NRC 2005-0020, Amendment to the Point Beach Nuclear Plant License Renewal Application
| ML050610283 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 02/23/2005 |
| From: | Koehl D Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC 2005-0020, TAC MC2099, TAC MC2100 | |
| Download: ML050610283 (90) | |
Text
NM Committed to Nuclear Exceuen Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC February 23, 2005 NRC 2005-0020 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 Amendment to the Point Beach Nuclear Plant License Renewal Application (TAC Nos. MC2099 and MC2100)
By letter dated February 25, 2004, Nuclear Management Company, LLC (NMC),
submitted the Point Beach Nuclear Plant (PBNP) Units 1 and 2 License Renewal Application (LRA). In accordance with 10 CFR 54.21 (b), NMC is submitting an amendment to the LRA. Enclosure 1 contains the amendment, which identifies changes to the PBNP current licensing basis, since the time of the LRA submittal, that materially affect the contents of the LRA, including the Final Safety Analysis Report supplement.
Should you have any questions concerning this submittal, please contact Mr. James E. Knorr at (920) 755-6863.
This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the forgoing is true and correct. Executed on February 23, 2005.
Dennis L. Koehl Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC Enclosure 4bCA3 6590 Nuclear Road
- Two Rivers, Wisconsin 54241 Telephone: 920.755.2321
T-
-. 4 Document Control Desk Page 2 cc:
Administrator, Region 111, USNRC Project Manager, Point Beach Nuclear Plant, USNRC Resident Inspector, Point Beach Nuclear Plant, USNRC PSCW
ENCLOSURE AMENDMENT TO THE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION In accordance with 10 CFR 54.21 (b), NMC is submitting an amendment to the Point Beach Nuclear Plant (PBNP) License Renewal Application (LRA).
The enclosure is divided into three sections: (1) Methodology, (2) Current Licensing Basis Changes, and (3) Clarifying Changes to the LRA.
Methodology All plant changes made between February 15, 2003, and January 15, 2005, were reviewed in preparation of the amendment to the PBNP LRA. NMC evaluated the changes to the current licensing basis (CLB) and determined those that materially affected the contents of the LRA. This included the following reviews:
Equipment delta reports: The data in the PBNP License Renewal Database (LRDB) was compared with current data in the PBNP equipment database to identify new or changed equipment. This included reviewing changes to information that was used in scoping (in either the in-scope or out-of-scope direction).
Modification records: All modifications installed in 2003 and 2004 were reviewed for new equipment or changes to existing equipment.
FSAR changes: All changes incorporated in the August 2004 update of the FSAR and proposed changes to-date for the June 2005 update of the FSAR were reviewed for any potential licensing basis changes.
Spare Parts Equivalency Evaluation Documents (SPEEDs): SPEEDs between February 15, 2003, and January 15, 2005, were reviewed to identify any component material changes.
These reviews focused specifically on plant changes that would require new information or revisions to existing information in the PBNP LRA. These LRA changes are detailed later in this letter. In some cases, plant changes occurred in this time span, but there was no net affect on information contained in the LRA. These changes are not detailed further in this letter.
During preparation of the PBNP LRA, the June 2003 revision of the FSAR was used. This revision reflected the plant as it existed on February 15, 2003. Additionally, equipment Page 1 of 87
o database records were also recorded as of February 15, 2003, for use in the LRDB, which in turn was used to prepare the scoping and aging management tables in the LRA.
Current Licensing Basis Changes New three-hour rated Appendix R fire walls were installed in the Auxiliary Feedwater Pump Room and Unit 1 MCC Room (8 ft. elevation of the PAB). Wall construction features include a stud-wall of galvanized cold form steel studs and two layers of 3/4-in. Ultracode Core (U.S. Gypsum Co.) gypsum board on both faces of the wall. A new fire wall divides the Auxiliary Feedwater Pump Room into a north half and south half. The Unit 1 MCC Room fire wall provides required separation for the Unit 1 charging pump electric cables.
These walls are considered to be in-scope and subject to an aging management review (AMR). The wall material and environment have been reviewed and no aging effects requiring management have been identified. None the less, these walls and their penetrations have been added to the scope of the Fire Protection Program to ensure the maintenance of its intended function of "Fire Barrier."
The Component Type for this wall is listed in Table 2.4.11-1 as "Gypsum Board/Indoor - All:
Walls." Table 3.5.2-11, "Structures and Component Supports - Fire Barrier Commodity Group - Summary of Aging Management Evaluation," is revised to include a new material line item as a result of the AMR. The details for the new line item are shown in the clarifying changes to the LRA for LRA Section 3.5.
Page 2 of 87
Clarifying Changes to the LRA LRA Section 1 - ADMINISTRATIVE INFORMATION No changes to this section have been identified.
LRA Section 2 - SCOPING AND SCREENING METHODOLOGY FOR IDENTIFYING STRUCTURES AND COMPONENTS SUBJECT TO AGING MANAGEMENT REVIEW, AND IMPLEMENTATION RESULTS BACKGROUND During discussion with the NRC staff regarding non-safety high energy line piping and its relation to scoping in accordance with 10 CFR 54.4(a)(2), NMC identified that Table 2.1.2.1-1, "Criterion 2 Scoping Results," should have an additional line added to reflect high energy piping in the turbine building.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 2.1.2.1-1 on LRA page 2-28 is revised with an additional line item as follows:
Table 2.1.2.1-1, Criterion 2 Scoping Results Component Description Drawing Reason AMR Type(s)
Reference Addressing Items Pipe, Fittings High energy HELB pipe whip Main Steam, piping on the 26' Feedwater and elevation of Condensate Turbine Building near Main Feed Regulating and Bypass valves Page 3 of 87
BACKGROUND By letter dated January 31, 2005, NMC submitted a response to the NRC staff's request for additional information regarding 10 CFR 54.4(a)(2), non-safety affecting safety scoping clarifications (Section 2.1 of the LRA).
The January 31, 2005, letter contained the following commitment:
NMC will remove the "Exposure Duration" discussion from Section 2.1.2.1.2 of the PBNP LRA and will summarize the response to RAI 2.1.1 in the "Components Qualified/Designed for Environment" discussion as part of the LRA annual update.
Based upon the NRC staff request during the staff meeting with NMC on February 15, 2005, a revised methodology will be developed during an expanded effort for 10 CFR 54.4(a)(2),
non-safety affecting safety scoping. This methodology description and associated specific example exclusions will be provided to the NRC for their review upon completion of the scoping effort. As a result, the above commitment will be completed as part of the methodology revision.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION None at this time.
BACKGROUND As part of the review of the LRA during the NRC audit, NMC noted that the Component Type, "Masonry Block Wall/Buried - All: Manholes," was not contained in LRA Table 2.4.8 1, "Yard Structures."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 2.4.8-1 on LRA page 2-216 is revised with an additional line item as follows:
Table 2.4.8-1 Yard Structures Component Type Intended Function l
MASONRY BLOCK 9UPPORT NSB WALUBURIED - ALL:
MANHOLES Page 4 of 87
T BACKGROUND Plant modifications conducted since the LRA submittal include new three-hour rated Appendix R fire walls installed in the Auxiliary Feedwater Pump Room and Unit 1 MCC Room (8 ft. elevation of the PAB). This resulted in an additional line on Table 2.4.11-1, "Fire Barrier Commodity Group."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 2.4.11-1 on LRA page 2-226 is revised as follows:
Table 2.4.11-1 Fire Barrier Commodity Group Component Type Intended Function EMIRE BARRIER BOARD/INDOOR - ALL:
WALLS Page 5 of 87
LRA Section 3 - AGING MANAGEMENT REVIEW RESULTS LRA Section 3.1 AGING MANAGEMENT OF REACTOR COOLANT SYSTEM BACKGROUND As a result of precedence reviews of the LRA, three notes on three line items in Table 3.1.2-6, "Reactor Coolant System - Non-Class 1 RCS Components System - Summary of Aging Management Evaluation," were changed from "C" to "D."
Note D reads, "Component is different, but consistent with NUREG-1 801 for material, environment, aging effect and AMP. AMP has exceptions to NUREG-1801 AMP."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.1.2-6 on LRA page 3-125 is revised as shown on the next pages.
Page 6 of 87
Table 3.1.2-6 Reactor Coolant System - Non-Class 1 Manaaement Evaluation RCS Components System - Summary of Aging Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Heat Pressure Carbon/Low Containment Loss Of Material Systems (Vll.I.1-b)
(3.3.1-05) 35,4 Exchanger Boundary Alloy Steel (External)
Monitoring Program Oil and Fuel Oil Loss Of Material One-Time (VII.G.7.b)
(3.3.1-06) 35,,D (Internal)
Inspection Program Treated Water -
Loss Of Material Closed-Cycle (VII.C2.1-a)
(3.3.1-15) 35, D Other (Internal)
Cooling Water System Surveillance Program One-Time (VII.C2.1 -a)
(3.3.1-15) 35, 34 Inspection Program Copper Alloy N/A (External)
None None Required 8
(Zn <,15%)
Oil and Fuel Oil Loss Of Material One-Time (VII.G.7-b)
(3.3.1-06) 35, G D (Internal)
Inspection Program Treated Water -
Loss Of Material Closed-Cycle (VII.C2.1 -a)
(3.3.1-15) 35, F, 5 Other (Internal)
Cooling Water System Surveillance Program One-Time (VII.C2.1-a)
(3.3.1-15) 35, F, 5 Inspection Program Heat Pressure Copper Alloy N/A (External)
None None Required 8
Exchanger Boundary (Zn > 15%)
Oil and Fuel Oil Loss Of Material One-Time (VII.G.7-b)
(3.3.1-06) 35, G Q (Internal)
Inspection Program Page 7 of 87
A Table 3.1.2-6 Reactor Coolant System - Non-Class 1 RCS Components System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Treated Water -
Loss Of Material Closed-Cycle (VII.C2.1-a)
(3.3.1-15) 35, F, 5 Other (Internal)
Cooling Water System Surveillance Program One-Time (VJl.C2.1-a)
(3.3.1-15) 35, F, 5 Inspection P ro g ra m_
Page 8 of 87
LRA Section 3.2 AGING MANAGEMENT OF ENGINEERED SAFETY FEATURES BACKGROUND Based upon NRC Audit Team inquiries and additional PBNP reviews, revisions to Table 3.2.1, "Summary of Aging Management Evaluations in Chapter V of NUREG-1801 for Engineered Safety Features," line item 3.2.1-08 and LRA Section 3.2.2.2.6, "Local Loss of Material due to Erosion," were revised to reflect aging management of the potential for erosion of the mini-flow recirculation line orifices on the low head safety injection pumps (RHR pumps) at PBNP.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
LRA Section 3.2.2.2.6 Local Loss of Material due to Erosion (LRA Page 3-144)
The high pressure safety injection pumps are not used for normal charging at PBNP, and therefore, loss of material due to erosion of the high head safety injection (Si pump) mini-flow orifices is not applicable at PBNP. However, loss of material due to erosion could not be ruled out for the RHR pump mini-flow orifices, and therefore a one-time inspection will be performed to manage this potential aging effect.
Table 3.2.1, line item 3.2.1-08 on LRA page 3-146, is revised as shown on the next page.
Page 8 of 87
Table 3.2.1 Summary of Aging Management Evaluations in Chapter V of NUREG-1801 for Engineered Safety Features Item Component Aging Aging Further Discussion Number Effect/Mechanism Management Evaluation Program Recommended 3.2.1-08 High pressure safety Loss of material Plant specific Yes, plant Not applicable at injection (charging) pump due to erosion specific (see PBNP as St miniflow orifice
[SRP] subsection pumps are not 3.2.2.2.6) normally in ue.
Further evaluation documented in Section 3.2.2.2.6 Page 9 of 87
LRA Section 3.2 AGING MANAGEMENT OF ENGINEERED SAFETY FEATURES BACKGROUND Based upon NRC Audit Team inquiries and additional PBNP reviews, additional line items have been added to Table 3.2.2-3, "Engineered Safety Features - Residual Heat Removal System - Summary of Aging Management Evaluation," to reflect the addition of "Loss of Material due to cavitation erosion" as an Aging Effect Requiring Management for the "Restricting Orifices" Component Type. These line items were added for Intended Functions "Pressure Boundary" and "Restricts Flow."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.2.2-3 on LRA page 3-169 is revised as shown on the next page.
Page 10 of 87
Table 3.2.2-3 Engineered Safety Features - Residual Heat Removal System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring.
Management 1801 Item Management Programs Volume 2 Line Item Restricting Pressure Stainless Indoor - No Air None None Required J
Orifices Boundary Steel Conditioning (External)
Treated Water -
Loss Of Material One-Time V.D11.2-c, 3.2.1-08, H, 1, 3
- Borated, Inspection (V.A.1 -a)
(3.2.1-15)
T<140'F Program (Internal)
Water V.D1.2-c, 3.2.1-08, H, I, 3 Chemistry (V.A.1-a)
(3.2.1-15)
Control Program Loss of Material Qne-Time V.D1,2-c 3.2.1-08 4
due to cavitation hnspecfion erosimn Restricts Stainless Indoor - No Air None None Required J
Flow Steel Conditioning (External)
Treated Water -
Loss Of Material One-Time V.D1.2-c, 3.2.1-08, H, I, 3
- Borated, Inspection (V.A.1 -a)
(3.2.1-15)
T<140'F.
