NRC 2004-0071, License Renewal Application Clarifications

License Renewal Application Clarifications

ML042030310
Person / Time
Site:	Point Beach
Issue date:	07/12/2004
From:	Koehl D Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC 2004-0071, TAC MC2099, TAC MC2100
Download: ML042030310 (24)

Text

Committed to Nuclear Excellence Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC July 12, 2004 NRC 2004-0071 10 CFR 54 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 License Renewal Application Clarifications (TAC Nos. MC2099 And MC 2100)

By letter dated February 25, 2004 (NRC 2004-0016), Nuclear Management Company, LLC, submitted the Point Beach Nuclear Plant (PBNP) Units 1 and 2 License Renewal Application (LRA). During the weeks of April 26 and June 7, 2004, the NRC performed an on-site audit of the PBNP aging management programs and aging management reviews. As a result of this audit and subsequent conversations between NMC and the NRC staff, the NRC staff requested the enclosed clarifying information.

Should you have any questions concerning this submittal, please contact Mr. James E. Knorr at (920) 755-6863.

Summary of Commitments This letter makes the following new commitments:

Audit Commitment Due Date or Item Frequency No.

66 Provide additional sub-criticality detail in the Boraflex 2005 LRA annual Monitoring Program description in Appendix B of the update annual update to the LRA.

67 Add appropriate references to Section 4.4.3 and/or 2005 LRA annual 4.4.4 in Appendix B to the LRA to indicate where the update reviewer can find the analysis that PBNP conducted for Cast Austenitic Stainless Steel.

6590 Nuclear Road

• Two Rivers, Wisconsin 54241 Telephone: 920.755.2321

'093

Document Control Desk Page 2 Audit Commitment Due Date or Item Frequency No.

85 A Reactor Vessel Internals Program will be submitted to Two years prior the NRC for review and approval.

to entering into the period of extended operation.

107 The Buried Services Monitoring Program, Parameters 2005 LRA Monitored or Inspected section will include if there are annual update any indications of selective leaching or if the condition is indeterminate, then a hardness test will be performed.

111 The Structures Monitoring Program, Scope of Program 2005 LRA section will be revised to add more detail to specifically annual update describe overhead crane locations in the program scope.

112 The steel edge supports and bracing for the masonry 2005 LRA wall description will be added to the Structures annual update Monitoring Program, Scope of Program.

119 Additional detail on recent cable testing and 2005 LRA manufacturer's recommended testing will be added to annual update the Cable Condition Monitoring Program Aging Management Program description in the LRA and/or the program basis document as appropriate.

Add trending of test results to the Cable Condition 2005 LRA Monitoring Program Aging Management Program annual update description in the LRA and/or the program basis document as appropriate.

The first Cable Condition Monitoring Program testing is Prior to entering to be completed prior to the period of extended the period of operation.

extended operation 134 The Aging Management Review results in Section 3 of 2005 LRA the LRA will be revised to include loss of material being annual update managed by the Periodic Surveillance and Preventive Maintenance Aging Management Program.

135 The Aging Management Review Results in Section 3 of 2005 LRA and the LRA will be revised to change note references as annual update 137 appropriate for copper alloys 136 A note correction deleting note F will be made in Table 2005 LRA 3.3.2-11 of the LRA.

annual update 147 The recirculation line orifices in the RHR system will be 2005 LRA added to the scope of the One-Time Inspection Program annual update of the LRA.

I Document Control Desk Page 3 I declare under penalty of perjury that the forgoing is true and correct. Executed on July 12, 2004.

Dennis L. Koehl Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC Enclosure cc:

Administrator, Region l1l, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW

ENCLOSURE CLARIFICATIONS TO POINT BEACH NUCLEAR PLANT LICENSE RENEWAL APPLICATION INFORMATION AS A RESULT OF AGING MANAGEMENT PROGRAM AND AGING MANAGEMENT REVIEW AUDITS OF APRIL AND JUNE 2004 o Audit item 66: From the results of the blackness testing, a calculation/analysis of the criticality margin is performed to ensure the 5% sub-criticality margin is met.

Technical Specifications 3.7.12, Spent Fuel Pool Storage, addresses fuel assembly storage in the spent fuel pool. The wording in the Boraflex Monitoring Program will be revised in the annual update to the LRA.

• Audit item 67: PBNP LRA, Appendix B, Section B2.0, "Aging Management Programs Correlation," provides a table correlating the NUREG-1 801 aging management programs to the PBNP programs. The explanation in this table as to why PBNP does not need an aging management program for thermal aging embrittlement of cast austenitic stainless steel (CASS) correlates to NUREG-1801,Section XI.M12 and will be updated during the 2005 annual update of the PBNP LRA. The update to Appendix B will include references to PBNP LRA Sections 4.4.3 and 4.4.4 to indicate where the reviewer can find the details of the analysis that PBNP conducted for its CASS material.

• Audit item 69: In general, aging management programs are made up of distinct aging management activities that are performed in accordance with various plant implementing documents (e.g., procedures). These plant implementing documents provide the administrative controls for performing the aging management activity.

Some of these activities may be required by the plant technical specifications surveillance requirements, while others implement actions to maintain plant equipment based on manufacturer recommendations and good practices such as preventive maintenance. Various surveillance and preventive maintenance activities have been credited and are relied on to replace or manage the age-related degradation of structures and components within the scope of license renewal at PBNP. These aging management activities are performed on a specified frequency or periodicity based on operating experience or other requirements (e.g., technical specifications, code requirements).

The frequency of these predefined/recurring surveillance and preventive maintenance activities are specified by call-ups maintained in the Computerized History and Maintenance Planning System (CHAMPS) at PBNP. CHAMPS is a computer based program in which records of work performed on plant systems, structures and components (SSC) are initiated and managed. Call-ups are another type of implementing document credited for license renewal at PBNP. Call-ups can be stand alone documents that contain all of the steps necessary to perform an Page 1 of 21

aging management activity, simply reference other plant implementing documents (e.g., procedures), or any combination of the above. CHAMPS also maintains a record of the frequencies and provides a work planning tool for these call-ups.

