ULNRC-06090, Enclosure 2: Amendment 32, LRA Changes
| ML14073A005 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/13/2014 |
| From: | Ameren Missouri, Union Electric Co |
| To: | Document Control Desk |
| Shared Package | |
| ML14073A002 | List:
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| References | |
| ULNRC-06090 | |
| Download: ML14073A005 (19) | |
Text
ULNRC-06090 March 13, 2014 Page 1 of 19 Amendment 32, LRA Changes Summary Table Affected LRA Section LRA As-Submitted Page Number(s)
Table 3.2.2-5 3.2-63 Table 3.3-1 3.3-81 Table 3.3.2-4 3.3-95 Table 3.3.2-26 3.3-260 Table 3.4-1 3.4-15 and 3.4-31 Table 3.4.2-4 3.4-49 Section A1.23 A-13 Section B2.1.21 B-75 through B-78 Section B2.1.23 B-81 through B-83
ULNRC-06090 March 13, 2014 Page 2 of 19 Callaway Plant License Renewal Application Amendment 32 Restored the aging evaluation for cracking of a stainless steel tank in a treated borated water environment that was inadvertently deleted.
Table 3.2.2-5 (Page 3.2-63) is revised as follows (new text underlined):
Table 3.2.2-5 Engineered Safety Features - Summary of Aging Management Evaluation - High Pressure Coolant Injection System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Tank PB Stainless Steel Treated Borated Water (Int)
Cracking Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18)
V.A.E-12 3.2.1.020 A
ULNRC-06090 March 13, 2014 Page 3 of 19 Callaway Plant License Renewal Application Amendment 32 Revised discussion column for aboveground metallic tanks line items to clarify the discussion is applicable to aboveground metallic tanks within the scope of Chapter XI.M29, Aboveground Metallic Tanks.
Table 3.3-1, Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems, (Page 3.3-81) is revised as follows (new text underlined and deleted text shown in strikethrough):
Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Number Component Type Aging Effect / Mechanism Aging Management Program Further Evaluation Recommended Discussion 3.3.1.128 Steel, stainless steel, or aluminum tanks (within the scope of Chapter XI.M29, Aboveground Metallic Tanks) exposed to soil or concrete, or the following external environments air-outdoor, air-indoor uncontrolled, moist air, condensation Loss of material due to general (steel only), pitting, or crevice corrosion; cracking due to stress corrosion cracking (stainless steel and aluminum only)
Aboveground Metallic Tanks (B2.1.15)
No Not applicable. Other than the fire water storage tanks that are managed by the fire water system program (B2.1.14),
Callaway has no in-scope steel, stainless steel, or aluminum tanks greater than 100,000 gallons (within the scope of Chapter XI.M29, Aboveground Metallic Tanks) exposed to a soil or concrete, or external environments within the auxiliary systems, so the applicable NUREG-1801 line was not used.
ULNRC-06090 March 13, 2014 Page 4 of 19 Table 3.3-1 Summary of Aging Management Programs in Chapter VII of NUREG-1801 for Auxiliary Systems Item Number Component Type Aging Effect / Mechanism Aging Management Program Further Evaluation Recommended Discussion 3.3.1.129 Steel tanks exposed to soil or concrete; air-indoor uncontrolled, raw water, treated water, waste water, condensation Loss of material due to general, pitting, and crevice, corrosion.
Aboveground Metallic Tanks (B2.1.15)
No Not applicable. Other than the fire water storage tanks that are managed by the fire water system program (B2.1.14),
Callaway has no in-scope steel tanks greater than 100,000 gallons (within the scope of Chapter XI.M29, Aboveground Metallic Tanks) exposed to a soil or concrete; air-indoor uncontrolled, raw water, treated water, waste water, condensation environments within the auxiliary systems, so the applicable NUREG-1801 line was not used.
3.3.1.137 Steel, stainless steel or aluminum tanks (within the scope of Chapter XI.M29, Aboveground Metallic Tanks) exposed to treated water, treated borated water Loss of material due to general (steel only) pitting and crevice corrosion Aboveground Metallic Tanks (B2.1.15)
No Not applicable. Other than the fire water storage tanks that are managed by the fire water system program (B2.1.14),
Callaway has no in-scope steel, stainless steel, or aluminum tanks greater than 100,000 gallons (within the scope of Chapter XI.M29, Aboveground Metallic Tanks) exposed to treated water or treated borated water within the auxiliary systems, so the applicable NUREG-1801 line was not used.
ULNRC-06090 March 13, 2014 Page 5 of 19 Callaway Plant License Renewal Application Amendment 32 Revised plant notes to correct a typographical error and reference plant specific note 4.