Program (Internal)
Water V.D1.2-c, 3.2.1-08, H, I, 3 Chemistry (V.A.1 -a)
(3.2.1-15)
Control Program Loss Of Material Qne-Time VD1.2-Q 32.j-08 4
due to cavitation Inspectio
_erosin emo ta Page 11 of 87
LRA Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS BACKGROUND By letter dated December 14, 2004, NMC submitted a response to the NRC staff's request for additional information regarding Auxiliary Systems (Section 2.3.3 of the LRA).
The December 14, 2004, letter contained the following commitment:
NMC will add line items to Table 3.3.2-2 to include stainless steel under the Component Type "Piping and Fittings" to address the flexible tubing as part of the License Renewal Application annual update.
An additional line item has been added to Table 3.3.2-2, "Auxiliary Systems - Component Cooling Water System - Summary of Aging Management Evaluation," on LRA page 3-223 to reflect the addition of stainless steel tubing for component cooling water to the reactor coolant pumps. This line item adds "Stainless Steel" as a material to the "Piping and Fittings" Component Type.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.3.2-2 on LRA page 3-223 is revised as shown on the next page.
Page 12 of 87
I, Table 3.3.2-2 Auxiliary Systems - Component Cooling Water System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Piping and Pressure Carbon/Low Containment Loss Of Material Systems VI1.1.1-b 3.3.1-05 4
Fittings Boundary Alloy Steel (External)
Monitoring Program Indoor - No Air Loss Of Material Systems VI1.1.1-b 3.3.1-05 4
Conditioning Monitoring (External)
Program Treated Water -
Loss Of Material Closed-Cycle VII.C2.1-a 3.3.1-15 B
Other (Velocity)
Cooling Water (Internal)
System Surveillance Program One-Time VII.C2.1-a 3.3.1-15 34 Inspection Program Sntainmnent Noned NoneRequid
.1 ste tExteMal Treated W
LoQLMaterialy Vll.C2.1a I3.-15 E
Other (Velocity Cooling Water (System Surveillance Program One-Time
_11:a 3.3.1:15 A
Inspection Page 13 of 87
LRA Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS BACKGROUND By letter dated July 12, 2004, NMC provided clarifications to the NRC staff as a result of questions raised during an audit regarding PBNP aging management programs and aging management reviews.
The July 12, 2004, letter contained the following commitment:
Audit Items 135 and 137 - The Aging Management Review Results in Section 3 of the LRA will be revised to change note references as appropriate for copper alloys.
Table 3.3.2-5, "Auxiliary Systems - Service Water System - Summary of Aging Management Evaluation," was revised to reflect the appropriate references (notes "F" and "5") for copper alloy material line items. Note F states, "Material not in NUREG-1 801 for this component."
Note 5 states, "Material/environment combination and/or aging effect not identified in NUREG-1 801. The aging management program(s) referenced are appropriate for the aging effects identified and provides assurance that the aging effects are effectively managed through the period of extended operation."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.3.2-5 on LRA pages 3-246 and 3-247 is revised as shown on the next pages.
Page 14 of 87
Table 3.3.2-5 Auxiliary Systems - Service Water System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Valve Pressure Copper Indoor -Air None None Required J
Bodies Boundary Alloy Conditioning (Zn <
(External) 15%)
Indoor - No Air None None Required J
Conditioning (External)
Raw Water Loss Of Material Open-Cycle VII.C1.2-a 3.3.1-17 8 E,5 (Internal)
Cooling (Service)
Water System Surveillance Program Raw Water Loss Of Material Open-Cycle Vll.C1.2-a 3.3.1-17 B,
(Stagnant)
Cooling (Service)
(Internal)
Water System Surveillance Program Periodic Vll.C1.2-a 3.3.1-17 13 Surveillance and Preventive Maintenance Program Raw Water Loss Of Material Open-Cycle Vll.C1.2-a 3.3.1-17 B, 15 (Velocity)
Cooling (Service)
(Internal)
Water System Surveillance Program Periodic Vll.C1.2-a 3.3.1-17 13 Surveillance and Preventive Maintenance Program Page 15 of 87
Table 3.3.2-5 Auxiliary Systems - Service Water System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Valve Copper Indoor - Air None None Required J
Bodies Alloy Conditioning (Zn >
(External) 15%)
Indoor - No Air None None Required J
Conditioning (External)
Pressure Copper Raw Water Loss Of Material Open-Cycle VII.C1.2-a 3.3.1-17 B E,5 Boundary Alloy (Stagnant)
Cooling (Service)
(Zn >
(Internal)
Water System 15%)
Surveillance Program Raw Water Loss Of Material Open-Cycle ViI.C1.2-a 3.3.1-17 ST 15 (Velocity)
Cooling (Service)
(Internal)
Water System Surveillance I Program I.
I Page 16 of 87
LRA Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS BACKGROUND As a result of review of draft RAls regarding fire protection, Table 3.3.2-6, "Auxiliary Systems - Fire Protection System - Summary of Aging Management Evaluation," was revised to include the "Air and Gas-Wetted, T<1400F (Internal)" Environment for the "Piping and Fittings" Component Type to address dry-pipe sections of piping in the Fire Protection system.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.3.2-6 on LRA page 3-253 is revised as shown on the next page.
Page 17 of 87
A Table 3.3.2-6 Auxiliary Systems - Fire Protection System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Piping and Pressure Carbon/Low Air and Gas None None Required J
Fittings Boundary Alloy Steel (Internal) l~Ua-Loss Of Material Eire Protection (Vl3.G.6a)
(3 35 Wetedogra 2
T<1 400F (Internall)
Buried Loss Of Material Buried Services VII.C1.1-b 3.3.1-18 A
(External)
Monitoring Program Concrete None None Required J
(External)
I Page 18 of 87
LRA Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS BACKGROUND As a result of reviews of modifications conducted since the LRA was submitted to the NRC, Table 3.3.2-7, "Auxiliary Systems - Emergency Power System - Summary of Aging Management Evaluation," was revised to include the "Air and Gas Wetted T<140'F (Internal)" Environment for the "Stainless Steel" Material that will be managed by the Periodic Surveillance and Preventive Maintenance Program. A modification replaced carbon steel piping between the emergency diesel generator (G-01) air start tanks and air start motors with stainless steel piping.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.3.2-7 on LRA page 3-273 is revised as shown on the next page.
Page 19 of 87
Table 3.3.2-7 Auxiliary Systems - Emergency Power System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -1801 Table 1 Item Notes Type Function Requiring Management Volume 2 Line Management Programs Item Piping and Pressure Copper Indoor - No Air None None Required J
Fittings Boundary Alloy (Zn <
Conditioning 15%)
(External)
Oil and Fuel Oil Loss Of Material Periodic J, 5 (Internal)
Surveillance and Preventive Maintenance Program Plastic Pipe Air and Gas -
None None Required J
Wetted, T<1400F (Internal)
Indoor - No Air None None Required J
Conditioning (External)
Stainless Indoor-No Air None None Required J
Steel Conditioning (External)__
Oil and Fuel Oil Loss Of Material Periodic J, 5 (Internal)
Surveillance and Preventive Maintenance Program Oil and Fuel Oil -
Cracking due to None Required J. 17 Pooling (Internal)
SCC Loss Of Material Fuel Oil (VII.H2.5-a)
(3.3.1-07)
F. 5 Chemistry Control Program One-Time (VII.H2.5-a)
(3.3.1-07)
F, 5 Inspection
____P rogram Air and Gas_
LossOiMateiial 122baft (Eeic-5
,Wetted, T<1 40'F Surveillance and prvemtiv Maintenance
_Erogram Page 20 of 87
LRA Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS BACKGROUND As a result of reviews of SPEEDs (Spare Parts Equivalency Evaluation Documents), line items will be added to Table 3.3.2-8, "Auxiliary Systems-Containment Ventilation System-Summary of Aging Management Evaluation," and Table 3.3.2-9, "Auxiliary Systems-Essential Ventilation System-Summary of Aging Management Evaluation," as shown in the partial tables on the following page. Additional Materials and associated Environments were identified. Aging management will be provided as noted in the tables.
In addition, by letter dated December 17, 2004, NMC submitted a response to the NRC staff's request for additional information regarding Auxiliary Systems - Ventilation (Section 2.3.3.10 of the LRA).
The December 17, 2004, letter contained the following commitment:
NMC will add line items to Table 3.3.2-9 to address the aging affects associated with the ventilation air intakes during the License Renewal Application annual update.
An additional line item has been added to Table 3.3.2-9 to reflect the addition of the air intakes.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Tables 3.3.2-8 and 3.3.2-9 on LRA pages 3-285, 3-286, and 3-290 are revised as shown in partial tables on the next pages.
Page 21 of 87
Page 3-285 Table 3.3.2-8 Auxiliary Systems - Containment Ventilation System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -1801 Table 1 Item Notes Type Function Requiring Management Volume 2 Line Management Programs Item Damper Pressure Carbon/Low Air and Gas None None J
Housings Boundary Alloy Steel (Internal)
Required Containment Loss Of Systems VII.1.1-b 3.3.1-05 4
(External)
Material Monitoring Program Stainless AandG None Nne I Steel (Inemall Requ ired I
Containment None N
( Extemal Required II Page 22 of 87
Page 3-286 Table 3.3.2-8 Auxiliary Systems - Containment Ventilation System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -1801 Table 1 Item Notes Type Function Requiring Management Volume 2 Line Management Programs Item Heat Heat HX-Copper Containment Loss of Heat Periodic (VII.F3.2-a)
(3.3.1-05)
H, 4 Exchanger Transfer Alloy (External)
Transfer due to Surveillance (Zn < 15%)
Fouling and Preventive Maintenance Program Raw Water Loss of Heat Open-Cycle (VII.C1.3-b)
(3.3.1-17)
D (Internal)
Transfer due to Cooling Fouling (Service)
Water System Surveillance Program Pressure Copper Alloy Indoor -
Loss Of Systems VII.F3.2-a 3.3.1-05 4
Boundary (Zn < 15%)
Wetted Material Monitoring (External)
Program Raw Water Loss Of Open-Cycle (VII.C1.3-a)
(3.3.1-17)
D (Internal)
Material Cooling (Service)
Water System Surveillance Program l
Stainless InWoQ~Air Noe No BawWater Loss of O
pen-Cycle Vl01.
(3.3.1-17)
ES Water Surveillance Page 23 of 87
PI Page 3-290 Table 3.3.2-9 Auxiliary Systems - Essential Ventilation System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG-1801 Table 1 Item Notes Type Function Requiring Management Volume 2 Line Management Programs Item Ductwork Pressure Carbon/Low Air and Gas None None J
Boundary Alloy Steel (Internal)
Required Air and Gas -
Loss Of Periodic VII.F1.1-a, 3.3.1-05 4
- Wetted, Material Surveillance ViI.F4.1-a T<1 40'F and (Internal)
Preventive Maintenance Program Indoor - Air None None J
Conditioning Required (External)
Indoor-No Loss Of Systems V11.1.1-b 3.3.1-05 4
Air Material Monitoring Conditioning Program l
(External)
Stainlesa Aiand-Gas -
Loss Of PeriodiQ ll.FlJ.1-a 3.3.1 -05 Steel Material surveillancm T<1 400F and (Internal)
Preventive Maintenance Indoorm-No None N__
o1 Air Required Airntake ressure Carbon/Low Qutdoor Loassof Sy4e A
sirmcturm Alloy Steel Material Monitoring Steel Erram Erogramr Page 24 of 87
LRA Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS BACKGROUND By letter dated July 12, 2004,' NMC provided clarifications to the NRC staff as a result of questions during an audit regarding PBNP aging management programs and aging management reviews.
The July 12, 2004, letter contained the following commitment:
Audit Item 134 - The Aging Management Review results in Section 3 of the LRA will be revised to include loss of material being managed by the Periodic Surveillance and Preventive Maintenance Aging Management Program.
Audit Item 136 - A note correction deleting note F will be made in Table 3.3.2-11 of the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.3.2-11 on LRA pages 3-246 and 3-247 is revised as shown on the next two pages.