Individual surveillance and preventive maintenance Work Orders for call-ups performed at regular intervals are forecast in CHAMPS from the controlled master call-up files to support the long range scheduling of these activities. Work Orders are records created in CHAMPS to assign, manage, track the status, and identify the scope of work. The work scope is identified directly by the call-up or through reference to applicable Work Plans, drawings, and approved procedures. Work Plans provide a formatted description of the work scope to be performed in implementing the activity.

The Periodic Surveillance and Preventive Maintenance Program provides the following:

o Control criteria for aging management activities defined by call-ups credited in the Periodic Surveillance and Preventive Maintenance Program and 23 other aging management programs identified in Appendix B of the PBNP LRA.

o A description of the activities defined by call-ups for certain structures and components within the scope of license renewal credited directly by the Periodic Surveillance and Preventive Maintenance Program. These activities include:

• Replacement activities with a specified interval that are used as a basis for declaring that an aging management review (AMR) is not required in accordance with 10 CFR 54.21 (a)(1).

• Aging management activities that ensure the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation in accordance with 10 CFR 54.21 (a)(3).

A list of the 23 other aging management programs in Appendix B of the PBNP LRA that credit the Periodic Surveillance and Preventive Maintenance Program is provided in Table 1. As stated above, the Periodic Surveillance and Preventive Maintenance Program provides control criteria for aging management activities defined by call-ups credited by these programs. Aging management activities defined by call-ups are subject to the constraints described below regarding frequency changes, deferrals, and cancellations. Plant procedures will be revised accordingly to ensure that these requirements are met.

Surveillance and preventive maintenance activities credited for license renewal shall Page 2 of 21

be completed within a grace period of 125% of their assigned interval, not to exceed 2 years. The frequency of surveillance and preventive maintenance activities that are credited for license renewal may be adjusted, or the activity deferred or canceled provided an evaluation is performed justifying the change from a license renewal perspective based on plant and industry operating experience. This evaluation will ensure that the effects of aging will be adequately managed so that the intended function(s) of structures and components within the scope of license renewal will be maintained consistent with the current licensing basis for the period of extended operation in accordance with 10 CFR 54.21 (a)(3). An Action Request will be initiated for any surveillance or preventive maintenance activity credited for license renewal that is not completed within its allowed grace period, unless the activity has been properly deferred or cancelled.

The majority of surveillance and preventive maintenance activities are credited by aging management programs other than the Periodic Surveillance and Preventive Maintenance Program. This was done in order to be consistent with the program usage identified in NUREG-1 801, "Generic Aging Lessons Learned (GALL) Report."

These surveillance and preventive maintenance activities are evaluated as a part of these other programs. As a result, the ten elements described in Appendix B of the PBNP LRA for these other programs contain all of the details relative to these aging management activities. Therefore, when one of these other programs is referenced in a specific AMR line item in the 3.x.2 tables in Section 3.0 of the PBNP LRA, the details of the aging management activities are fully described in Appendix B of the PBNP LRA for the corresponding program. Although the ten elements of the Periodic Surveillance and Preventive Maintenance Program are written to be applicable to any surveillance or preventive maintenance activity, it is primarily the constraints placed on deferrals, cancellations, and frequency changes (i.e., control function) that applies to these other programs.

The remaining surveillance and preventive maintenance activities are directly credited by the Periodic Surveillance and Preventive Maintenance Program. These activities are either replacement activities or aging management activities that could not be correlated to another aging management program. Components that are replaced on a specified interval (e.g., relief valves) do not require an Aging Management Review in accordance with 10 CFR 54.21 (a)(1). In general, the effects of aging on a component are cumulative throughout its installed service life. One way to effectively mitigate these aging effects is to periodically replace the component on a specified interval to prevent age-related degradation leading to a loss of intended function. When a component is replaced in accordance with a specified time period, it is assumed that an appropriate replacement interval is established. In such cases, there is a high likelihood that the detrimental effects of aging will not accumulate during the replacement interval such that there is a loss of intended function, and therefore, no aging management is required. However, should a component no longer be replaced on a specified time period aging management would be required. Therefore, these replacement activities were Page 3 of 21

identified as part of the Periodic Surveillance and Preventive Maintenance Program so that they could be flagged as requiring replacement on a specified frequency based on operating experience. If the replacement is discontinued, an AMR must be performed and an aging management program credited, if appropriate.

The surveillance and preventive maintenance activities directly credited by the Periodic Surveillance and Preventive Maintenance Program for aging management are a collection of call-ups that could not be correlated to another aging management program. The AMR line items in the 3.x.2 tables in Section 3.0 of the PBNP LRA identify the component types, materials, environments, and aging effects being directly managed by the Periodic Surveillance and Preventive Maintenance Program. The surveillance and preventive maintenance activities that manage these aging effects are described in the ten elements of the Periodic Surveillance and Preventive Maintenance Program presented in Section B2.1.15 of Appendix B to the PBNP LRA. The ten elements of the Periodic Surveillance and Preventive Maintenance Program are written to be applicable to any surveillance and preventive maintenance activity, including the constraints placed on deferrals, cancellations, and frequency changes (i.e., control function). The level of detail presented in the ten elements of the Periodic Surveillance and Preventive Maintenance Program is consistent with the level of detail provided in the Reference Plant LRA (Section B2.1.23) and found acceptable by the NRC in the Reference Plant SER (Section 3.0.3.8), which is cited here as precedence. Additional details of these activities are available on-site for audit by the NRC in the supporting documentation for the PBNP LRA.

TABLE 1 AGING MANAGEMENT PROGRAMS THAT CREDIT THE PERIODIC SURVEILLANCE AND PREVENTIVE MAINTENANCE PROGRAM LRA, App. B, Title Section No.