Table 3.3.2-4 (Page 3.3-95) is revised as follows (new text underlined and deleted text shown in strikethrough):
Table 3.3.2-4 Auxiliary Systems - Summary of Aging Management Evaluation - Essential Service Water System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Piping LBS, PB, SIA Carbon Steel Raw Water (Int)
Wall thinning Open-Cycle Cooling Water System (B2.1.10)
VII.C1.A-409 3.3.1.126 E, 3 E, 4 Notes for Table 3.3.2-4:
Plant Specific Notes:
1 External Surfaces Monitoring of Mechanical Components program (B2.1.21) is used instead of Open Cycle Cooling Water program (B2.1.10) to manage the aging of the external surfaces of nonsafety-related components exposed to raw water.
2 HDPE components in a plant indoor air environment are not exposed to an aggressive chemical environment that would concentrate contaminants and degrade HDPE chemical and mechanical properties. HDPE is not exposed to ozone, ionizing radiation or a UV source (sunlight or fluorescent light) that would result in aging. Operating temperatures do not exceed 140°F. HDPE components in a plant indoor air environment have no aging effects requiring aging management.
3 This TLAA is applicable to the high-density polyethylene (HDPE) piping. Section 4.7.7 describes the evaluation of this TLAA for the replacement ESW piping.
4 Open-Cycle Cooling Water System program (B2.1.10) is used instead of Flow-Accelerated Corrosion program (B2.1.7) to manage wall thinning due to erosion of carbon steel piping exposed to raw water.
5 The Open-Cycle Cooling Water System program (B2.1.10) is used to monitor for recurring internal corrosion in the ESW system. See Further Evaluation 3.3.2.2.8.
6 The Bolting Integrity program (B2.1.8) is used instead of the Open-Cycle Cooling Water program (B2.1.10) to manage loss of material in submerged closure bolting.
ULNRC-06090 March 13, 2014 Page 6 of 19 Callaway Plant License Renewal Application Amendment 32 Revised Table 3.3.2-26 revised to correct a typographical error and reference Table 1 Item 3.3.1.135.
Table 3.3.2-26 (Page 3.3-260) is revised as follows (new text underlined and deleted text shown in strikethrough):
Table 3.3.2-26 Auxiliary Systems - Summary of Aging Management Evaluation - Oily Waste System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Pump LBS Stainless Steel Waste Water (Ext)
Loss of material External Surfaces Monitoring of Mechanical Components (B2.1.21)
VII.E5.A-411 3.3.1.072 3.3.1.135 A
Pump LBS Stainless Steel Waste Water (Int)
Loss of material External Surfaces Monitoring of Mechanical Components (B2.1.21)
VII.E5.A-411 3.3.1.072 3.3.1.135 A
ULNRC-06090 March 13, 2014 Page 7 of 19 Callaway Plant License Renewal Application Amendment 32 Table 3.4-1 item 012 was revised to reflect consistency with NUREG-1801 based on the recent changes to the steam generator blowdown system for the carbon steel tank in a secondary water environment aging evaluation line. Also corrected a typographical error in Table 3.4-1 item numbers.
Table 3.4-1, Summary of Aging Management Programs in Chapter VIII of NUREG-1801 for Steam and Power Conversion System, (Pages 3.4-15 and 3.4-31) is revised as follows (deleted text shown in strikethrough and new text shown underlined):
Table 3.4-1 Summary of Aging Management Programs in Chapter VIII of NUREG-1801 for Steam and Power Conversion System Item Number Component Type Aging Effect / Mechanism Aging Management Program Further Evaluation Recommended Discussion 3.4.1.012 Steel; stainless steel Tanks exposed to Treated water Loss of material due to general (steel only), pitting, and crevice corrosion Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18)
No Not applicable. Callaway has no in-scope steel or stainless steel tanks less than 100,000 gallons exposed to treated water in the steam and power conversion systems, so the applicable NUREG-1801 lines were not used.
Consistent with NUREG-1801.
3.4.061 3.4.1.061 Metallic piping, piping components, and tanks exposed to raw water or waste water Loss of material due to recurring internal corrosion A plant-specific aging management program is to be evaluated to address recurring internal corrosion Yes, plant-specific (See subsection 3.4.2.2.6)
Not applicable. Callaway has no in-scope components subject to recurring internal corrosion in the steam and power conversion systems, so the applicable NUREG-1801 lines were not used.