Page 25 of 87
Table 3.3.2-11 Auxiliary Systems - Plant Air System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -1801 Table 1 Item Notes Type Function Requiring Management Volume 2 Line Management Programs Item Page 3-303 Compressor Pressure Cast Iron Air and Gas, None None J
Casing Boundary Wetted LoSS Requied (Internal)
MatialEeriodig
.urveillance and Preventive
~Maintenance Indoor-No Loss Of Systems V1.1.1-b 3.3.1-05 4
Air Material Monitoring Conditioning Program (External)
Page 3-306 Valve Bodies Pressure Carbon/Low Air and Gas -
Loss Of Periodic VII.D.2-a 3.3.1-19 E, 6 Boundary Alloy Steel
- Wetted, Material Surveillance T<140'F and (Internal)
Preventive Maintenance Program Containment Loss Of Systems VI1.1.1-b 3.3.1-05 4
(External)
Material Monitoring Program Indoor - No Loss Of Systems VI1.1.1-b 3.3.1-05 4
Air Material Monitoring Conditioning Program
_(External)
Copper Alloy Air and Gas None None J
(Zn < 15%)
(Internal)
Required Page 26 of 87
Table 3.3.2-11 Auxiliary Systems - Plant Air System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -1801 Table 1 Item Notes Type Function Requiring Management Volume 2 Line Management Programs Item Air and Gas -
Loss Of Periodic (VII.D.2-a)
(3.3.1-19)
F, E, 6
- Wetted, Material Surveillance T<140'F and (Internal)
Preventive Maintenance Program Containment None None J
(External)
Required Page 3-307 Valve Bodies Pressure Copper Alloy Indoor - Air None None J
Boundary (Zn < 15%)
Conditioning Required (External)
Indoor-No None None J
Air Required Conditioning (External)
Copper Alloy Air and Gas None None J
(Zn > 15%)
(Internal)
Required Air and Gas -
Loss Of Periodic (VII.D.2-a)
(3.3.1-19)
F, E, 6
- Wetted, Material Surveillance T<1 40'F and (Internal)
Preventive Maintenance Program Containment None None J
(External)
Required Indoor-No None None J
Air Required Conditioning (External)
Page 27 of 87
LRA Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS BACKGROUND As a result of reviews of additions to the PBNP equipment data base (CHAMPS),
Table 3.3.2-14, "Auxiliary Systems - Treated Water System - Summary of Aging Management Evaluation," has lines added to reflect the addition of "Copper Alloy (Zn <15%)" Material for "Valve Bodies" Component Type in an "Indoor - No Air Conditioning (External)" Environment with no aging effect requiring management and a "Treated Water Other (Internal)" Environment that will be managed by the One-Time Inspection Program.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.3.2-14 on LRA page 3-314 is revised as shown on the next two pages.
Page 28 of 87
Table 3.3.2-14 Auxiliary Systems - Treated Water System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -1801 Table 1 Item Notes Type Function Requiring Management Volume 2 Line Management Programs Item Piping and Pressure Stainless Indoor - No None None J
Fittings Boundary Steel Air Required Conditioning
_(External)
Raw Water Loss Of One-Time J, 5 Drainage Material Inspection (Internal)
Program Treated Loss Of One-Time J, 41 Water - Other Material Inspection (Internal)
Program Valve Bodies Pressure Carbon/Low Indoor - No Loss Of Systems VII.1.1-b 3.3.1-05 4
Boundary Alloy Steel Air Material Monitoring Conditioning Program (External)
Raw Water Loss Of One-Time J, 5 Drainage Material Inspection (Internal)
-Program Cast Indoor-No None None J
Austenitic Air Required Stainless Conditioning Steel (External)
Treated Loss Of One-Time J, 41 Water - Other Material Inspection (Internal)
Program Stainless Indoor-No None None J
Steel Air Required Conditioning (External)
Treated Loss Of One-Time J, 41 Water - Other Material Inspection (Internal)
Program Page 29 of 87
Table 3.3.2-14 Auxiliary Systems - Treated Water System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -1801 Table 1 Item Notes Type Function Requiring Management Volume 2 Line Management Programs Item Copper Alloy indoor--J1 No NMn ln (Zn <15%
M.
aeurd Conditoning fExtmal)
Aic=
Water -Othe[
Material Internal)
Page 30 of 87
LRA Section 3.4 AGING MANAGEMENT OF STEAM AND POWER CONVERSION SYSTEM BACKGROUND During a review for a response to an NRC RAI dated July 30, 2004, Table 3.4.2-3, "Steam and Power Conversion System - Auxiliary Feedwater System - Summary of Aging Management Evaluation," has been revised to include "Copper Alloy" and "Neoprene" Materials under the "Piping and Fittings" Component Type to address portions of the backup air sub-system of the Auxiliary Feedwater System that were not originally included in the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.4.2-3 on LRA page 3-355 is revised as shown on the next pages.
Page 31 of 87
Table 3.4.2-3 Steam and Power Conversion System - Auxiliary Feedwater System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Piping and Pressure Carbon/Low Treated Water -
Loss Of Material One-Time VIII.G.1-c 3.4.1-02 B
Fittings Boundary Alloy Steel Secondary, Inspection T>1200F Program (Internal)
Water VlIl.G.1-c 3.4.1-02 B
Chemistry Control Program Loss of Material Flow-VIII.G.1-a 3.4.1-06 A
due to Accelerated FAC/Erosion-Corrosion Corrosion Program Water VIII.G.1-a 3.4.1-06 34 Chemistry Control Program Stainless Air and Gas None None Required J
Steel (Internal)
Indoor - No Air None None Required J
Conditioning (External)
Treated Water -
Loss Of Material One-Time VIII.G.4-b 3.4.1-02 D
Secondary, Inspection T<1200F Program (Internal)
Water VIII.G.4-b 3.4.1-02 D
Chemistry Control Program Copper AiandGas None None R Page 32 of 87
Table 3.4.2-3 Steam and Power Conversion System - Auxiliary Feedwater System - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Indoor - No Air None None RequiredI Neoprene Atand Gas None Required (Internal).
Indoor - No Air l
hame in Ngna-1Required J, 1 Conditioning Materilal (Extemal)prperties and
_I.
CraLk Page 33 of 87
- p.
i LRA Section 3.5 AGING MANAGEMENT OF CONTAINMENTS, STRUCTURES AND COMPONENT SUPPORTS BACKGROUND As part of the review of the application during the NRC audit process NMC noted that the Component Type, "Masonry Block Wall/Buried - All: Manholes," was not contained in LRA Table 3.5.2-8, "Structures and Component Supports - Yard Structures - Summary of Aging Management Evaluation."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.5.2-8 on LRA page 3-460 is revised as shown on the next page.
Page 34 of 87
Table 3.5.2-8 Structures and Component Supports - Yard Structures - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2
_ _ _ _L in e Ite m_
Masonry Block SuLWall Buried (External)
Crackinlctures 11l.A32-a 3.5.1-24 Wall/Buried -
All;_
_eta__
Montoraing Manholes shrinkage. etc, Eorwmm Page 35 of 87
LRA Section 3.5 AGING MANAGEMENT OF CONTAINMENTS, STRUCTURES AND COMPONENT SUPPORTS BACKGROUND As part of a review of CLB changes at PBNP since the LRA was submitted, NMC identified that the Component Type "Gypsum Board/Indoor-All: Walls " should be added to LRA Table 3.5.2-11, "Structures and Component Supports - Fire Barrier Commodity Group -
Summary of Aging Management Evaluation."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Table 3.5.2-11 on LRA page 3-460 is revised with a line addition as shown on the next page.
Page 36 of 87
Table 3.5.2-11 Structures and Component Supports - Fire Barrier Commodity Group - Summary of Aging Management Evaluation Component Intended Material Environment Aging Effect Aging NUREG -
Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Volume 2 Line Item Gypsum Fire Barrierm Indoor-No Air NoQne ire Proteion 1
Board/lndoor-Al!:
5aDd Walls
_E__
_rmall Page 37 of 87
II LRA Section 4 - TIME-LIMITED AGING ANALYSES LRA Section 4.3 METAL FATIGUE BACKGROUND As part of a review of changes in the current licensing basis, NMC identified that additional structural, fatigue, corrosion, and fracture mechanics analyses have been performed in support of inspections of both Unit 1 and Unit 2 PBNP reactor pressure vessel (RPV) head Alloy 600 penetrations, and inspection and repair of the Unit 1 PBNP reactor pressure vessel head penetration 26. Therefore, additional text has been added to LRA Section 4.3.1, "Reactor Vessel Structural Integrity."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
The following text is added to LRA Section 4.3.1, "Reactor Vessel Structural Integrity" on LRA page 4-40:
4.3.1 Reactor Vessel Structural Integrity In general, the analyses do not support operation with the existing RPV heads to end of extended life (EOEL) due to the Alloy 600 penetrations. The analyses provide iustification for operation through each Unit's current fuel cycle. The RPV head on each unit will be replaced with a new RPV head that does not incorporate Alloy 600 penetration material. The RPV heads will be replaced in each unit's respective refueling outage in 2005. All analyses associated with the new RPV heads have been evaluated for operation through EOEL in accordance with 10 CFR 54.21 (c)(1)(i).
The analyses associated with verifying the structural integrity of the reactor vessels have been projected to the end of the period of extended operation in accordance with 10 CFR 54.21 (c)(1)(ii).
Page 38 of 87
LRA Section 4.4 FRACTURE MECHANICS ANALYSIS BACKGROUND As part of a review of changes in the current licensing basis, NMC identified that the following additional sub-section should be added to LRA Section 4.4, "Fracture Mechanics Analysis."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough) 4.4.9 Reactor Vessel Head Penetration Analysis is added as follows:
4.4.9 Reactor Vessel Head Penetration Analysis Additional structural, fatigue, corrosion, and fracture mechanics analyses have been performed in support of inspections of both Unit 1 and Unit 2 PBNP reactor pressure vessel (RPV) head Alloy 600 penetrations, and inspection and repair of the Unit 1 PBNP reactor pressure vessel head penetration 26. In general, the analyses do not support operation with the existing RPV heads to end of extended life (EOEL) due to the Alloy 600 penetrations. The analyses provide justification for operation through each Unit's current fuel cycle. The RPV head on each unit will be replaced with a new RPV head that does not incorporate Alloy 600 penetration material. The RPV heads will be replaced in each unit's respective refueling outage in 2005. All analyses associated with the new RPV heads have been evaluated for operation through EOEL in accordance with 10 CFR 54.21 (c)(1 )(i).
Page 39 of 87
LRA Section 4.5 LOSS OF PRELOAD BACKGROUND Based upon the NRC staff request during the staff meeting with NMC on February 15, 2005, the confirmatory Pre-Stressed Concrete Containment Tendon Surveillance Program (LRA Section B3.3) has been deleted from the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
The final paragraph for Section 4.5.1, "Containment Tendon Loss of Pre-stress Analysis," on LRA page 4-82 is revised as follows.
4.5.1 Containment Tendon Loss of Prestress Analysis As a confirmatory program, the containment structure post tensioning Sub systetm roinolleancel Will continue to be poormned in aGcordanco with the Pro Stressed Concrte Containment Tendon Surwoillano Progrgamn to Yerify the integrity of the tondons.
Page 40 of 87
LRA Section 4.6 Neutron Absorber BACKGROUND During discussions with NRC staff during audits of the Boroflex Monitoring Program some needed revisions to the program details were identified.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
The following changes were made to the LRA Section 4.6.1, "Spent Fuel Pool Storage Rack Boraflex," discussion on LRA Page 4-84:
4.6.1 Spent Fuel Pool Storage Rack Boraflex The Boroflex Monitoring Program manages aging effects for the Boraflex material in the spent fuel racks. This program provides for blackness testing and areal density measurements of the Boraflex material in the spent fuel storage racks to confirm the in-service Boraflex performance. In addition, tracking of the spent fuel pool silica levels provides a qualitative indication of boron carbide loss. Neutron attenuation or blackness testing will be performed to determine gap formation, while areal density measurements will be used to ascertain the physical loss of boron carbide. Monitoring aiA by analysis of criticality will also be performed to assure that the required 5% subcriticality margin is maintained. Based on the results of these inspections and analysis, appropriate measures will be taken to ensure the Boraflex will continue to perform its intended function. This program addresses the concerns described in NRC GL 96-04. The Boraflex Monitoring Program is described in Appendix B.
The Boraflex Monitoring Program for the Boraflex panels will provide reasonable assurance that the equipment will be adequately managed for the period of extended operation, in accordance with 10 CFR 54.21 (c)(1 )(iii).
Page 41 of 87
LRA APPENDIX A - FSAR SUPPLEMENT BACKGROUND Based upon the NRC staff request during the staff meeting with NMC of February 15, 2005, the confirmatory Pre-Stressed Concrete Containment Tendon Surveillance Program (LRA Section B3.3) has been deleted from the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Appendix A Contents Appendix A, Contents, line item 15.3.1, page A-iii, was changed as follows:
15.3.1 Pre Stresoed Concrote Containment Tendon Survoillanco Program A 31 Page 42 of 87
LRA APPENDIX A - FSAR SUPPLEMENT BACKGROUND A need for revision of the FSAR was identified during review of the Quality Assurance requirements for License Renewal.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
In FSAR Table 1.4-6, "Plant Operating Records," (FSAR page 1.4-28) an additional line item X* will be added as follows:
X*
Records necessary to document compliance with the provisions of 10 CFR 54.
