPR-XI.E1 Revision 1, the staff identified that 1) the AMP B2.1.37 and its basis document did not discuss cable bus; 2) the insulated cables and connections covered by Robinson AMP B2.1.37 are accessible and in an ALE environment while the insulated cables and connections in the cable bus are not accessible (i.e., cannot be viewed easily without the opening of metal covers) and are in an outdoor uncontrolled environment, and dust and industrial pollution could cause reduced electrical insulation resistance due to degradation caused thermal/thermoxidative degradation of organics and photolysis (UV sensitive materials only) of organics, moisture/debris intrusion and ohmic heating for the cable bus terminals/connection and cables. In response to the staffs breakout question, the applicant stated that the insulated cables within the cable bus are periodically made accessible by existing preventive maintenance inspections (via procedures PM-144-3 and PM-144-4) that remove the cable bus covers for a clearer visual access to the inside of the ventilated cable bus; 1) AMP B2.1.37 visually inspects insulated cables and connections for jacket surface anomalies including surface contamination which would identify any deposits (e.g. dust or debris) on the cable jackets; and 2) the procedures PM-144-3 and PM-144-4 include inspection for foreign, debris, dust, etc., and the maintenance plan will be added to the AMP basis document SLR-RNP-AMPR-XI.E1. The applicant stated that the SLRA AMP B2.1.37 and UFSAR supplement A2.1.37 will be revised in a future supplement to include that AMP B2.1.37 will manage the insulated cables and connections in the cable bus located in an outdoor uncontrolled environment.
SLRA Section 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 Preload for Transmission Conductors, Switchyard Bus, and Connections.
Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the AMR discussed in SLRA Section 3.6.2.2.3 and the following:
SLRA Table 3.6.1, Summary of Aging Management Programs for the Electrical and Instrumentation and Controls Evaluated in Chapter VI of the GALL-SLR Report, Item Number 3.6.1-004 - Transmission conductors composed of aluminum; steel exposed to air - outdoor
88 SLRA Table 3.6.1, Item Number 3.6.1-005 - Transmission connectors composed of aluminum; steel exposed to air - outdoor SLRA Table 3.6.1, Item Number 3.6.1-006 - Switchyard bus and connections composed of aluminum; copper; bronze; stainless steel; galvanized steel exposed to air - outdoor SLRA Table 3.6.1, Item Number 3.6.1-007 - Transmission conductors composed of aluminum; steel exposed to air - outdoor Audit Activities. An on-site audit was performed June 3 to June 5, 2025. The table below lists documents that were reviewed by the staff and were found relevant to the AMR evaluation in SLRA Section 3.6.2.2.3. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-IPAR-E100 SLR Integrated Plant Assessment of the Elec and I&Cs Revision 0 /
10/3/2024 SLR-RNP-OPEX-0100 SLR Operating Experience Review Methodology and Results Revision 2 SLR-RNP-FERR-0600 SLR Further Evaluation Required Report - Elec and I&C Revision 0 /
10/2/2024 CSD-EG-ALL-2000.2 Nuclear Switchyard Operating Guidelines Revision 11 /
8/8/2024 The staff made the following observation during walkdowns:
During the on-site audit, the staff performed a walkdown of the station blackout (SBO) offsite power recovery path from the switchyard to the startup transformers and the main transformer bank. The staff did not observe any signs of adverse or abnormal age-related degradation with in-scope switchyard bus and connections, transmission conductors, or transmission connectors.
SLRA Section 3.6.2.3.2, High-Voltage Electrical Insulators Summary of Information in the Application. During the audit, the staff reviewed plant documentation associated with the AMR discussed in SLRA Section 3.6.2.3.1 and the following:
SLRA Table 3.6.1, Summary of Aging Management Programs for Electrical and Instrumentation and Controls Evaluated in Chapter VI of the GALL-SLR Report, Item Number 3.6.1-002 - High-voltage electrical insulators composed of porcelain; malleable iron; aluminum; galvanized steel; cement, toughened glass; polymers; silicone rubber; fiber glass, aluminum alloy exposed to air - outdoor SLRA Table 3.6.1, Item Number 3.6.1-003 - High-voltage electrical insulators composed of porcelain; malleable iron; aluminum; galvanized steel; cement, toughened glass; polymers; silicone rubber; fiber glass, aluminum alloy exposed to air - outdoor Audit Activities.