3.4.062 3.4.1.062 Steel, stainless steel or aluminum tanks (within the scope of Chapter XI.M29, Aboveground Metallic Tanks) exposed to treated water Loss of material due to general (steel only), pitting, and crevice corrosion Aboveground Metallic Tanks (B2.1.15)
No Consistent with NUREG-1801.
ULNRC-06090 March 13, 2014 Page 8 of 19 Table 3.4-1 Summary of Aging Management Programs in Chapter VIII of NUREG-1801 for Steam and Power Conversion System Item Number Component Type Aging Effect / Mechanism Aging Management Program Further Evaluation Recommended Discussion 3.4.063 3.4.1.063 Insulated steel, stainless steel, copper alloy, aluminum, or copper alloy (> 15%
Zn) piping, piping components, and tanks exposed to condensation, air-outdoor Loss of material due to general (steel, and copper alloy), pitting, or crevice corrosion, and cracking due to stress corrosion cracking (aluminum, stainless steel and copper alloy (>15% Zn) only)
External Surfaces Monitoring of Mechanical Components (B2.1.21) or Aboveground Metallic Tanks (B2.1.15) (for tanks only)
No Consistent with NUREG-1801.
3.4.064 3.4.1.064 Jacketed calcium silicate or fiberglass insulation in an air-indoor uncontrolled or air-outdoor environment Reduced thermal insulation resistance due to moisture intrusion External Surfaces Monitoring of Mechanical Components (B2.1.21)
No Consistent with NUREG-1801.
3.4.065 3.4.1.065 Jacketed foamglas (glass dust) insulation in an air-indoor uncontrolled or air-outdoor environment Reduced thermal insulation resistance due to moisture intrusion External Surfaces Monitoring of Mechanical Components (B2.1.21)
No Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program Aboveground Metallic Tanks (B2.1.15) is credited.
ULNRC-06090 March 13, 2014 Page 9 of 19 Callaway Plant License Renewal Application Amendment 32 Revised Table 3.4.2-4 to reference NUREG-1801 item VIII.E.SP-75 for tanks rather than NUREG-1801 item VIII.F.SP-74 for piping.
Table 3.4.2-4 (Page 3.4-49) is revised as follows (new text underlined and deleted text shown in strikethrough):
Table 3.4.2-4 Steam and Power Conversion System - Summary of Aging Management Evaluation - Steam Generator Blowdown System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Program NUREG-1801 Item Table 1 Item Notes Tank SIA Carbon Steel Secondary Water (Int)
Loss of material Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.18)
VIII.F.SP-74 VIII.E.SP-75 3.4.1.013 3.4.1.012 C
A
ULNRC-06090 March 13, 2014 Page 10 of 19 Callaway Plant Unit 1 Page A-13 License Renewal Application Amendment 32 Appendix A Final Safety Analysis Report Supplement A1.23 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING AND DUCTING COMPONENTS The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program manages changes in material properties, cracking, loss of material, hardening and loss of strength. The program inspects internal surfaces of metallic piping, concrete piping, piping components, piping elements, ducting, heat exchanger components, polymeric and elastomeric components, and other components that are exposed to plant indoor air, ventilation atmosphere, atmosphere/weather, condensation, borated water leakage, diesel exhaust, lubricating oil, and water system environment not managed by Open-Cycle Cooling Water System (A1.10), Closed Treated Water System (A1.11), Fire Water System (A1.14),
and Water Chemistry (A1.2) programs.
Internal inspections are normally performed at opportunities where the internal surfaces are made accessible, such as periodic system and component surveillance activities or maintenance activities. Visual inspections of internal surfaces of plant components are performed by qualified personnel. For certain materials, such as polymers, visual inspections will be augmented by physical manipulation or pressurization to detect hardening, loss of strength, and cracking. The program includes inspections to detect material degradation that could result in a loss of component intended function.
If work opportunities are not sufficient to allow inspection of a representative sample of components, supplemental inspections are also performed. A representative sample size is 20 percent of the accessible and inaccessible component population (defined as components having the same material and environment combination) up to a maximum of 25 components. The locations and intervals for supplemental inspections are based on assessments of the likelihood of significant aging effects, derived from current industry and plant-specific operating experience.
At a minimum, in each 10-year period during the period of extended operation a representative sample of 20 percent of the population (defined as components having the same combination of material, environment, and aging effect) or a maximum of 25 components per population is inspected. Where practical, the inspections focus on the bounding or lead components most susceptible to aging because of time in service, and severity of operating conditions. Opportunistic inspections continue in each period despite meeting the sampling limit.
Components having the same material-environment combination with repetitive failures due to aging require a plant-specific program, unless the component material has been replaced by a material of more corrosion resistance for the environment of interest.