License Renewal Rule, will be retained for the term of the renewed operatinA license.
Page 43 of 87
LRA APPENDIX A - FSAR SUPPLEMENT BACKGROUND Based upon the NRC staff request during the staff meeting with NMC on February 15, 2005, the confirmatory Pre-Stressed Concrete Containment Tendon Surveillance Program (LRA Section B3.3) has been deleted from the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Section 5.7.1.5 "Tendon Surveillance," last paragraph on LRA page A-14 is revised as follows:
The Pro~ tro sed roncroo Cn rv n
Progr~,am SetiQR ( 5.3.1) con*tain, Additiona pI nrinsrd fnr thi niod of nxt4nded nran rs, Page 44 of 87
LRA Appendix A, Section 15 - NEW FSAR CHAPTER 15 LRA Appendix A, Section 15.1 - PROGRAMS THAT MANAGE THE EFFECTS OF AGING AND GENERIC QUALITY ASSURANCE PROGRAM REQUIREMENTS BACKGROUND The first paragraph in Section 15.1 of LRA Appendix A has been revised to remove reference to the Program Basis Documents. These documents will be maintained as historical records as required by 10 CFR 54.37.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Section 15.1 on LRA Page A-22 is revised as follows:
15.1 PROGRAMS THAT MANAGE THE EFFECTS OF AGING AND GENERIC QUALITY ASSURANCE PROGRAM REQUIREMENTS This section provides summaries of the programs and activities credited for managing the effects of aging. These aging management programs may not exist as discrete programs at PBNP. In many cases they exist as a compilation of various implementing documents that, when taken as a whole, satisfy the intent of NUREG-1800 and/or NUREG-1801 elements. The Program Basis Documents for Liconso Ronewal provide -and decraibe thehoproram's structur, includiRng a dcmpilatisn of all dequiFed implennentig documedto.
The implemertiog documnents_ -are intified in and are referMnced to the applicable program basis Page 45 of 87
LRA Appendix A Section 15.2 AGING MANAGEMENT PROGRAMS BACKGROUND By letter dated July 12, 2004, NMC provided clarifications to the NRC staff as a result of questions during an audit regarding PBNP aging management programs and aging management reviews.
The July 12, 2004, letter contained the following commitment:
Audit Item 147 - The recirculation line orifices in the RHR system will be added to the scope of the One-Time Inspection Program of the LRA.
As a result, LRA Appendix A, Section 15.2, Aging Management Programs, has been revised to reflect this scope change.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Section 15.2.13 on LRA page A-28 has been revised as follows:
15.2 AGING MANAGEMENT PROGRAMS 15.2.13 One-Time Inspection Program
- To verify aging effects are not occurring in various components (e.g., reactor vessel internals hold-down spring, letdown orifices, steam traps, downstream piping near the RHR pump mini-flow recirculation orifices, and miscellaneous heat exchangers).
Page 46 of 87
LRA Appendix A Section 15.2 AGING MANAGEMENT PROGRAMS BACKGROUND By letter dated October 25, 2004, NMC provided clarifications to the NRC staff regarding Time Limited Aging Analyses for Pressurized Thermal Shock and Upper Shelf Energy.
The October 25, 2004, letter provided detailed changes to various portions of the LRA.
For completeness the revised FSAR section 15.2.18, "Reactor Vessel Surveillance Program," is provided here. For details on the LRA Appendix B changes see the revisions for the Reactor Vessel Surveillance Program, LRA Section 62.1.18, later in this enclosure.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Section 15.2.18 on LRA pages A-29 and A-30 has been revised as follows:
The Reactor Vessel Surveillance Program manages the aging effect reduction of fracture toughness due to neutron embrittlement of the low alloy steel reactor vessels.
Monitoring methods will generally be in accordance with 10 CFR 50, Appendix H. but may alsor include diroct meaurrement of f racturo toughness scimenns to 6upport a Master Curwo Approach. This program includes (a) capsule insertion, withdrawal and materials testing/evaluation, (including upper shelf energy and RTNDT determinations),
(b) fluence and uncertainty calculations, (c) monitoring of Effective Full Power Years (EFPY), (d) development of pressure-temperature limitations, afi (e) determination of low-temperature overpressure protection (LTOP) setpoints, and (f) implementation of a flux reduction program and other options, as necessary, allowed by 10 CFR 50.61 (b) for the Unit 2 intermediate-to-lower shell girth weld. The program ensures the reactor vessel materials (a) meet the fracture toughness requirements of 10 CFR 50, Appendix G, and (b) have adequate margins against brittle fracture caused by Pressurized Thermal Shock (PTS) in accordance with 10 CFR 50.61. OF altemativaey-.
via the Master Iurwo Approach, which involvo s the use of directly measured fractuIr taqhiiesr, data.
Page 47 of 87
LRA Section 15.3 TIME LIMITED AGING ANALYSIS SUPPORTING ACTIVITIES BACKGROUND Based upon the NRC staff request during the staff meeting with NMC on February 15, 2005, the confirmatory Pre-Stressed Concrete Containment Tendon Surveillance Program (LRA Section B3.3) has been deleted from the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Section 15.3.1 on LRA page A-31 has been revised as follows:
Pro Streossd Concrete Containment Tendon SurvoEillano Program Tho Pro Stressed Concroto Containment Tondon Survoillanco Program is a confirmatory program that monitors the 1oss of containment prestrossingforces in containment tendonRS throug1hout tho life of tho plant including the poriod of oxtondRd operation. This program consists of an acsoesment of the results of the tondon pro6trossing forco mea6urements porformed in accordance with ASME Soction Xi, Subsection IWL. Tho a6sessment related to tho adequacy of the prostro66ing force6 will consi6t of the ostablishmont of (a) accoptanco critoria, and (b) trend lines. The acceptance criteria will normally con6i6t of a prodicted lower limit (PLL) and the minimum required pros6tres6ing force or value (MRV).
The trend line rpreseRnts the trend of poFestressing forcs bas-ed on actual mneasred fgores. Maintain-ng the protreingR9 force trend linRes above the PlLI eonsurs that the prestressing forces in the containment would not be boelow the MRVE prior to the end of the period of extended operation. In accordance with the requirements of 10 CFR 50.55a(b)(2)(viii)(B), an ovaluation will be performed if the trend lines predict the prestressing forces in the containment to be below the MR'.' hefore the next scheduled inspectiGRon.
Page 48 of 87
LRA Section 15.4 - EVALUATION OF TIME-LIMITED AGING ANALYSES BACKGROUND Based upon the NRC staff request during the staff meeting with NMC on February 15, 2005, the confirmatory Pre-Stressed Concrete Containment Tendon Surveillance Program (LRA Section B3.3) has been deleted from the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
LRA Section 15.4.4 on LRA page A-48 last paragraph of Section 15.4.4 has been revised as follows:
15.4.4 Loss of Preload Containment Tendon Loss of Prestress Analysis Ar a confirmatory' measure, the Pro Stressed Concroto ContainmRnt Tendon Surveillance Program monitors the loss of prostroecing forces in the contaimeRnt tendons. This pFrogram onnsists of an asse-ssrnnnt of the results of the tendon prostrossing force measurements performed in accordanco with ASME Section XI, Subsection IlAL.
Page 49 of 87
LRA Section APPENDIX B - AGING MANAGEMENT PROGRAMS BACKGROUND Based upon the NRC staff request during the staff meeting with NMC on February 15, 2005, the confirmatory Pre-Stressed Concrete Containment Tendon Surveillance Program (LRA Section B3.3) has been deleted from the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
LRA Appendix B Table of Contents on LRA page B-iii is revised as follows:
Appendix B - Aging Management Programs The Table of Contents for LRA Appendix B has been revised to reflect the following Aging Management Program deletion.
B 3.3 Pro Strsserd Concroto Containmont Tondon Survoillanco Program B 215 The program listing in LRA Section B1.6 on LRA page B-5 has been revised to reflect the following Aging Management Program deletion as follows:
B1.6 Time Limited Aging Analyses Aging Management Programs:
- 1. Environmental Qualification Program [Section B3.1] [Existing]
- 2. Fatigue Monitoring Program [Section B3.2] [Existing]
- 3. Pro Stro66od Concroto Containmont Tondon Survoillanco Program [Soction 133.3)[EvirtiR91 Page 50 of 87
LRA Section APPENDIX B AGING MANAGEMENT PROGRAMS BACKGROUND By letter dated July 12, 2004, NMC provided clarifications to the NRC staff as a result of questions during an audit regarding PBNP aging management programs and aging management reviews.
The July 12, 2004, letter contained the following commitment:
Audit Item 67 - Add appropriate references to Section 4.4.3 and/or 4.4.4 in Appendix B to the LRA to indicate where the reviewer can find the analysis that PBNP conducted for Cast Austenitic Stainless Steel.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
The program listing in LRA Section B2.0, "AGING MANAGEMENT PROGRAMS CORRELATION," (page B-7) has been revised to reflect the following reference addition:
NUREG NUREG-1801 PBNP Program NUREG-1801
-1801 ID Program Comparison XI.M12 Thermal Aging Not Applicable - not credited for N/A Embrittlement of Cast aging management. Degradation Austenitic Stainless sustained from the effects of Steel (CASS) thermal embrittlement was determined to be significant for CASS Class 1 piping and asso-ciated pressure boundary com-ponents, which encompasses CASS RCS elbows, RCP casings, and CASS Class 1 valves exceeding a temperature threshold criteria of 482 degrees F. PBNP has chosen the evalua-tion method (fracture mechanics) to disposition reduction in fracture toughness due to thermal embrittlement of primary loop elbows and RCP casings. In addition, the CASS RCP casings have been determined to not be susceptible to thermal aging embrittlement. PBNP has no large CASS valves (>10") above 482 degrees F. Standard valve body Page 51 of 87
design practices cause valve bodies to be inherently tough.
Thus, an aging management program to manage thermal embrittlement for the CASS RCS elbows, RCP casings, and Class 1 CASS valves is not required beyond the examinations programmatically required by ASME Section Xi. ffieen-e LRA Sections 4.4.3 and 4.4.4)
Page 52 of 87
LRA Section APPENDIX B AGING MANAGEMENT PROGRAMS BACKGROUND Based upon the NRC staff request during the staff meeting with NMC on February 15, 2005, the confirmatory Pre-Stressed Concrete Containment Tendon Surveillance Program (LRA Section B3.3) has been deleted from the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
The program listing in LRA Section B2.0, "AGING MANAGEMENT PROGRAMS CORRELATION," on LRA page B-1 1 has been revised to reflect the following Aging Management Program deletion:
NUREG NUREG-1801 PBNP Program NUREG-1801
-1801 ID Program Comparison XI.S1 Concrete Containment Pro Stroccod ConcrGte GGsisteont Tendon Prestress Containment Tendon Surveillance N/A ProraFn [Section B3.1}
The TLAA resolution for Loss of Preload as applicable to containment tendon loss of prestress analysis is resolved in accordance with IO CFR 54.21 (c) (1 ) (ii),
Page 53 of 87
LRA Section APPENDIX B - AGING MANAGEMENT PROGRAMS BACKGROUND During review of Program Basis Documents, a revision to more generally reference 10 CFR 50.55a in the B2.1.2, "ASME Section Xl, Subsections IWE & IWL Inservice Inspection Program," was identified.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
LRA Section B2.1.2 on LRA page B-37 is revised as follows:
B2.1.2 ASME Section Xl, Subsections IWE & IWL Inservice Inspection Program Monitoring and Trending The IWE Containment Inspection Program deviates from the requirements of IWE-2430 by following the alternative examination requirements allowed by 10 CFR 50.55a(b)(2)(ix)(D). If the examinations reveal flaws or areas of degradation exceeding the acceptance standards of IWE-3400-1, an evaluation is performed to determine whether additional component examinations are required.
Page 54 of 87
LRA Section APPENDIX B - AGING MANAGEMENT PROGRAMS BACKGROUND By letter dated July 12, 2004, NMC provided clarifications to the NRC staff as a result of questions during an audit regarding PBNP aging management programs and aging management reviews.
The July 12, 2004, letter contained the following commitment:
Audit Item 107 - The Buried Services Monitoring Program, Parameters Monitored or Inspected section will include if there are any indications of selective leaching or if the condition is indeterminate, then a hardness test will be performed.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
LRA Section B2.1.7 on pages B-74 and B-75 is revised as follows:
B2.1.7 Buried Services Monitoring Program Program Description The Buried Services Monitoring Program assures that the effects of aging on buried piping, tanks, and miscellaneous components are being effectively managed for the period of extended operation. The effects of corrosion are detectable by visual inspections, while the effects of selective leaching are detectable by visual inspections and/or hardness measurements. If there are any indications of selective leaching or if the condition is indeterminate, then a hardness test will be performed.