B2.1.1 ASME Section XI, Subsections IWB, IWC and IWD Inservice Inspection Program B2.1.2 ASME Section Xl, Subsections IWE & IWL Inservice Inspection Program B2.1.3 ASME Section XI, Subsection IWF Inservice Inspection Program B2.1.4 Bolting Integrity Program B2.1.5 Boraflex Monitoring Program B2.1.6 Boric Acid Corrosion Program B2.1.7 Buried Services Monitoring Program B2.1.8 Cable Condition Monitoring Program Page 4 of 21

LRA, App. B, Title Section No.

B2.1.9 Closed-Cycle Cooling Water System Surveillance Program B2.1.10 Fire Protection Program B2.1.11 Flow-Accelerated Corrosion Program B2.1.12 Fuel Oil Chemistry Control Program B2.1.13 One-time Inspection Program B2.1.14 Open-Cycle Cooling (Service) Water System Surveillance Program B2.1.16 Reactor Coolant System Alloy 600 Inspection Program B2.1.17 Reactor Vessel Internals Program B2.1.18 Reactor Vessel Surveillance Program B2.1.19 Steam Generator Integrity Program B2.1.20 Structures Monitoring Program B2.1.21 Systems Monitoring Program B2.1.22 Tank Internal Inspection Program B2.1.23 Thimble Tube Inspection Program B2.1.24 Water Chemistry Control Program Audit item 85: A combination of the ASME Section Xl, Subsections IWB, IWC, and IWD Inservice Inspection Program and the Reactor Vessel Internals (RVI) Program will be used to manage loss of fracture toughness due to neutron irradiation embrittlement and/or void swelling in susceptible RVI components.

PBNP will continue to participate in industry groups studying RVI materials degradation issues, such as the EPRI MRP RI-ITG and Westinghouse Owner's Group, for the purpose of evaluating the significance of void swelling on selected PWR reactor vessel internals components. As new information and technology becomes available, the plant-specific Reactor Vessel Internals Program will be modified to incorporate enhanced inspections of appropriate components as necessary.

The revised Reactor Vessel Internals Program will be submitted to the NRC for review and approval two years prior to entering into the period of extended operation.

Audit item 107 As part of the LRA annual update, the Buried Services Monitoring Program - Parameters Monitored or Inspected section will have the following additional information inserted: If there are any indications of selective leaching or if the condition is indeterminate, then a hardness test will be performed.

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o Audit item 111: As part of the LRA annual update, the Structures Monitoring Program, Scope of Program section will be revised to add more detail specifically describing overhead crane locations in the program scope.

o Audit item 112: The steel edge supports and bracing for the masonry wall description will be added to the Structures Monitoring Program, Scope of Program as part of the LRA annual update.

o Audit item 119: The Cable Condition Monitoring Program (62.1.8 of the PBNP LRA) for non-EQ electrical cables used in nuclear instrumentation circuits includes the source range, intermediate range and power range circuits of the excore detectors.

These circuits contain instruments that use electrical cables that carry sensitive, low level signals. The program does not use the calibration approach since these cables are disconnected from their circuits during calibration. Instead, these cables are tested once every 10 years to detect a significant reduction in cable insulation resistance. The first tests for license renewal are to be completed before the period of extended operation. In fact these circuits have already been tested as part of the normal system condition monitoring by the system engineer at PBNP.

The specific type of test performed is determined prior to testing and capable of detecting a significant reduction in cable insulation resistance. A significant reduction in insulation resistance is defined as a reduction in insulation resistance that adversely affects the accuracy of nuclear instrumentation circuits.

Appropriate tests, based on the manufacturer's recommendations, may include insulation resistance tests, time domain reflectometry (TDR) tests, or IV testing to identify the potential existence of a reduction in cable insulation resistance.

Additional information such as impedance, dissipation factor, and quality factor data may also be obtained. Trending of test results will be performed as required to detect and predict degradation in IR below an acceptable level. The acceptance criteria for each test is defined by the specific type of test performed and the specific cable tested in the nuclear instrumentation circuits. If an unacceptable condition or situation were identified, a determination would be made as to whether the same condition or situation is applicable to other cables used in nuclear instrumentation circuits.

o Audit item 133: For steel commodities (e.g., pipe) embedded in concrete (not wetted), the high alkalinity of concrete provides an environment that mitigates corrosion. Hence, there are no applicable aging mechanisms for embedded steels.

o Audit item 134: This is the charging pump speed controller backup air compressor.

This is a portable compressor for Appendix R concerns that is normally not installed on any system. (Note that modifications are in progress to change the design of the charging pumps control system to eliminate the need for control air. Once these modifications are complete, the need for this back-up air compressor will also be Page 6 of 21

eliminated.) Although PBNP plant specific operating experience supports the conclusion of no aging effects for this component, this component is susceptible to general corrosion for cast iron in an air and gas (not dried) environment (per the EPRI tools). The Aging Management Review results will be changed to include loss of material (due to general corrosion) and will be managed by the Periodic Surveillance and Preventive Maintenance Aging Management Program.

o Audit item 135: Although the GALL reference does include copper alloys for this component (VII. C1.2-a materials include bronze and aluminum bronze) the Note will be changed from B to F, 5 in the annual update to the LRA.

o Audit item 136: The inclusion of Note F for this line item was included in error. Note F will be deleted as part of the annual update to the LRA.

o Audit item 137: Although the GALL reference does include copper alloys for this component (VII. C1.2-a materials include bronze and aluminum bronze) the Note will be changed from B to F, 5 in the annual update to the LRA.

o Audit item 138: In accordance with the EPRI material science documents, no aging effects exist for this material in these environments and this is substantiated by PBNP plant specific operating experience Table 3.x.2, Note 16 for a particular component states that elastomer (e.g., neoprene, rubber, etc.) components are indoors and not subject to ultra violet light or ozone, nor are they in locations that are subject to radiation exposure. These locations are also not subject to temperatures where change in material properties or cracking could occur (>95 degrees F).