89 An on-site audit was performed June 3 to June 5, 2025. The table below lists documents that were reviewed by the staff and were found relevant to the AMR evaluation in SLRA Section 3.6.2.3.1. The staff will document its review of this information in the SE.
Relevant Documents Reviewed Document Title Revision / Date SLR-RNP-IPAR-E100 SLR Integrated Plant Assessment of the Elec and I&Cs Revision 0 / 10/3/2024 SLR-RNP-OPEX-0100 SLR Operating Experience Review Methodology and Results Revision 2 SLR-RNP-FERR-0600 SLR Further Evaluation Required Report - Elec and I&C Revision 0 / 10/2/2024 CSD-EG-ALL-2000.2 Nuclear Switchyard Operating Guidelines Revision 11 / 8/8/2024 CSD-EG-ALL-2000.1 Nuclear Switchyard Interface Agreement Revision 3 / 2/1/2022 The staff made the following observations 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 startup transformers and the unit auxiliary transformer. The staff did not observe any adverse or abnormal signs of age-related degradation with in-scope high-voltage electrical insulators.
3.
Supplements to the SLRA By letters dated August 28, 2025 (ML25240B655), and September 26, 2025 (ML25072A153),
Duke voluntarily submitted Supplements 1 and 2, to the SLRA resulting from discussions held during the audit.
4.
Audit Questions Provided to Duke Over the course of the audit, the NRC staff provided audit questions to Duke to facilitate the audit discussions (ML25253A040).
Subject Area Meeting Date On-site Audit 6/3/25 - 6/5/25 Scoping and Screening - Fire Protection 6/16/25 Fire Protection AMP 6/25/25 Metal Fatigue TLAA 6/30/25 ASME Section XI, Subsections IWB, IWC, and IWD 6/30/25 Fatigue Monitoring AMP 6/30/25 PWR Vessel Internals AMP 7/2/25 Reactor Coolant Pump Flywheel Analysis and Reactor Pressure Vessel Underclad Cracking TLAAs 7/2/25 Cable Bus and MEB AMPs 7/2/25 Equipment Qualification of Electrical Equipment AMP 7/2/25 Identification of TLAA 7/7/25 Further Evaluations in SLRA Section 3.2-3.4 - SCC and Loss of Material (pitting, crevice) for Stainless Steel, Nickel Alloys, and Aluminum Alloys 7/9/25
90 Subject Area Meeting Date EAF TLAA 7/9/25 Water Chemistry AMP 7/10/25 Flow-Accelerated Corrosion AMP 7/10/25 Recurring Internal Corrosion 7/14/25 Internal Coatings/Linings of In-Scope Piping, Piping Components, Heat Exchangers, and Tanks AMP 7/14/25 Non-Equipment Qualification of Sensitive Instrumentation Cable Insulation Material AMP 7/17/25 Fire Water System AMP 7/17/25 Prestressed Concrete Containment with Grouted Tendons TLAA 7/24/25 Selective Leaching AMP 7/24/25 Structures Monitoring AMP 7/24/25 Buried and Underground Piping and Tanks AMP 7/25/25 Structural Irradiation 7/28/25 7/30/25 7/31/25 8/20/25 Prestressed Concrete Containment with Grouted Tendons AMP 8/1/25 5.
Applicant Personnel Contacted During Audit Name Affiliation Alex Robertson Duke Austin Keller Duke Bert Spear Duke Brian Mitchell Duke Chris Saville Duke Chuck Tomes Duke Crystal Bowers Duke Daniel Roberts Duke David Morris Duke Erik Wagner Duke Heather Galloway Duke Jeff Lane Duke Lori Hekking Duke Mark Pyne Duke Mark Rinckel Duke Matthew Peters Duke Matthew Walker Duke Rachel Doss Duke Steve Graham Duke Travis Walsh Duke Kevin Wong Structint Terry Herrmann Structint Alexandria Scott Westinghouse (W)
Andrew Hawk W
Anees Udyawar W
Brian Hall W
David DiBasilio W
91 Daniel Carlin W
Donald McNutt W
Derek Simpson W
Gordon Hall W
Ian Senior W
Jeremy Leghorn W
Maria Rizzilli W
Stephen Longwell W
Xi Liu W
6.
Exit Meeting An exit meeting was held with the applicant on August 22, 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 SLRA review.