This is a new program for PBNP that includes preventive measures such as coatings and wrappings to mitigate loss of material due to corrosion and selective leaching, and visual inspections of the external surfaces of buried carbon steel, cast iron, and low alloy steel components (e.g., piping, tanks) for evidence of coating damage and substrate degradation. Evidence of damage to the coating or wrapping, such as coating perforation, holidays, or other damage will cause the protected components to be inspected for evidence of loss of material. If the visual inspection shows that the coatings or wrappings are intact, no further inspection is required. However, if any evidence of damage is observed or the piping is not coated, the components will be further inspected for evidence of degradation.
Page 55 of 87
LRA Section APPENDIX B - AGING MANAGEMENT PROGRAMS BACKGROUND By letter dated July 12, 2004, NMC provided clarifications to the NRC staff as a result of questions during an audit regarding PBNP aging management programs and aging management reviews.
The July 12, 2004, letter contained the following commitment:
Audit Item 119 - Additional detail on recent cable testing and manufacturer's recommended testing will be added to 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 Monitoring Program Aging Management Program description in the LRA and/or the program basis document as appropriate.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
The 62.1.8, "Cable Condition Monitoring Program," description in LRA Appendix B (LRA Pages B-83 through B-96) was revised as follows:
62.1.8 Cable Condition Monitoring Program Scope of Program Page B-83 Non-EQ Electrical Cables Used in Nuclear Instrumentation Circuits This program applies to non-EQ electrical cables used in nuclear instrumentation circuits with sensitive, high voltage, low-level signals that are within the scope of license renewal and are installed in adverse localized environments caused by heat or radiation in the presence of oxygen (i.e., source range, intermediate range and power range circuits of the excore detectors).
This element includes exceptions to NUREG-1 801, "Generic Aging Lessons Learned (GALL) Report," Section XL.E2, "Electrical Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits." The Cable Condition Monitoring Program only includes non-EQ electrical cables used in nuclear instrumentation circuits that are within the scope of license renewal and are installed in adverse localized environments (i.e., source range, intermediate range and power range circuits of the excore detectors), while the NUREG-1801 program Page 56 of 87
applies to all non-EQ instrumentation circuits with sensitive, high voltage, low-level signals exposed to adverse localized environments such as radiation monitoring and nuclear instrumentation that are within the scope of license renewal.
Page B-84 Inaccessible Non-EQ Medium-Voltage Cables None of the inaccessible non-EQ medium-voltage cable that is within the scope of license renewal is direct buried. Medium-voltage cables at PBNP were ordered moisture resistant for direct buried or underground service, but inaccessible non-EQ medium-voltage cable within the scope of license renewal are not used in direct buried applications. Medium-voltage cables used at PBNP are installed in conduit, duct packs/banks, or manholes, which provide a flow path to drain water (e.g., duct packs/banks are sloped). Cables designed for direct burial are expected to be exposed to normal groundwater, which is both seasonal and determined by periodic rainfall that can last more than a few days. Therefore. these cables can be expected to have an extended useful life, since the cables were designed and manufactured for direct buried service but are actually installed in less severe environmental conditions.
Page B-85 Inaccessible Non-EQ Medium-Voltage Cables PBNP has already tested all in-scope inaccessible non-EQ medium-voltage cables.
This testing was performed in 2003 and 2004, and no significant deterioration of the cables was found to exist. The test results account for the exposure of cables to water during the past normal seasonal cycles, since these tests were conducted on installed cables at PBNP. This testing included both the cables installed during the original construction of the plant (1966-1971) and those cables installed more recently (1988 and 1994). -The actual conditions during these three extended periods of operation (i.e., more than a few years) are representative of the ongoing conditions to which the cables will be subjected regarding water exposure or immersion. This testing identified no faults or defects in cables from either time period or manufacturer.
XLPE or high molecular weight polyethylene (HMWPE) insulation materials are most susceptible to water tree formation. Based on a review of cable data, PBNP has no cables with XLPE insulation being operated in the medium-voltage range (i.e., 2K VAC to 15K VAC).
Minimizing exposure to moisture also minimizes the potential for the development of water treeing. Manhole flooding and groundwater intrusion has been a long standing issue at PBNP and efforts were periodically taken to reduce the exposure Page 57. of 87
S of medium-voltage cables to water. In order to better understand the magnitude of the groundwater intrusion problem into the electrical manholes, a new call-up to inspect and pump the flooded manholes was initiated. The new call-up periodically inspects and pumps down the electrical manholes, as necessary. As part of the new call-up, the approximate water level in each manhole is recorded. The recording of the water level will provide the basis for any future changes in frequency to the call-up and any deletion of manhole inspections.
None of the inaccessible non-EQ medium-voltage cables that are within the scope of license renewal have been exempted from this program on the basis that the cables may now be in a dry environment. However, removal of water from the proximity of cables will Drolong the lifetime of these cables. The design and installation of the duct banks between the switchyard and plant include a 1/2 % or greater slope. The duct banks were enclosed in concrete when installed, and no surface slumping along their routes has been observed. Therefore, they are not likely to have settled during their periods of service nor is settlement likely during the period of extended operation. This should ensure continued draining of any water entering the duct banks into the manholes.
Therefore, PBNP meets the intent of this NUREG-1 801 aging management program element.
Parameters Monitored and Inspected Page B-86 Accessible Non-EQ Electrical Cables and Connections A representative sample of accessible electrical cables and connections installed in adverse localized environments are visually inspected for cable and connection jacket surface anomalies, such as discoloration, swelling, cracking, or surface contamination. This sample is based on the severity of the adverse localized environment, as compared to the plant design environment, and other criteria such as accessibility, availability, importance-to-safety, and/or prior inspection results.
The selection criteria for this sample will also be based on the primary stressor(s' of concern, as noted in SAND96-0344 (Section 6.3.3, Step 1), and a standard statistical basis to be representative of accessible electrical cables/connections and plant areas in-scope for license renewal.
This element is consistent with NUREG-1 801, "Generic Aging Lessons Learned (GALL) Report,"Section XI.E1, "Electrical Cables And Connections Not Subject To 10 CFR 50.49 Environmental Qualification Requirements."
Page 58 of 87
a Non-EQ Electrical Cables Used in Nuclear Instrumentation Circuits Nuclear instrumentation circuits are periodically tested to provide an indication of the condition of the cable insulation. 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.
Page B-87 Non-EQ Electrical Cables Used in Nuclear Instrumentation Circuits Nuclear instrumentation circuits are periodically tested to provide an indication of the condition of the cable insulation. 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. This element includes exceptions to NUREG-1 801, "Generic Aging Lessons Learned (GALL) Report,"Section XI.E2, "Electrical Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits." The NUREG-1801 program indicates that the parameters monitored are specified in the plant technical specifications. However, the surveillance tests required by the PBNP technical specifications do not include the electrical cables for certain nuclear instrumentation circuits. These cables are disconnected from their circuits during calibration. Therefore, the Cable Condition Monitoring Program periodically tests nuclear instrumentation circuits to provide an indication of the cable insulation condition, which meets the intent of this NUREG-1 801 aging management program element.
- Inaccessible Non-EQ Medium-Voltage Cables A representative sample of in-scope, inaccessible medium-voltage cables not designed for submergence subject to prolonged exposure to significant moisture and significant voltage are periodically tested to provide an indication of the condition of the conductor insulation. This sample is based on the severity of prolonged exposure to significant moisture and significant voltage, and the age of the cable.
For example, for cables of the same size, construction, voltage and ampere loading.
and age run in parallel conduits in the same underground duct bank, the sample Page 59 of 87
may consist of only those cables in the lowest conduits, since they are more likely to be exposed to water. In addition, cables of recent manufacture and installation.
using more modern materials and processes, are more resistant to degradation due to exposure or immersion in water (i e., water treeing leading to electric treeing) than those cables installed during the original construction of the plant. The specific type of test performed is determined prior to testing and capable of detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, or polarization index, as described in EPRI TR-103834-P1-2.
This element includes exceptions to NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," Section XL.E3, "Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements." The Cable Condition Monitoring Program requires periodic testing of a representative sample of in-scope, inaccessible medium-voltage cables not designed for submergence subject to prolonged exposure to significant moisture and significant voltage, while the NUREG-1801 program implies all such cables are to be tested. This sampling approach is acceptable for the following reasons.
None of the inaccessible non-EQ medium-voltage cable that is within the scope of license renewal is direct buried. Medium-voltage cables at PBNP were ordered moisture resistant for direct buried or underground service, but are not used in direct buried applications. Medium-voltage cables used at PBNP are installed in conduit, duct packs/banks, or manholes, which provide a flow path to drain water (e.g., duct packs/banks are sloped). Cables designed for direct burial are expected to be exposed to normal groundwater, which is both seasonal and determined by periodic rainfall that can last more than a few days. Therefore, these cables can be expected to have an extended useful life, since the cables were designed and manufactured for direct buried service but are actually installed in less severe environmental conditions.
Page B-88 The formation and growth of water trees varies directly with operating voltage. As stated in NUREG-1 801, treeing is much less prevalent in 4K VAC cables than those operated at 13 or 33K VAC. Major portions of the higher medium-voltage (13.8K VAC) cables used at PBNP, which are more susceptible to water treeing, were replaced in 1988 with cables ordered moisture resistant for direct buried or underground service. In addition, the 13.8 K VAC cables subject to submergence were successfully tested in 2003 using the Energized Partial Discharge Testing Methodology.
PBNP has already tested all in-scope inaccessible non-EQ medium-voltage cables.
This testing was performed in 2003 and 2004, and no significant deterioration of the cables was found to exist. The test results account for the exposure of cables to water during the past normal seasonal cycles, since these tests were conducted on Page 60 of 87
- installed cables at PBNP. This testing included both the cables installed during the original construction of the plant (1966-1971l) and those cables installed more recently (1988 and 1994). The actual conditions during these three extended periods of operation (i.e., more than a few years) are representative of the ongoing conditions to which the cables will be subjected regarding water exposure or immersion. This testing identified no faults or defects in cables from either time period or manufacturer.
XLPE or high molecular weight polyethylene (HMWPE) insulation materials are most susceptible to water tree formation. Based on a review of cable data, PBNP has no cables with XLPE insulation being operated in the medium-voltage range (i.e., 2K VAC to 15K VAC).
Minimizing exposure to moisture also minimizes the potential for the development of water treeing. Manhole flooding and groundwater intrusion has been a long standing issue at PBNP and efforts were periodically taken to reduce the exposure of medium-voltage cables to water. In order to better understand the magnitude of the groundwater intrusion problem into the electrical manholes, a new call-up to inspect and pump the flooded manholes was initiated. The new call-up periodically inspects and pumps down the electrical manholes, as necessary. As part of the new call-up, the approximate water level in each manhole is recorded. The recording of the water level will provide the basis for any future changes in frequency to the call-up and any deletion of manhole inspections.
None of the inaccessible non-EQ medium-voltage cables that are within the scope of license renewal have been exempted from this program on the basis that the cables may now be in a dry environment. However, removal of water from the proximity of cables will prolong the lifetime of these cables. The design and installation of the duct banks between the switchyard and plant include a 1/2 % or greater slope. The duct banks were enclosed in concrete when installed, and no surface slumping along their routes has been observed. Therefore, they are not likely to have settled during their periods of service nor is settlement likely during the period of extended operation. This should ensure continued draining of any water entering the duct banks into the manholes.
Therefore, PBNP meets the intent of this NUREG-1 801 aging management program element.
Page B-89 Detection of Aging Effects Non-EQ Electrical Cables Used in Nuclear Instrumentation Circuits Page 61 of 87
However, the surveillance tests required by the PBNP technical specifications do not include the electrical cables for certain nuclear instrumentation circuits. These cables are disconnected from their circuits during calibration. Therefore, the Cable Condition Monitoring Program periodically tests nuclear instrumentation circuits to provide an indication of the cable insulation condition, which meets the intent of this NUREG-1 801 aging management program element.
Page B-90 Inaccessible Non-EQ Medium-Voltage Cables None of the inaccessible non-EQ medium-voltage cable that is within the scope of license renewal is direct buried. Medium-voltage cables at PBNP were ordered moisture resistant for direct buried or underground service, but inaccessible non-EQ medium-voltage cable within the scope of license renewal are not used in direct buried applications. Medium voltage cabl_
used at PBNP These cables are installed in conduit, duct packs/banks, or manholes, which provide a flow path to drain water (e.g., duct packs/banks are sloped). Cables designed for direct burial are expected to be exposed to normal groundwater, which is both seasonal and determined by periodic rainfall that can last more than a few days. Therefore, these cables can be expected to have an extended useful life, since the cables were designed and manufactured for direct buried service but are actually installed in less severe environmental conditions.
Page B-91 PBNP has already tested all in-scope inaccessible non-EQ medium-voltage cables.