Following a failure due to recurring internal corrosion, this program may be used if the failed material is replaced by one that is more corrosion-resistant in the environment of interest, or corrective actions have been taken to prevent recurrence of the recurring internal corrosion.
ULNRC-06090 March 13, 2014 Page 11 of 19 Callaway Plant Unit 1 Page A-14 License Renewal Application Amendment 32 Appendix A Final Safety Analysis Report Supplement In addition, the internal coatings of the service water pump strainers are periodically visually inspected to ensure that loss of coating integrity is detected prior to (1) loss of component intended function, including loss of function due to accelerated degradation caused by localized coating failures, and (2) degradation of downstream component performance due to flow blockage.
The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program and will be implemented prior to the period of extended operation.
Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.
ULNRC-06090 March 13, 2014 Page 12 of 19 Callaway Plant Unit 1 Page B-75 License Renewal Application Amendment 32 Appendix B AGING MANAGEMENT PROGRAMS B2.1.21 External Surfaces Monitoring of Mechanical Components Program Description The External Surfaces Monitoring of Mechanical Components program manages loss of material and cracking for metallic components and cracking and changes in material properties for cement board (splash panel) components. The program also manages loss of material, cracking, hardening and loss of strength for polymeric components.
Visual inspections of external surfaces will be conducted with system inspections and walkdowns of metallic components for evidence of loss of material and leakage. The inspection parameters for metallic components include material condition, which consists of evidence of corrosion, corrosion stains, material wastage, evidence of insulation damage or wetting; wear, flaking or oxide-coated surfaces; and leakage onto external surfaces. Coating degradation (e.g. cracking, flaking, and blistering) is used as an indicator of possible underlying degradation of the component. Polymer visual inspections will inspect for surface cracking, crazing, discoloration, wear, scuffing, dimensional change, exposure of internal reinforcement, and hardening/loss of strength as evidenced by loss of suppleness during manual or physical manipulation. Stainless steel monitoring will also include visual inspection for cracking when exposed to an aggressive air environment containing halides. Cement board visual inspections will inspect for loss of material or cracking that results in a loss of the components intended function.
Visual inspections of components in normally accessible locations are conducted at least every refueling outage. This frequency accommodates inspections of components that may be in locations that are normally only accessible during outages. Surfaces that are not readily visible during plant operations and refueling outages are inspected when they are made accessible and at intervals that would ensure the components intended functions are maintained. Inspection intervals for inaccessible components will be determined based on an evaluation of aging effects and their impact on intended functions observed during external surface inspections on accessible components with the same material and environment combination.
Reduced thermal insulation resistance due to moisture intrusion, associated with insulation which is jacketed, is managed by visual inspection of the condition of the jacketing when the insulation has been included in scope to reduce heat transfer from the insulated components. Outdoor insulated components, and indoor components exposed to condensation (because the in-scope component is operated below the dew point), have portions of the insulation inspected or removed to determine whether the exterior surface of the component is degrading or has the potential to degrade.
Visible evidence of degradation will be evaluated to ensure the components intended functions are maintained. Visual inspection activities will be performed by qualified personnel in accordance with site controlled procedures and processes. Deficiencies are documented and evaluated under the corrective action process.
ULNRC-06090 March 13, 2014 Page 13 of 19 Callaway Plant Unit 1 Page B-76 License Renewal Application Amendment 32 Appendix B AGING MANAGEMENT PROGRAMS The following aging management programs manage external surface aging of metallic or polymeric mechanical components outside the scope of the External Surfaces Monitoring program:
- 1. Boric Acid Corrosion program (B2.1.4) for components in systems near treated borated water or reactor coolant environments where boric acid corrosion may occur.
- 2. Buried and Underground Piping and Tanks program (B2.1.25) for buried components in buried and underground environments.
- 3. Aboveground Metallic Tanks program (B2.1.15) for external surfaces of outdoor, above-ground metallic tanks.
- 4. ASME Section XI ISI, Subsections IWB, IWC, and IWD program (B2.1.1) for Class 1, 2, and 3 pressure-retaining components and their integral attachments.
- 5. Fire Protection program (B2.1.13) for external surfaces of Halon system and associated components.
The External Surfaces Monitoring of Mechanical Components program is a new program that will be implemented prior to the period of extended operation.
NUREG-1801 Consistency The External Surfaces Monitoring of Mechanical Components program is a new program that, when implemented, will be consistent with NUREG-1801,Section XI.M36, External Surfaces Monitoring of Mechanical Components and LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation.