Therefore, no aging management is required. Although Table 3.0-2 states that Indoor No Air Conditioning environment may achieve temperature variations between 70 to 120 degrees F with 100% humidity, this is provided as a generic environment whereas Note 16 is a specific environment for this material in a specific location. These components were evaluated individually for both an internal environment of "raw water" and an external environment of 'indoor no air conditioning" with regard to these criteria and as a result, were either managed due to the potential for the applicable effects/mechanisms for these environments or noted as not applicable where these criteria did not apply.

Audit item 141: Loss of material (due to general and/or crevice corrosion) is an aging effect that is not identified in NUREG-1801 for these RCS components. PBNP has chosen to include loss of material as a potential aging effect. The Water Chemistry Aging Management Program is a mitigation program. Primary Water Chemistry will control contaminants and oxygen content, which will sufficiently mitigate this potential aging effect.

In the SER for WCAP-1 4574-A, Aging Management Evaluation for Pressurizers, the staff concludes that general and crevice corrosion will be managed as long as the "aggressive corrosive effect of oxygen" is controlled by the Water Chemistry Control Page 7 of 21

Program (see Applicant Action Item 3.2.2.1-1). A one-time inspection is not included or required, to verify the effectiveness of the Water Chemistry Control Program.

A similar conclusion is reached in the SER for WCAP-14575-A, Aging Management Evaluation for Class 1 Piping and Associated Pressure Boundary Components, which is mainly attributed to the tight control of water chemistry.

PBNP has multiple opportunities for inspections of these components every outage when systems are opened. Industry operating experience along with PBNP's plant specific operating experience has been excellent to-date, and has demonstrated that general and crevice corrosion are not active degradation mechanisms within Class 1 piping and components.

Therefore, for the case of Class 1 piping and components (as identified in this question), the Water Chemistry Program alone, has proven to be effective in managing this aging effect (loss of material).

Audit item 142: For those line items in Table 3.x.1 that require "further evaluation,"

an evaluation was performed that justifies the use of the credited aging management program to adequately manage the effects of aging. These evaluations documented in Appendix B of the LRA and supporting project reports concluded that the aging management programs specified will adequately manage the aging effects listed for the subject line items. The following responses are intended to provide the justification for the selection of the aging management programs for the Table 3.x.1 line items that require "further evaluation." These justifications were not provided for each line item because they would have been repeated many times when the same program is credited, but they were provided for each program in Appendix B.

Reactor Coolant Systems 3.1.2.2.2.1 Loss of material due to pitting and crevice corrosion could occur on the secondary-side internal surfaces of the steam generators. The Water Chemistry Control Program conforms to the guidelines in EPRI TR-1 05714, Rev. 4, and TR-102134, Rev. 5. The Water Chemistry Control Program mitigates aging effects such as loss of material due to pitting and crevice corrosion, by controlling the environment to which the secondary-side internal surfaces of the steam generators are exposed. This aging effect is minimized by controlling the chemical species that cause the underlying mechanisms that result in this aging effect. The program provides assurance that an elevated level of contaminants and oxygen does not exist on the secondary-side internal surfaces of the steam generators, and thus minimizes the occurrences of this aging effect. The Water Chemistry Control Program has been in use since initial plant operation and has been effective at maintaining the desired system water chemistry and detecting abnormal conditions, Page 8 of 21

which have been corrected in an expedient manner. Therefore, the Water Chemistry Control Program effectively mitigates the loss of material due to pitting and crevice corrosion on the secondary-side internal surfaces of the steam generators. However, the Water Chemistry Control Program does not preclude loss of material due to pitting and crevice corrosion. Verification of the effectiveness of the program will be performed to ensure that corrosion is not occurring.

Inservice inspections performed in accordance with the ASME Section XI, IWB, IWC, and IWD Inservice Inspection Program are credited to manage the aging effect "loss of material" due to pitting and crevice corrosion in order to confirm the effectiveness of the Water Chemistry Control Program. The extent and schedule of the existing steam generator inspections are designed to ensure that flaws cannot attain a depth sufficient to threaten the integrity of the welds. However, according to NRC Information Notice 90-04, if general corrosion pitting of the shell exists, the program may not be sufficient to detect pitting corrosion. Therefore, the Steam Generator Integrity Program is used to augment these inspections to manage this aging effect. The Steam Generator Integrity Program performs periodic visual inspections to verify the integrity of the secondary-side internal surfaces of the steam generators.

Therefore, a combination of the Water Chemistry Control Program, ASME Section Xl, IWB, IWC, and IWD Inservice Inspection Program, and the Steam Generator Integrity Program is used to manage this aging effect.

3.1.2.2.8 Crack initiation and growth due to SCC and IASCC could occur in the baffle/former bolts of the reactor vessel internals. The Water Chemistry Control Program conforms to the guidelines in EPRI TR-1 05714, Rev. 4, and TR-1 02134, Rev. 5.

The Water Chemistry Control Program mitigates aging effects such as crack initiation and growth due to SCC and IASCC, by controlling the environment to which the baffle/former bolts are exposed. This aging effect is minimized by controlling the chemical species that cause the underlying mechanisms that result in this aging effect. The program provides assurance that an elevated level of contaminants and oxygen does not exist in the reactor coolant system, and thus minimizes the occurrences of this aging effect. The Water Chemistry Control Program has been in use since initial plant operation and has been effective at maintaining the desired system water chemistry and detecting abnormal conditions, which have been corrected in an expedient manner. Therefore, the Water Chemistry Control Program effectively mitigates crack initiation and growth due to SCC and IASCC in the baffle/former bolts of the reactor vessel internals. However, the Water Chemistry Control Program does not preclude crack initiation and growth due to SCC and IASCC, and verification of the effectiveness of the program will be performed to ensure that cracking is not occurring.