This testing was performed in 2003 and 2004, and no significant deterioration of the cables was found to exist. The test results account for the exposure of cables to water during the past normal seasonal cycles, since these tests were conducted on installed cables at PBNP. This testing included both the cables installed during the original construction of the plant (1966-1971) and those cables installed more recently (1988 and 1994). The actual conditions during these three extended periods of operation (i.e., more than a few years) are representative of the ongoing conditions to which the cables will be subjected regarding water exposure or immersion. This testing identified no faults or defects in cables from either time period or manufacturer.
XLPE or high molecular weight polyethylene (HMWPE) insulation materials are most susceptible to water tree formation. Based on a review of cable data, PBNP has no cables with XLPE insulation being operated in the medium-voltage range (i.e., 2K VAC to 15K VAC).
Minimizing exposure to moisture also minimizes the potential for the development of water treeing. Manhole flooding and groundwater intrusion has been a long Page 62 of 87
standing issue at PBNP and efforts were periodically taken to reduce the exposure of medium-voltage cables to water. In order to better understand the magnitude of the groundwater intrusion problem into the electrical manholes, a new call-up to inspect and pump the flooded manholes was initiated. The new call-up periodically inspects and pumps down the electrical manholes, as necessary. As part of the new call-up, the approximate water level in each manhole is recorded. The recording of the water level will provide the basis for any future changes in frequency to the call-up and any deletion of manhole inspections.
None of the inaccessible non-EQ medium-voltage cables that are within the scope of license renewal have been exempted from this program on the basis that the cables may now be in a dry environment. However, removal of water from the proximity of cables will prolong the lifetime of these cables. The design and installation of the duct banks between the switchyard and plant include a 1/2 % or areater slope. The duct banks were enclosed in concrete when installed, and no surface slumping along their routes has been observed. Therefore, they are not likely to have settled during their periods of service nor is settlement likely during the period of extended operation. This should ensure continued draining of any water entering the duct banks into the manholes.
Therefore, PBNP meets the intent of this NUREG-1801 aging management program element.
Monitoring and Trending Trending actions are not included as part of this program bocauso the ability to trend inspoction or tost resuIts is limited and dependent on the specific typo of tost chosen.
- Accessible Non-EQ Electrical Cables and Connections Trending actions are not included as part of this program because the ability to trend inspection results is limited.
- Non-EQ Electrical Cables Used in Nuclear Instrumentation Circuits Trending of test results will be performed as required to detect and predict degradation in insulation resistance below an acceptable value.
Inaccessible Non-EQ Medium-Voltage Cables Trending actions are not included as part of this program because the ability to trend test results is dependent on the specific type of test chosen.
Page 63 of 87 r
Page B-92 Acceptance Criteria
- Non-EQ Electrical Cables Used in Nuclear Instrumentation Circuits 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.
This element includes exceptions to NUREG-1801, "Generic Aging Lessons Learned (GALL) Report,"Section XI.E2, "Electrical Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits." The NUREG-1 801 program indicates that the acceptance criteria are specified in the plant technical specifications.
However, the surveillance tests required by the PBNP technical specifications do not include the electrical cables for certain nuclear instrumentation circuits.
These cables are disconnected from their circuits during calibration.
Therefore, the Cable Condition Monitoring Program periodically tests nuclear instrumentation circuits to provide an indication of the cable insulation condition, which meets the intent of this NUREG-1 801 aging management program element.
Page B-95 Operating Experience Electrical cables associated with radiation monitoring instrumentation within the scope of license renewal at PBNP are either environmentally qualified in accordance with 10 CFR 50.49 or not installed in adverse localized environments (e.g., radiation monitoring instrumentation associated with the Control Room).
Non-EQ electrical cables used in nuclear instrumentation circuits within the scope of license renewal are included within the scope of the Cable Condition Monitoring Program. These cables have already been tested as part of the normal system condition monitoring by the system engineer at PBNP. Operating experience has shown that anomalies found during cable testing can be caused by the degradation of the nuclear instrumentation circuit cable and are a possible indication of potential cable degradation.
Page B-96 Plant-specific operating experience has also shown that manholes with cables are subject to flooding. Manhole flooding and groundwater intrusion has been a long standing issue at PBNP and efforts were periodically taken to reduce the exposure of medium-voltage cables to water. In order to better understand the magnitude of Page 64 of 87
the groundwater intrusion problem into the electrical manholes, a new call-up to inspect and pump the flooded manholes was initiated. The new call-up periodically inspects and pumps down the electrical manholes, as necessary. As part of the new call-up, the approximate water level in each manhole is recorded. The recording of the water level will provide the basis for any future changes in frequency to the call-up and any deletion of manhole inspections. In addition, a number of cableo subject to submergonce wore succoerfully teoted in 2003 using the Enorgized Partial Dischargo Toting Mothodology. PBNP has already tested all in-scope inaccessible non-EQ medium-voltage cables. This testing was performed in 2003 and 2004, and no significant deterioration of the cables was found to exist.
Page 65 of 87
LRA Section APPENDIX B AGING MANAGEMENT PROGRAMS LRA Section APPENDIX B B2.1.10 FIRE PROTECTION PROGRAM BACKGROUND As a result of review of the NRC Aging Management Audit report, NMC has added the industry operating experience to the appropriate element discussion for the B2.1.10,
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Appendix B Section B2.1.10 on LRA page 117 is revised with additional text as follows:
B2.1.10 Fire Protection Program Operating Experience Industry operating experience has shown that silicone foam fire barrier penetration seals have experienced splits, shrinkage, voids, lack of fill, and other failure modes.
Degradation of electrical raceway fire barriers such as small holes, cracking, and unfilled seals have also been found on routine walkdowns. Fire doors have experienced wear of hinges and handles. No corrosion-related problems have been reported for the fuel supply line and pump casing of diesel-driven fire pumps. or halon suppression systems. No significant aging related problems have been reported on fire protection systems, emergency breathing equipment, and communication equipment.
Water-based fire protection systems properly designed, inspected, tested and maintained have also demonstrated reliable performance.
Page 66 of 87
LRA Section APPENDIX B AGING MANAGEMENT PROGRAMS LRA Section APPENDIX B B2.1.13 ONE-TIME INSPECTION PROGRAM BACKGROUND By letter dated July 12, 2004, NMC provided clarifications to the NRC staff as a result of questions during an audit regarding PBNP aging management programs and aging management reviews.
The July 12, 2004, letter contained the following commitment:
Audit Item 147 - The recirculation line orifices in the RHR system will be added to the scope of the One-Time Inspection Program of the LRA.
By letter dated October 15, 2004, NMC provided clarifications to the NRC staff as a result of questions during an audit regarding PBNP aging management programs and aging management reviews.
The October 15, 2004, letter contained the following commitment:
As part of LRA Section B.2.1.13, "One Time Inspection Program," a one-time visual inspection and hardness measurement will be performed on accessible locations of a select set of components of each material type (i.e., cast iron and brass) to determine whether selective leaching has occurred and whether the resulting loss of strength and/or material will affect the intended functions of these components during the period of extended operation.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
LRA Appendix B Section, B2.1.13, on portions of LRA pages 135 through 143 is revised as shown on the following page.
Page 67 of 87
B2.1.13 One-Time Inspection Program Program Description Page B-135 To verify aging effects are not occurring in various components (e.g., reactor vessel internals hold-down spring, letdown orifices, steam traps, downstream piping near the RHR pump mini-flow recirculation orifices, and miscellaneous heat exchangers).
Page B-137 Selective leaching is the removal of one element from a solid alloy by corrosion processes. The most common example is the selective removal of zinc in brass alloys (dezincification). Another metal that is susceptible to selective leaching is gray cast iron, which can display this type of aging mechanism even in relatively mild environments. Therefore, this program includes a one-time visual inspection of selected components that may be susceptible to selective leaching. The inspection may w also include hardness measurements of accessible surfaces. The one-time inspections will determine whether loss of material due to selective leaching is occurring, and whether the process will affect the ability of the components to perform their intended function(s) for the period of extended operation. A sample of the components (such as piping, valve bodies and bonnets, pump casings, and heat exchanger components), whose materials of construction may include cast iron, brass, bronze, or aluminum bronze, that are exposed to raw water, treated water, or ground water environment that may lead to selective leaching will be selected for inspection. During the aging management review process it was not always possible to determine whether the cast iron components in question were constructed of gray or ductile cast iron. In these cases., PBNP conservatively assumed that the material was gray cast iron and susceptible to selective leaching. Should further material evaluation determine that the material is ductile cast iron and therefore not susceptible to selective leaching, these components will be removed from the selected set of components to be inspected. The inspections will be scheduled as close to the end of the current operating license as practical with margin provided to ensure completion prior to commencing the period of extended operation.
Any corrective actions will be implemented through the corrective action program.
NUREG-1801 Consistency The One-Time Inspection Program is a new program that is consistent with, btt includes excoptions to, NUREG-1 801, "Generic Aging Lessons Learned (GALL)
Report," Section XL.M33, "Selective Leaching of Materials," and is consistent with but includes exceptions to NUREG-1 801.Section XI.M32, "One-Time Inspection" (Reference 3).
Page 68 of 87
Pages B-138 and B-139 Scope of Program For selective leaching, which is a slow acting corrosion process, visual examinations and hardness measurements are performed on accessible locations to verify that this aging mechanism is not occurring. Hardness moasurlments may also be performed to identify selective leaching. The scope of this program includes the following:
Page B-139 Verification that aging effects are not occurring in various components (e.g., reactor vessel internals hold-down spring, letdown orifices, steam traps, downstream piping near the RHR pump mini-flow recirculation orifices, and miscellaneous heat exchangers).
This element includes exceptions to is consistent with the corresponding NUREG-1801, Section XL.M33, "Selective Leaching of Materials" aging management program element.
Section X.I.M33 of NUREG-1801 states that hardness measurements are performed on a select Get of omponRents. The internal rsufaces of r.uscGeptible omnponeRnts may not hpv;rwrrih1 v
fw. h:r T
vlv-V W Ivvh~Trva be acorder ssiblofor hIardnos mne as unrements due to the siZe Of theconent Therefo only visual inspections are required by the program. Hardness measurements may be performed in accessible locations to confirm the absence of selective leaching and determine material properties which can be used in component functionality assessments.
Page B-140 Enhancements to the program include the creation of new implementing documents required to provide those inspections necessary to manage aging of components within the scope of license renewal.
Therefore, PBNP meets the intent of these this NUREG-1801 aging management program elements.
Page B-140 and B-141 Parameters Monitored or Inspected For verification of the effectiveness of the Water Chemistry Control Program and the Closed-Cycle Cooling Water System Surveillance Program for stagnant or low flow areas and for verification of the effectiveness of the Fuel Oil Chemistry Control Program, a visual examination or other appropriate NDE methodology will be used to verify that degradation due to the applicable aging effects is not occurring. For selective leaching, which is a slow acting corrosion process, visual examinations and hardness Page 69 of 87
measurements of select components with accessible locations will be performed to verify that this aging mechanism is not occurring. Hardness measuroments may also be performed to confirm the absonco of soloctivo leaching. For verification that galvanic corrosion on the internal surfaces of piping and components where galvanic couples are present is not occurring, visual (or remote visual) or volumetric examinations will be performed. Measurement of the non-compressed spring height will be used to detect evidence of stress relaxation in the reactor vessel hold-down spring.
Table 1 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 aping effect is managed consistent with the current licensing basis. If a different inspection method will be used than that listed in Table 1. the basis for the revised inspection method will be documented. The aging effects being mananed are on the internal surfaces of components and visual inspections are only performed when the component surface of interest is accessible.
If degradation is identified throuah a visual inspection. additional NDE may be performed to characterize the degradation and determine the extent of condition. NDE exams performed as part of the One-Time Inspection Program will be conducted in accordance with the requirements of 10 CFR 50, Appendix B. NDE exams performed as part of the One-Time Inspection Program will also be conducted in accordance with the requirements of ASME Section Xl: except for General or Remote Visual examination for loss of heat transfer due to fouling which will be conducted in accordance with ASME Section V.
TABLE 1 AGING EFFECTS/MECHANISMS MANAGED BY THIS PROGRAM Aging Effect Aging Mechanism Measurement Method Parameter Monitored Loss of Crevice Corrosion Visual (VT-1) and/or Wall Thickness Material Volumetric (RT or UT)
Loss of Galvanic Corrosion Visual (VT-3) and/or Wall Thickness
Loss of General Corrosion Visual (VT-3) and/or Wall Thickness Material Volumetric (RT or UT)
Loss of MIC Visual (VT-3) and/or Wall Thickness Material Volumetric (RT or UT)
Loss of Pitting Corrosion Visual (VT-1 ) and/or Wall Thickness Material Volumetric (RT or UT)
Loss of Selective Leaching Visual (VT-3) and/or Wall Thickness
Loss of Erosion Visual (VT-3) and/or Wall Thickness Material Volumetric (RT or UT)_
Loss of Heat Fouling General or Remote Tube Fouling Transfer I
Visual Page 70 of 87
Cracking SCC I Volumetric (RT or UT Cracks Loss of Stress Relaxation Visual (VT-3)
Dimensional Changes Preload
- Hardness measurements will also be performed on accessible locations of a select set of components of each susceptible material type to detect Selective Leaching.
This element is consistent with the corresponding NUREG-1801, Section XL.M32, "One-Time Inspection," and XL.M33, " Selective Leaching of Materials." aging management program elements.
This olomont includes exceptions to tho corresponding NUREG 1801,Section XI.M33, "aging management program eomont.Section XI.M33 of NUREG 1801 statos that hardnoses measuroments aro performod on a coloct set of components. The intornal surfacos of suscoptiblo componentS. may not bo accossiblo for hardness meoasurements duo to the size of the componont. Thoroforo, only visual inspoctions aro roquired by the program. Hardness measuromonts maybe performed in accos6iblo locations to confirm tho absence of soloctivo leaching and dItIrmino material properties which can be used in component functionality assessmonts.
Therefore, PBNP moets the Intont of those NUREG 1801 aging management program elemeRts.
Detection of Aging Effects The examination techniques will be visual, volumetric, or other appropriately established NDE methods. The NDE will be performed by qualified personnel following procedures consistent with the ASME Code and 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." A representative sample of the component population will be chosen for inspection. The focus, when practical, will be placed on bounding or lead components. Factors that will be considered when choosing components for inspection are time in service, severity of operating conditions, and operating experience.
Visual examinations will be usod to detect sele-tive leaching. In addition, hardness mea6urements may be taken to determine whether 6elective leaching has occurrod and whether the resulting 1los of strength and/or material will affect the intended function of the components during the period of extended operation. and hardness measurements will be performed on accessible locations of a select set of components of each material type (i.e., cast iron and brass) to determine whether selective leaching has occurred and whether the resulting loss of strength and/or material will affect the intended functions of these components during the period of extended operation. The internal surfaces of susceptible components may not be accessible for hardness measurements due to the size of the component. Therefore. one of the factors used in choosing the selected set of components to be inspected for selective leaching will be the Page71 of 87
accessibility of the'internal surface of the component for hardness testing. Hardness measurements will be performed in accessible locations to confirm the absence of selective leaching and determine material properties which can be used in component functionality assessments During the aging management review process it was not always possible to determine whether the cast iron components in question were constructed of gray or ductile cast iron. In these cases, PBNP conservatively assumed that the material was gray cast iron and susceptible to selective leaching. Should further material evaluation determine that the material is ductile cast iron and therefore not susceptible to selective leaching, these components will be removed from the selected set of components to be inspected.
To detect loss of material due to galvanic corrosion, visual (or remote visual) or volumetric examinations will be used. The loss of material will be evident at the location of the junction of the dissimilar metals.
Page B-142 This element includes exception6 to is consistent with the corresponding NUREG-1801, Section XL.M33, "Selective Leaching of Materials," aging management program element.Section XI.M33 of NUREG 1801 states that hardnoss measurements are performed on a select set of components. The internal surfaces of su6ceptible components may not bo accessible for hardness moeasuroments duo to the size of the component. Thorefore, only visual inspections are required by the One Time Inspoction ProrFam. HardrnesseasuFromont mna" be performed inR acessible location6 to confirm the absrono of selective leaching and determine material preporrtes Which caR be ursod in component functionality ass6essments.
Therefore, PBNP meets the intent of these thiNUREG-1 801 aging management program elements.
Page B-143 Acceptance Criteria Acceptance criteria, against which the need for corrective action will be evaluated. will be established to ensure that the structure or component intended function(s) are maintained under all CLB design conditions during the period of extended operation.
Any indications of degradation or unacceptable conditions are evaluated through the corrective action program. The need to increase the sample population will also be evaluated when'indications or relevant conditions of degradation are found.
Page 72 of 87
LRA Section APPENDIX B AGING MANAGEMENT PROGRAMS LRA Section APPENDIX B B2.1.14 OPEN-CYCLE COOLING (SERVICE) WATER SYSTEM SURVEILLANCE PROGRAM:
BACKGROUND As a result of a review of the Section B2.1.14, "Open-Cycle Cooling (Service) Water System Surveillance Program," basis document a need for a clarification was identified.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
The Appendix B, Section B2.1.14, on parts of pages B-146, B-150 and B-253 is revised to reflect the clarification as follows.
B2.1.14 Open-Cycle Cooling (Service) Water System Surveillance Proqram Page B-146 Enhancements Enhancements to the Open-Cycle Cooling (Service) Water System Surveillance Program include: verification that the implementing documents for activities credited by the plant's "GL 89-13 Program Document" contain a reference or other link back to the "GL 89-13 Program Document," clarification of GL 89 13 commitmonts regarding the Emergency Diosol Gonerator G1!/G02 coolant heat oxchangore, revisions to existing callups to ensure evaluations take place for the management of aging effects credited by the activity for license renewal, and the creation of new activities to inspect individual components or representative samples of components not addressed by existing activities.
Page B-150 Enhancements to plant documents will be made to ensure that the implementing documents and callups for the activities specified in the PBNP "GL 89-13 Program Document" are linked back to the PBNP "GL 89-13 Program Document" by a purpose statement or other reference, clarify the PBNP GL 89 13 commitments regarding the Emergency Diosol Gonorator G011GO2 coolant heat oxchangors, and to ensure evaluations take place for the management of aging effects credited for license renewal.
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Page B-153 The guidance of GL 89-13 has been implemented for approximately 10 years and has been effective in managing and monitoring the aging effects due to biofouling, corrosion, erosion, degradation of protective coatings, and silting in components serviced by the Service Water System.
A corroctive action documont was written requosting review of PBNP's GL 89 13 commitments pertaining to the Emergency Diesel Generators Go1.G02 coolant heat exchangers. This issue is being tracked under the corrective action program.
A review of NRC Inspection Reports, QA Audit/Surveillance Reports, and Self-Assessments since 1999 revealed no other issues or findings that could impact the effectiveness of the Open-Cycle Cooling (Service) Water System Surveillance Program.
As additional operating experience is obtained, lessons learned may be used to adjust this program.
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LRA Section APPENDIX B - AGING MANAGEMENT PROGRAMS LRA Section APPENDIX B B2.1.15 PERIODIC SURVEILLANCE AND PREVENTIVE MAINTENANCE PROGRAM BACKGROUND As a result of a review of the Section B2.1.15, "Periodic Surveillance and Preventive Maintenance Program," basis document a need for a clarification was identified.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
The Appendix B, Section B2.1.15, on parts of pages B-157 is revised to reflect the clarification as follows:
B2.1.15 Periodic Surveillance and Preventive Maintenance Program Detection of Aging Effects Surveillance and preventative maintenance activities credited for license renewal shall be completed within a grace period of 125% of their assigned interval, not to exceed two 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 functions(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.
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LRA Section APPENDIX B - AGING MANAGEMENT PROGRAMS LRA Section APPENDIX B B2.1.18 REACTOR VESSEL SURVEILLANCE PROGRAM:
BACKGROUND By letter dated October 25, 2004, NMC provided responses to requests for additional information to the NRC regarding the reactor vessel. This letter provides details on the changes to LRA Appendix B, Section B-2.1.18, "Reactor Vessel Surveillance Program."
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
Reference the October 25, 2004, letter for revisions to LRA Appendix B, Section B2.1.18, " Reactor Vessel Surveillance Program," aging management program.
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LRA Section APPENDIX B - AGING MANAGEMENT PROGRAMS LRA Section APPENDIX B - B2.1.20 STRUCTURES MONITORING PROGRAM BACKGROUND Various clarifications have been inserted into the Structures Monitoring Program (LRA pages B-1 99 through B-206) as discussed in NMC to NRC correspondence dated July 26, 2004 and August 26, 2004. Additional revisions have been provided as a result of discussions held with NRC auditors.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
LRA Appendix B Section B2.1.20 on LRA pages B-1 99 through B-206 is revised as follows:
B2.1.20 Structures Monitoring Program Page B-199 Program Description Of the various mechanisms for concrete degradation, only cavitation and abrasion of concrete exposed to flowing water (i.e., water intake/discharge structures) are considered to be of sufficient significance to require aging management. However, this program also provides for comprehensive management of other various potential degradation mechanisms for the concrete structures within the scope of this program.
Periodic ground water level measurements and chemical analysis of ground water and lake water are performed to verify the associated chemistry remains non-aggressive.
Initially the frequency for ground water level measurement will be once every quarter and ground water and lake water chemistry (pH, chlorides, and sulfates) will be once every nine months. This will facilitate obtaining the seasonal variance. Based on an evaluation and trend of the obtained data. a determination will be made as to the appropriate long term frequency for continued monitoring.
Page B-200 Enhancements Enhancements to the Structures Monitoring Program include revisions to existing implementing documents to clarify inspection intervals, perform specific inspections related to aging effects, indicate the parameters to be monitored, and provide acceptance criteria. New implementing procedures will be created and/or existing Page 77 of 87
procedures revised to include those components not presently inspected. A structural condition survey of the reactor vessel containment sump area will be performed and documented. These enhancements are required to satisfy the NUREG-1801 aging management program requirements. Details of the enhancements are included in the appropriate element descriptions below.
Enhancements are scheduled for completion prior to the period of extended operation.
Page B-201 The Structures Monitoring Program provides inspection requirements to manage aging effects in accordance with the license renewal rule. The scope of the program includes the following:
- Masonry walls, including steel edged supports and bracing, identified as performing intended functions in accordance with NRC IEB No. 80-1 1.
- Structures, including all safety related buildings and the internal structures within containment.
- Circulating water pumphouse.
- GContainmont, Auxiliary Building, Turbino Hall and G03!GO4 overhead cranes.
- Overhead Cranes in the Containment, Auxiliary Building, Turbine Hall. and Diesel Generator Building.
- Structural steel and fasteners.
- Earthen berm installed around the above ground fuel oil storage tanks.
Page B-202 Parameters Monitored or Inspected Visual inspections are used to inspect the structures and components that are within the scope of the Structures Monitoring Program. The following parameters are monitored or inspected:
For masonry wall inspections, the parameters monitored are cracking, deteriorated penetrations, or broken block. Steel edge supports and bracing for masonry walls are inspected as described below for structural steel.
Page B-203
- The earthen berm installed around the above ground fuel oil storage tanks is inspected for signs of physical damage such as loss of material due to surface run-off and erosion.
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- For wood associated with the diesel generator air intake barrier, the Darameters monitored include rot and mildew.
This element is consistent with the corresponding NUREG-1801, Sections XL.S5, XL.S6, and XL.S7 aging management program elements.
Detection of Aging Effects For each structure/aging effect combination, the inspection methods, inspection schedule, and inspector qualifications are selected to ensure that aging degradation will be detected and quantified before there is loss of intended function(s). For example:
- Visual inspections by qualified inspection personnel are used to examine masonry walls. The inspection interval is -1 months five years.
- Visual inspections are also used to detect degradation of water control structures (i.e., circulating water pumphouse). The inspection interval is five years, however portions of the forebay are typically inspected every refueling by divers.
- Accessible structural bolting is inspected by visual examination. T:he6e inspections aro conducted on a 12 month cycle. The inspection interval is five years.
Page B-204
- Visual examinations of concrete surfaces for evidence of cracking and deterioration are performed at five year inspection intervals aRnually. The deterioration may include popouts, spalling, erosion/abrasion, rust stains, scaling, and differential settlement.
- Differential settlement measurements are performed periodically. The freauencv of these measurements is based on observed settlement rates.
- The earthen berm installed around the above ground fuel oil storage tanks is visually inspected for signs of physical damage. These visual inspections are performed annually.
Enhancements include revisions to existing implementing documents to perform specific inspections related to aging effects, indicate the parameters to be monitored, and provide acceptance criteria. For example, enhancements will be made to include:
- Specific guidance on corrosion and crane rail wear evaluation and acceptance criteria.
- Steps to inspect the trolley and bridge structural components for signs of corrosion, rail wear, or other discrepancies and add a step to provide the acceptance criteria for the structural component inspections.
- Steps to provide inspection acceptance criteria. Guidance for acceptance criteria can be found in Regulatory Guide 1.127, Section C, Paragraph 2.
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- Inspection frequencies for block walls and structural bolting and to address non ASME Section Xl (IWE, IWL, or IWF) inspections inside containment.
8 A structural condition survey of the reactor vessel containment sump area will be performed and documented.
In addition, new implementing procedures will be created and/or existing procedures revised to include those components not presently inspected.
This element is consistent with the corresponding NUREG-1 801 aging management program elements.
Page B-205
- The earthen berm installed around the above ground fuel oil storage tanks is monitored by periodic inspections and evaluations of the inspection results.
These inspections verify that the earthen berm will continue to perform its intended function of containing fuel oil spills and any resulting fire.
- Periodic monitoring of around water level and chemistry and lake water chemistry is performed to verify the associated chemistry remains non-aggressive.