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The Reactor Vessel Internals Program will be used to manage these aging effects for the baffle/former bolts in order to confirm the effectiveness of the Water Chemistry Control Program. This program provides for inservice inspections in accordance with ASME Section Xl requirements, including examinations performed during the 1 0-year ISI examination. However, VT-3 visual examinations historically have not identified baffle/former bolt cracking because the cracking occurs at the juncture of the bolt head and shank, which is not accessible for visual inspection.

Recent UT examinations of the baffle/former bolts at several plants have identified cracking. Therefore, this program also provides for a baffle-former/barrel-former bolt evaluation that will determine the acceptability of the current arrangement or if ultrasonic examination and/or replacement of these bolts is necessary. A portion of the baffle-former bolts in the PBNP Unit 2 internals have already been replaced with a more crack resistant material.

Therefore, a combination of the Water Chemistry Control Program and the Reactor Vessel Internals Program will be used to manage this aging effect.

3.1.2.2.11 New, replacement recirculating steam generators were installed at PBNP (Unit 1 in 1983 and 1984, Unit 2 in 1996). These new steam generators incorporate many enhancements in design and materials of construction, to minimize aging effects.

However, cracking due to PWSCC and IGA/IGSCC and loss of material due to pitting and wear could occur in the PBNP steam generator tubes and plugs.

The Water Chemistry Control Program conforms to the guidelines in EPRI TR-1 05714, Rev. 4, and TR-1 02134, Rev. 5. The Water Chemistry Control Program mitigates aging effects such as cracking due to PWSCC and IGA/IGSCC and loss of material due to pitting and wear by controlling the environment to which the steam generator tubes and plugs are exposed. These aging effects are minimized by controlling the chemical species that cause the underlying mechanisms that result in these aging effects. The program provides assurance that an elevated level of contaminants and oxygen does not exist in either the primary or secondary sides of the steam generators, and thus minimizes the occurrences of these aging effects.

The Water Chemistry Control Program has been in use since initial plant operation and has been effective at maintaining the desired primary and secondary water chemistry and detecting abnormal conditions, which have been corrected in an expedient manner. Therefore, the Water Chemistry Control Program effectively mitigates cracking due to PWSCC and IGA/IGSCC and loss of material due to pitting and wear in the steam generator tubes and plugs. However, the Water Chemistry Control Program does not preclude cracking due to PWSCC and IGA/IGSCC and loss of material due to pitting and wear, and verification of the effectiveness of the program will be performed to ensure that these aging effects are not occurring.

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The Steam Generator Integrity Program is used to manage these aging effects for the steam generator tubes and plugs in order to confirm the effectiveness of the Water Chemistry Control Program. The Steam Generator Integrity Program was developed to meet the guidelines of NEI 97-06. The program manages these aging effects through a balance of prevention, inspection, evaluation, repair, and leakage monitoring measures. Eddy Current Testing is used to detect steam generator tube flaws and degradation. Steam generator tubes not meeting the Technical Specification limits for continued operation are removed from service by installation of tube plugs. Tube plugs installed in the steam generators are fabricated from heat treated Inconel Alloy 690 material. Although these plugs have a high resistance to PWSCC, they are routinely inspected as a part of the program. A tube integrity assessment is performed following each steam generator tube inspection to ensure that the performance criteria have been met for the previous operating period and will continue to be met for the next period.

Therefore, a combination of the Water Chemistry Control Program and the Steam Generator Integrity Program is used to manage these aging effects.

3.1.2.2.13 New replacement recirculating steam generators were installed at PBNP (Unit 1 in 1983 and 1984, Unit 2 in 1996). These new steam generators incorporate many enhancements in design and materials of construction to minimize aging effects.

There are no carbon steel tube support materials in the PBNP steam generators.

However, cracking due to SCC was identified as an aging effect that could occur in the steam generator stainless steel tube support plates.

The Water Chemistry Control Program conforms to the guidelines in EPRI TR-1 05714, Rev. 4, and TR-1 02134, Rev. 5. The Water Chemistry Control Program mitigates aging effects such as cracking due to SCC, by controlling the environment to which the steam generator stainless steel tube support plates are exposed. This aging effect is minimized by controlling the chemical species that cause the underlying mechanisms that result in the aging effect. The program provides assurance that an elevated level of contaminants and oxygen does not exist in either the primary or secondary sides of the steam generators, and thus minimizes the occurrences of this aging effect. The Water Chemistry Control Program has been in use since initial plant operation and has been effective at maintaining the desired primary and secondary water chemistry and detecting abnormal conditions, which have been corrected in an expedient manner. Therefore, the Water Chemistry Control Program effectively mitigates cracking due to SCC in the steam generator stainless steel tube support plates. However, the Water Chemistry Control Program does not preclude cracking due to SCC, and verification of the effectiveness of the program will be performed to ensure that this aging effect is not occurring.

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The Steam Generator Integrity Program is used to manage this aging effect for the steam generator stainless steel tube support plates in order to confirm the effectiveness of the Water Chemistry Control Program. The Steam Generator Integrity Program was developed to meet the guidelines of NEI 97-06. The program manages this aging effect through a balance of prevention, inspection, evaluation, repair, and leakage monitoring measures. Periodic visual inspections of accessible areas are performed to verify the integrity of secondary-side components, including the steam generator stainless steel tube support plates.

Therefore, a combination of the Water Chemistry Control Program and the Steam Generator Integrity Program is used to manage this aging effect.

Auxiliary Systems 3.3.2.2.5 This section deals with the management of loss of material due to general, pitting and crevice corrosion, and microbiologically induced corrosion, for internal surfaces within ventilation and emergency power systems, and for external surfaces of carbon steel component in Auxiliary Systems.

The internal environments associated with this line item are those in which the internal surfaces are subject to normal atmospheric air and are also prone to wetting or condensation. The Periodic Surveillance and Preventive Maintenance Program (PSPM) provides for inspections of these selected internal surfaces which will look for and be able to detect this aging effect. The Tank Internal Inspection Program also provides for the inspection of selected tank internals that will look for and be able to detect this aging effect. Therefore, application of the PSPM Program or the Tank Internal Inspection Program provides adequate assurance that this aging effect will be managed throughout the period of extended operation.

For external surfaces, the Systems Monitoring Program provides for visual inspections and monitoring of external surfaces of piping, tanks, and other components and equipment, for leakage and evidence of material degradation.

These inspections and monitoring are able to identify the aging effect of concern (loss of material) on external surfaces, prior to a loss of intended function of these components.

The Open-Cycle Cooling Water Program and the Fire Protection Program both provide for wall thickness assessments (looking for this loss of material) to be performed. These wall thickness assessments are typically performed from the outside of the components, and therefore are able to detect any external surface degradation. For that reason, these two programs augment the Systems Monitoring Program, for managing loss of material on the external surfaces of components within the Service Water System and the Fire Protection System. The One-Time Page 12 of 21

Inspection Program provides for inspections of components for various reasons.

During this inspection, the external surfaces of the components are inspected to identify this aging effect. Therefore, the Systems Monitoring Program, augmented in selected cases by the Open Cycle Cooling Water Program, the Fire Protection Program, or the One-Time Inspection Program, provides adequate assurance that loss of material on the external surfaces of components will be managed for the period of extended operation.

3.3.2.2.6 Loss of material due to general, galvanic, pitting, and crevice corrosion could occur in the Reactor Coolant Pump Oil Collection sub-system. The One-Time Inspection Program is credited to manage this aging effect. The One-Time Inspection Program addresses the potentially long incubation period for this aging effect and provides a means of verifying that this aging effect is either not occurring or progressing so slowly as to have negligible effect on the intended function(s) of the Reactor Coolant Pump Oil Collection sub-system.

Therefore, the One-Time Inspection Program is used to manage this aging effect.

3.3.2.2.7 Loss of material due to general, pitting and crevice corrosion, MIC, and biofouling could occur on the internal surfaces of fuel oil tanks. The Fuel Oil Chemistry Control Program is credited to manage these aging effects. The Fuel Oil Chemistry Control Program mitigates and manages these aging effects on the internal surfaces of fuel oil storage tanks and associated components in systems that contain fuel oil. The program includes (a) surveillance and monitoring procedures for maintaining fuel oil quality by controlling contaminants in accordance with applicable ASTM standards, (b) periodic draining of water from fuel oil tanks, (c) periodic or conditional visual inspections of internal surfaces or wall thickness measurements (e.g., by UT) from external surfaces of fuel oil tanks, and (d) one-time inspections of a representative sample of components in systems that contain fuel oil.

The objective of the Fuel Oil Chemistry Control Program is to minimize the introduction and presence of contaminants in the plant's Fuel Oil System that could cause degradation of components in systems that contain fuel oil. A representative sample of components in systems that contain fuel oil will be inspected via the One-Time Inspection Program. The One-Time Inspection Program addresses the potentially long incubation periods for these aging effects and provides a means of verifying that these aging effects are either not occurring or progressing so slowly as to have negligible effect on the intended function(s) of these components.

Therefore, a combination of the Fuel Oil Chemistry Control Program and One-Time Inspection Program is used to manage these aging effects.

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Engineered Safety Systems 3.2.2.2.3.2 Loss of material due to general, pitting and crevice corrosion, and MIC can occur in containment spray components, and containment isolation valves and associated piping. PBNP's RWST is located indoors, not buried, and not susceptible to a wetted environment, and therefore is not subject to this aging effect.

The Water Chemistry Control Program conforms to the guidelines in EPRI TR-105714, Rev. 4, and TR-1 02134, Rev. 5. The Water Chemistry Control Program mitigates aging effects such as loss of material due to general, pitting and crevice corrosion, and MIC, by controlling the environment to which containment spray components, and containment isolation valves and associated piping are exposed.

This aging effect is minimized by controlling the chemical species that cause the underlying mechanisms that result in this aging effect. The program provides assurance that an elevated level of contaminants and oxygen does not exist, and thus minimizes the occurrences of this aging effect. The Water Chemistry Control Program has been in use since initial plant operation and has been effective at maintaining the desired system water chemistry and detecting abnormal conditions, which have been corrected in an expedient manner. Therefore, the Water Chemistry Control Program effectively mitigates the loss of material due to general, pitting and crevice corrosion, and MIC on containment spray components, and containment isolation valves and associated piping. However, the Water Chemistry Control Program does not preclude loss of material due to general, pitting and

-crevice corrosion, and MIC, and verification of the effectiveness of the program will be performed to ensure that corrosion is not occurring.

The One-Time Inspection Program is credited to manage the aging effect loss of material due to general, pitting and crevice corrosion, and MIC in order to confirm the effectiveness of the Water Chemistry Control Program. The One-Time Inspection Program addresses the potentially long incubation period for this aging effect and provides a means of verifying that this aging effect is either not occurring or progressing so slowly as to have negligible effect on the intended function(s) of these components. To verify the effectiveness of water chemistry control, this program will perform a one-time inspection on selected components where the flow of water is low or stagnant conditions exist.

Therefore, a combination of the Water Chemistry Control Program and the One-Time Inspection Program is used to manage this aging effect.

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3.2.1-10 This line item deals with loss of material due to general corrosion on the external surfaces of carbon steel components.

The Systems Monitoring Program provides for visual inspections and monitoring of external surfaces of piping, tanks, and other components and equipment, for leakage and evidence of material degradation. These inspections and monitoring are able to identify the aging effects of concern (loss of material) on external surfaces, prior to a loss of intended function of these components.

Therefore, the Systems Monitoring Program is an appropriate program to manage loss of material on the external surfaces of carbon steel components.