Page B-206 Operating Experience Masonry walls are inspected per plant procedures. Cracks in masonry walls have been found primarily at the mortar joints and these findings have been documented and resolved.
Concrete structure inspections have been and continue to be a large part of the Structures Monitoring Program as described in plant procedures. Cracks, erosion, corrosion of embedded steel, and concrete spalling have been observed. These findings are evaluated and resolved by engineering.
Consolidation of soils beneath building foundations typically occurs within the first three to four years after construction. Consolidation of the soil after that time frame is typically negligible. PBNP has a facilities settlement monitoring program. During original plant construction, numerous bench marks were established throughout the plant. The bench marks were first surveyed in the fall of 1969. Subsequent surveys have been performed and differential settlement values determined. To date,. the average differential settlement, averaae of all bench marks, is 0.636 inches. The maximum differential settlement between any of the points (non-adjacent) is 1.296 inches.
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LRA Section APPENDIX B AGING MANAGEMENT PROGRAMS LRA Section APPENDIX B B2.1.21 SYSTEMS MONITORING PROGRAM BACKGROUND During discussions with NRC staff during audits of the Systems Monitoring Program some needed revisions to the program details were identified.
The System Monitoring Program has been revised to reflect walk down frequencies.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
LRA Appendix B, B2.1.21 on LRA pages B-212 and B-213 is revised as follows:
B2.1.21 Systems Monitoring Program Page B-212 Detection of Aging Effects Bolted connections are inspected for missing fasteners and degradation such as damaged threads and evidence of corrosion. The minimum walkdown frequency is once per operating cycle within the limits of accessibility. year for thosE systems and components that are accossiblo during normal plant operation. Systems and ompnornonsR that aro only atoersible duFring plant outagos, ro nspected at least onco per rofueling interval. The inspection frequency may be increased based on the safety significance, production significance, and/or operating experience of each system.
Enhancements to existing implementing documents will be made to include the following:
- Additional Inspections, and
- Strengthen the requirements for performance of system walkdown inspections at a minimum specified frequency (12 months, or refueling intervals for those components not accessible during normal opRration)(once each operating cycle within the limits of accessibility). Include requirements for a review, evaluation and approval for any deferred inspections. Require documentation to be retained and retrievable. Require an Action Request be generated if the inspections do not occur within the inspection interval. As an alternative to placing these restrictions in the existing implementing documents, CHAMPS callups may be generated subject to the constraints placed on deferrals, cancellation, and frequency changes for license renewal.
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I Page B-213 Monitoring and Trending Visual inspections are performed at least once per operating cycle within the limits of accessibility. year for thoesystoems and conRtS that alo rng nrmal plant oprrationR. Syctom and compoRnnt that aro only accociblo during plant-outago6, aro inspoctod at teast onco por rofuoling interpal.
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LRA Section APPENDIX B AGING MANAGEMENT PROGRAMS BACKGROUND Based upon the NRC staff request during the staff meeting with NMC on February 15, 2005, the confirmatory Pre-Stressed Concrete Containment Tendon Surveillance Program (LRA Section B3.3) has been deleted from the LRA.
DESCRIPTION OF CHANGES TO LICENSE RENEWAL APPLICATION (additions are double-underlined; deletions are strikethrough)
LRA Section B 3.3, starting on LRA page B-245, is deleted.
B3.3 Pre-Stressed Concrete Containment Tendon Surveillance Programn PFgaM DesG~iptUen Tho Pro Stressed Concroto Containment Tendon Surveillanco Program is a confirmater' program that monitors the loss of containment prectressing fores in containment tendons throughout the life of the plant, inRcuding the poriod of eXtonord operation. This program consistof an assessment of the resultS of the tendon pro6tressing force moasurFmonts porformed in accordance with ASMME Soction RxI, Subsection IWL. The assessment related to the adoquacy of tho prestressing forces will consist of the establishmont of (a) acceptance criteria, and (b) trend line6. The acceptance criteria will normall, consist of a predicoted ower imit (PLL.
) and the minimum required prestres6ing force or value (MRV). The trend line represents the trend of prestressing forces based on actual measured foroes. Maintaining the pre6tre66ing force trend lines above the PLL ensures that the prestressing forces in the containment would not be below the MRVs prier to the end of tho period of extended operation. In accordanco with the requirements of 10 CFR 50.55a(b)(2)(viii)(B),-an evaluation will be performed if the trend lines predict the pre6tres6ing forcs6 in the contai*nmnt to be below the MRV befhre th t che duled inspection.
The PLL and upper bnnAd Of the tolraRne band for each tendon group was recalculated for the 60 year life of the tendons based on the Actual Seating Stress vs.
the Minimum Design Seating Stress. The Caldulation wara performed using the guidelines provided in NRC Regulatory Guide 1.35.1 (Reference 30). NRC-nformation oti 10 (RefeRenc 31) discusses the potential for teRdon wire breakage, the effects-of high tempertuGr on teandn prestmrss foren e, aRd make r rommeRdations regarding the trending of prostros6 forces. Th new calcu!lation take6 wire breakage into account and used a 1% brekeonrmissing wire vllowance. The results of the calculation indicate that the PLL romains above the MRV through the life of the plant, including the period of exteRded operation.
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C.
During tho schodulod survoillancos, tho tondon prostross forco i6 moasured for a random samplo of each tendon group. Ono tondon in each group is designated as tho common tendon. Tho prostress forco i; tho common toRdon is measured duriR each surwillano r
aRd iS used to establirh tho trond of prostress less for tho group. An evaluation is roquirod if tho acceptance criteria of ASME Section XI, Subsoction lIWL is not mot, or if the trond indicatec that tondon ferco(s) would bo los6 than the MRV before the noxt schoduled in6pection, as roquired by 10 CFR 50.55a(b)(2)( iii)(B).
NUREG-i80l Consistency Tho Pro StrFesed Concrete Containment Tendon Surveillance Program is an existing program that is consistent with NUREG 1801, "Generic Aging Les6sns Learned (GALL)
Report," Scti9on X.SY, "Concrete CrntainRennt Tendon PreStress" (Refeen 3r Exceptions to NUREG 1801 NG;;e Enha:ncepmentR Enhancements to the Pro Stressed Concrete Containment Tendon SurweillanRe Program include more detailed requirements regarding tho trending and evaluation of inspection results. Additionally, the WI=L implementation schedule will be revised to include the period of extended operation. These enhancements are required to satisfy the NUREG-1801 aging managomont progra rouiemnt6. Details6 of the enhRe~n9Rnnts -re iRoludedrliR tho -nror
-t elmnl3rGriptiGRnbe hlre Enhancements are scheduled for completion prior to the period of extended operation.
Aging Management Program Elements The key elementrs, Whih are used in the Pro strressed oncrete Containment Tendon Surweillao Program, are described belew. The results of an evaluation of each key element against NUREG 1801, "Generic Aging Lessons Learned (GALL) Report,"
Section X.S1, "Concrete Containment Tendon Prestress," is also provided below.
Scorpe Of Pogramr The program addresses the assesrOment of Unit and Unlit 2 cortainment tenRdon wire prestrerssiRng for9. During the scheduled sureillances, the tenRdon prestress force is measured for a random sample of each tendon group. One tendon in each group is dosignatod as the common tendon. The proetres6 force in the common tendon is measured during each surveillance and is used to establi6h the trend of prestres6 less for the'group. The trnRd of psress foefor each grou i omred to the MRV to ensure that the prestres force will nRot fall below the MR priorr to next sche uled Page 84 of 87
in6pection. PBNP calculations indicate that the PLL romains above the MRV throughout tho life of the plant, including the period of extended oporation.
This element i6 consistent with the corresponding NUREG 1801 aging-management program element.
Preventive Actions Ther are nR preventive actions asseriated with this progm. As lngr as the tendon wire prestressing values are found to be within the acceptance criteria no actions are required. Maintaining the pre6troes above the MRV will ensure that the 6tructural and functional adequacy of the containment aro maintained.
This element is consistent with the corresponding NUREG 1801 aging management Parameters Menitored or Inspected The parameters monitored are the containment tendon wire pre6troesing forces in aonrSdance with the rquiremeRnts specified in Subsection IWL of Section Xl of the
,ASS~.E Code, Wzhich is desribed; in the PBNPE ISI IWIL Containment lnRpectiRn Program.
This element is consistent with the correSponding NUREG 1801 aging management nracrnm nlomAnt Dect.tion of Aging Effects The loss of tendon Wirne prstreeSing forces is detected by p9eGormnne of the tenRdn inspections conducted per the PBNP ISI-IWL Containment Inspection Program.
Enhancements to the Pro Stressed Concrete Containment Tendon Surveillance Program will result in the inclusion of more detailed requirements regarding the trending and evaluation of inspection results. Additionally, the IW=L implementation schedule will be reviSed to include the period of extended operation.
This element is consistent with the corresponding NUREG 1 801 aging managment program oloenet.
Monitoring and Trending The tendon wire proetrFesing forces are cormpared to the PLI anrd upper bound line that were developed for the period of extended operation. ProstreSS force trends are al6o evaluated to en6ure that the prestress force will net fall below the MRV prior to the next scheduled inspection.
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Now common tendonS which havo not boon previously rotonsienod woro soloctod for tho 28th year surveillanco; Those tondonI will bo te6ted in futuro surveillances in ordor to e6tablish valid pro6trese forco trend linos.
T-his element isGconsstont Rwiththe FoerresorndingNUREG-1801 ing manageme ArcGeptance Criteria An evaluation ireqired if tho acceptanco criteria of ASME Section; Xl, Subsectionr I
is not met, or if tho trend indicateo that tendon force(s) would bo l6os than the MRV before the noxt scheduled inspection, as roquired by 10 CFR 50.55a(b)(2)(viii)(B).
This element is consistent with the corresponding NUREG 1 801 aging management program element.
Corr-ctive Actions Corrective actionsaro irnpl~ornted in accordance with the requirements of 10 CFR 50, Appendix B, "Quality A6surance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," anrd AINSI N18.7 1976, "Administrati'.o Contrls anrd Quality Assurance for the Operational Phase of Nuclear P Pantr," as committed in Section 1.1 of the PB3NP Final Safety Analysis. RopedFt (ASR).
This element is consistent with the corre6ponding NUREG-1801 aging management program olomont.
Confirmation Process The confirmation process is part of the corrective action program, which is implemented in accordance with the requirements of 10 CFR 50, Appendix B and ANSI N18.7 1976, as committed in Section 1.1 of the PBNP FSAR.
This eolmont i6 consistent with the corresponding NUREG-1801 aging managemont prograrm eltment.
AdminiStrative Controls The Pro-Stressed Concroet Containment Tendon Surveillanco Program is implemented through various plant documents. These implementing document e
are subject to administrative controls, including a formal review and approval process, in accordance with the requirements Of 10 CFR 50, Appendix B and ANSI N18.7 1976, as committed in Section 1.4 of the PBNP FSAR.
This element i6 consistent with the corresponding NUREG1 8041 agingmanagement program element.
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Opeating Experien~e The calculated PLL and past inspection results indicate that the containment tendon wire protroess forFes for RBNP nItRs 1 & 2 a-r expected to romain above tho MRV for tho period of eoxrdod operatiG-on During the preparations for the 28th year tendon survoillancG, it was discovered that the designated "common" or "control" tendon6 (i.e., those tondons in each group that are tested ever; 6ruenilanae in order to e stalish the trend of proetrres force for that group) had been roTsiRoned duriRg each preced!ring rureilfannce a-reommended by earlier verSIonR of Reg. Guide 1.35. Periodic rotnrsi*ning of these tendons did not allow an accurate determination of the prestress force relaxation trends. New common tendons which have not been previou6ly retensionod were 6seected for the 28th year sur.eillance. Those tendons will be tested in futuro sur.eillance6 in order to establish valid prestross frcre trends. The NRC was, advised f this rsituation in a June, 199 letter. (Reference 1 1).
A review of NRC Inspection Repors, QA Audit/Surveillance Repoes, and Self-Assessments since 18999 revealed no issues or findings that could impact the effectivomnsrs nof the Po -Stressed ConcrGete-Containe Tendon Sur^ollanPr ogram.
As additional operating prince is obtained, lessnRs learned may be used to adjust thi6 pFogram.
This element is consistent with the corresponding NUREG 1 801 aging management program element.
The Pro Stressed Concrete Containment Tendon Surveillanco Program provides reasonable assurance that the aging effect of-loss of containment prestressing forces will be managed, such that the containment tendons will continue to peofForm their intended function consistent with the current licensing ba6is during the extended period of operation. The -oentainRment tendonRs have bon inspected eight times on each unit since the plant began operation. The tendon prostress PLL has boonR reclculated and plotted using the actual 6eating stress instead of the design stress. The recalculation accounted4for a 1°' allowance for wire breakage and considered a 60 year life of the plant. The measured prs6trs66 force of the designated common tendons will be trended and omnpared to the PI and MR'.'.
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