Steam and Power Conversion 3.4.2.2.2 This section deals with the management of loss of material due to general, pitting, and crevice corrosion of pipe, fittings, valve bodies, and other various components.

The PBNP Water Chemistry Control Program conforms to the guidelines in EPRI TR-1 05714, Rev. 4. The Water Chemistry Control Program mitigates aging effects such as loss of material due to general, crevice, or pitting corrosion, by controlling contaminants and oxygen levels in the water environment. The control of these parameters has been shown to minimize these aging effects. Water chemistry, however, does not preclude the loss of material, and a one-time inspection of susceptible locations will be performed to verify the effectiveness of the Water Chemistry Program. Therefore, application of the Water Chemistry Control Program and the One-Time Inspection Program provides adequate assurance that loss of material will be managed throughout the period of extended operation.

In a few cases specific to relief valves, the valves are replaced on a specified frequency, and therefore PBNP credits the PSPM Program with managing this aging effect throughout the period of extended operation.

Additionally, in the case of the condensate storage tanks (found in Tanks in Auxiliary Feedwater), tank internal inspections will be performed that are able to verify the effectiveness of the Water Chemistry Control Program, and therefore the Tank Internal Inspection Program is used to manage this aging effect for these tanks, throughout the period of extended operation.

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3.4.2.2.4 This line item deals with loss of material due to general corrosion on the external surfaces of carbon steel components.

The Systems Monitoring Program provides for visual inspections and monitoring of external surfaces of piping, tanks, and other components and equipment, for leakage and evidence of material degradation. These inspections and monitoring are able to identify the aging effects of concern (loss of material) on external surfaces, prior to a loss of intended function of these components.

Therefore, the Systems Monitoring Program is an appropriate program to manage loss of material on the external surfaces of carbon steel components.

3.4.2.2.5.1 This section deals with the management of loss of material due to general, pitting and crevice corrosion, and MIC, within the lube oil portions of the Auxiliary Feedwater Pumps.

The Periodic Surveillance PM Program provides for periodic inspections of the lube oil portions of the Auxiliary feedwater pumps and testing of the lube oil, which is able to detect the presence of these aging effects/mechanisms. Therefore, the application of the PSPM Program provides adequate assurance that this aging effect (loss of material) will be managed throughout the period of extended operation.

Audit item 143:

Question 1 (a) The following table links the aging effects/mechanisms managed by the One-Time Inspection Program with the parameters monitored/inspected and the measurement methodology. The inspection method identified is capable of measuring the parameter monitored and providing data that is adequate to conclude the aging effect is managed consistent with the current licensing basis. If a different inspection method is used than that listed in the table below, the basis for the revised inspection method will be documented.

The One-Time Inspection Program manages these aging effects/mechanisms on the internal surfaces of components. Visual inspections are only performed when the component surface of interest is accessible. If degradation is identified through a visual inspection, additional NDE may be performed to characterize the degradation and determine the extent of condition.

Aging Effect Aging Parameter Measurement Mechanism Monitored Method Loss of Material Crevice Wall Thickness Visual (VT-1)

Corrosion and/or Page 16 of 21

Aging Effect Aging Parameter Measurement Mechanism Monitored Method Volumetric (RT or UT)

Loss of Material Galvanic Wall Thickness Visual (VT-3)

Corrosion and/or Volumetric (RT or UT)

Loss of Material General Wall Thickness Visual (VT-3)

Corrosion and/or Volumetric (RT or UT)

Loss of Material MIC Wall Thickness Visual (VT-3) and/or Volumetric (RT or UT)

Loss of Material Pitting Corrosion Wall Thickness Visual (VT-1) and/or Volumetric (RT or UT)

Loss of Material Selective Wall Thickness Visual (VT-3)

Leaching and/or Volumetric (RT or UT)

Loss of Material Erosion Wall Thickness Visual (VT-3) and/or Volumetric (RT or UT)

Loss of Heat Fouling Tube Fouling General or Transfer Remote Visual Cracking SCC Cracks Volumetric (RT o r U T )

Loss of Preload Stress Dimensional Visual (VT-3)

Relaxation Changes Question 1 (b) NDE exams performed as a part of the One-Time Inspection Program will be conducted in accordance with the requirements of ASME Section Xl and 10 CFR 50, Appendix B, except for the General or Remote Visual examinations. The General or Remote Visual examinations for loss of heat transfer due to fouling will be performed in accordance with the requirements of ASME Section V and 10 CFR 50, Appendix B.

o Audit item 147: The SRP Table 3.2-1 line item (3.2.1-08) referenced in the LRA provides a reference to the following SRP Section.

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"3.2.2.2.6 Local Loss of Material due to Erosion Local loss of material due to erosion could occur in the high pressure safety injection pump miniflow orifice.

This aging mechanism and effect will apply only to pumps that are normally used as charging pumps in the chemical and volume control systems (PWRs). The GALL report recommends further evaluation to ensure that the aging effect is adequately managed. Acceptance criteria are described in Branch Technical Position RSLB-1 (Appendix A.1 of this standard review plan)."

This not withstanding, the question was raised as to the potential for erosion on the mini-flow recirculation orifices on the Low Head SI pumps (RHR pumps) at PBNP. A review of the potential for loss of material due to cavitation was completed. The review concluded that cavitation could not be ruled out. Therefore, the downstream piping near the mini-flow orifices on the Low Head SI pumps (RHR pumps) will be examined under the One-Time Inspection Program as part of the 2005 annual update to the LRA.

Audit item 148:

Question 1. An "Action Request" is a form (electronic or hard copy) that provides the means by which a problem is documented and entered into the site's corrective action program. The frequency of surveillance and preventive maintenance activities that are credited for license renewal may be adjusted, or the activity deferred or canceled, provided an evaluation is performed within the corrective action program justifying the change from a license renewal perspective based on plant and industry operating experience. This evaluation will ensure that the effects of aging will be adequately managed so that the intended function(s) of structures and components within the scope of license renewal will be maintained consistent with the current licensing basis for the period of extended operation in accordance with 10 CFR 54.21 (a)(3). Completion of call-ups credited for license renewal within a grace period of 125%, not to exceed 2 years, will be a stated procedural requirement. Failure to comply with a procedural requirement is cause for the initiation of an Action Request to document the compliance failure and enter it into the corrective action program to ensure that the problem is appropriately addressed.

Question 2. The Periodic Surveillance and Preventive Maintenance (PSPM) program ensures that the administrative controls placed on surveillance and preventive maintenance activities implemented through the use of CHAMPS call-ups are adequate to allow the activity to be credited for aging management. There are no other functions of the PSPM program beyond the stated control criteria that are applicable to the 23 other aging management programs that credit the PSPM program.

Audit item 149: For the various line items that have no aging effects identified, and no AMP, there was typically no comparable line item referenced in GALL.

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Therefore, Note J, "Neither the component nor the material and environment combination is evaluated in NUREG-1801," was used for each of these line items.

This was not meant to imply that because GALL was silent on that specific material/environment that would justify our position of no aging effects.

As stated in LRA section 3.0.1.4, the determination of aging effects for PBNP was based primarily on the industry standard (EPRI) Mechanical Tools. The justification for the selection of no aging effects for these various material/environment combinations is based on the conclusions identified in the industry standard (EPRI)

Mechanical Tools. We also reviewed plant specific and industry OE, and did not find any aging associated with these material/environment combinations.

Audit item 150: When performing the GALL reconciliation with PBNP LRA 3.x.2 line items, we attempted to identify the GALL line item that fit closest to the PBNP line item. In some cases, PBNP identified aging effects that were different from those identified in the GALL. In these cases, Note H "Aging effect not in NUREG-1801 for this component, material and environment combination" was used. In the corresponding Table 3.x.1 line item, we would then address the management of the different aging effect, along with the aging effect initially identified in GALL.

In this instance, line item 3.3.1-09 and SRP section 3.3.2.2.9 discuss cracking.

PBNP also identified the potential for loss of material for components in this line item. The following justification for using the Water Chemistry Control Program and the One-Time Inspection Program to manage these aging effects is described in Appendix B and in plant documents.

The PBNP Water Chemistry Control Program conforms to the guidelines in EPRI TR-1 05714, Rev. 4. The Water Chemistry Control Program mitigates aging effects such as loss of material due to general, crevice, or pitting corrosion, and cracking due to SCC, by controlling contaminants and oxygen levels in the water environment. The control of these parameters has been shown to minimize these aging effects. Water chemistry, however, does not preclude the loss of material or cracking, and a one-time inspection of susceptible locations will be performed to' verify the effectiveness of the Water Chemistry Program.

Therefore, application of the Water Chemistry Control Program and the One-Time Inspection Program provides adequate assurance that loss of material and cracking are managed throughout the period of extended operation.

Audit item 196: The following table links the aging effects/mechanisms managed by the Periodic Surveillance and Preventive Maintenance Program with the parameters monitored/inspected and the measurement methodology. The inspection method identified is capable of measuring the parameter monitored and providing data that is adequate to conclude the aging effect is managed consistent with the current licensing basis. If a different inspection method is used than that listed in the table Page 19 of 21

below, the basis for the revised inspection method will be documented.

The Periodic Surveillance and Preventive Maintenance Program manages these aging effects/mechanisms on the internal and/or external surfaces of components.

Visual inspections are only performed when the component surface of interest is accessible. If degradation is identified through a visual inspection, additional NDE may be performed to characterize the degradation and determine the extent of condition.

Aging Effect Aging Mechanism Parameter Measurement Monitored Method Change in Material Elevated Temperature General General Visual Properties (1)

Surface Condition Cracking (1)

Elevated Temperature Cracks General Visual Cracking SCC Cracks Volumetric (RT or UT)

Cracking (1)

Ultraviolet Radiation Cracks General Visual and Ozone Loss of Heat Transfer Fouling Tube Fouling General or Remote Visual (2)

Loss of Material Crevice Corrosion Wall Visual (VT-1)

Thickness and/or Volumetric (RT or UT)

Loss of Material Erosion Wall Visual (VT-3)

Thickness and/or Volumetric (RT or UT)

Loss of Material Galvanic Corrosion Wall Visual (VT-3)

Thickness and/or Volumetric (RT or UT)

Loss of Material General Corrosion Wall Visual (VT-3)

Thickness and/or Volumetric (RT or UT)

Loss of Material MIC Wall Visual (VT-3)

Thickness and/or Volumetric (RT or UT) (2)

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+

Aging Mechanism Parameter Measurement Monitored Method Loss of Material Pitting Corrosion Wall Volumetric (RT Visual (VT-1) and/or Thickness or UT)

Loss of Material Selective Leaching Wall Volumetric (RT Visual (VT-3) and/or Thickness or UT)

Notes:

1. These aging effects/mechanisms only apply to the elastomer boot seals on the spent fuel transfer canal doors and the elastomer refueling cavity seal ring.

2. Where the material is in an oil or fuel oil environment, an oil sample will be taken and analyzed for evidence of MIC, corrosion products, and/or other contaminants in lieu of these inspections.

NDE exams performed as a part of the Periodic Surveillance and Preventive Maintenance Program will be conducted in accordance with the requirements of ASME Section Xl and 10 CFR 50, Appendix B, except for the General Visual and General or Remote Visual examinations. The General or Remote Visual examinations for loss of heat transfer due to fouling will be performed in accordance with the requirements of ASME Section V and 10 CFR 50, Appendix B.

The General Visual examination for change in material properties due to elevated temperature and cracking due to elevated temperature or ultraviolet radiation and ozone is not an NDE exam.

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