Exceptions to NUREG-1801 None Enhancements None Operating Experience The following discussion of operating experience provides objective evidence that the External Surfaces Monitoring of Mechanical Components program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation.
ULNRC-06090 March 13, 2014 Page 14 of 19 Callaway Plant Unit 1 Page B-77 License Renewal Application Amendment 32 Appendix B AGING MANAGEMENT PROGRAMS
- 1. The External Surfaces Monitoring of Mechanical Components program is a new program, however, external surface monitoring via system walkdown inspections are already in effect at Callaway. Routine system walkdowns are performed as part of the Plant Health and Performance Monitoring Program. The results of the walkdowns provide data for performance monitoring and trending, are an input to work planning and prioritization process, and are communicated in the System Health Reports and System Performance Monitoring Indicators. The walkdown inspections have been used to effectively maintain the condition of component external surfaces. The scope of these inspections and the inspection techniques are in accordance with industry practice. A review of the plant-specific operating experience for the past 10 years showed that the Plant Health and Performance Monitoring Program has been effective in maintaining the condition of component external surfaces.
- 2. In 2006, cracking was found on a rubber expansion joint located between the essential service water piping and the diesel generator intercooler heat exchanger. An extent of condition review revealed cracking on the expansion joint of the opposite train. Both expansion joints were replaced. The apparent cause of the cracking was pipe misalignment. The PMs to inspect the heat exchanger tubes were revised to include an inspection of the expansion joints. During the repair, it was discovered that the spare expansion joint in the warehouse was also cracked. As a result, the shelf life of the expansion joints was decreased from 372 months to 60 months. Expansion joint storage methods were changed to require bagging to mitigate their aging effects.
- 3. In 2006, loss of material due pitting and general corrosion was identified on essential service water supply line piping. A piping ultrasonic test confirmed the piping met minimum wall thickness. The pipe coating was completely restored on all bare metal surfaces of this piping, up to the floor seal. Inspection of safety-related carbon steel cooling piping exposed to aggressive environments and in the vicinity of penetrations through floors, walls, and ceilings was performed to determine extent of condition. No indications of significant corrosion were found as a result of these inspections.
- 4. In 2006, loss of material due pitting and general corrosion was identified on piping in the pipe chase between the condensate storage tank and the auxiliary building. The piping was ultrasonically examined to determine loss of wall thickness. Piping was replaced or recoated consistent with the results of the ultrasonic examinations. The apparent cause of the corrosion was intrusion of rainwater through the equipment access hatch at ground level outside of the condensate storage tank valve house. The access panel was resealed to prevent rain water intrusion.
ULNRC-06090 March 13, 2014 Page 15 of 19 Callaway Plant Unit 1 Page B-78 License Renewal Application Amendment 32 Appendix B AGING MANAGEMENT PROGRAMS
- 5. In 2008, during a mechanical maintenance pre-job walkdown, expansion joint surface cracking was found on the emergency diesel generator intercooler heat exchanger shell side inlet and outlet. The shallow surface cracking was determined to not affect the structural integrity of the joint. The expansion joints are regularly inspected and trended per established preventive maintenance activities, so no further actions were required. During inspection of additional expansion joints on the essential service water system, additional expansion joints with cracks and visible cords were found.
Expansion joints containing cracks deep enough to affect the second layer of nylon cording were replaced, since cracking of this layer questions the structural stability of the expansion joint.
The operating experience for the system walkdown inspections that will be incorporated into the External Surfaces Monitoring of Mechanical Components program did not show any adverse trend in performance. Occurrences that would be identified by the system walkdowns will be evaluated to ensure there is no significant impact to the safe operation of the plant and adequate corrective actions will be taken to prevent recurrence.
Appropriate guidance for re-evaluation, repair, or replacement will be provided for locations where aging is found. There is confidence that the implementation of the External Surfaces Monitoring of Mechanical Components program will effectively identify aging prior to loss of intended function.
Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.
Conclusion The implementation of the External Surfaces Monitoring of Mechanical Components program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
ULNRC-06090 March 13, 2014 Page 16 of 19 Callaway Plant Unit 1 Page B-81 License Renewal Application Amendment 32 Appendix B AGING MANAGEMENT PROGRAMS B2.1.23 Inspection of Internal Surfaces of Miscellaneous Piping and Ducting Components Program Description The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program manages changes in material properties, cracking, loss of material, hardening and loss of strength. The program inspects internal surfaces of metallic piping, concrete piping, piping components, piping elements, ducting, heat exchanger components, polymeric and elastomeric components, and other components that are exposed to plant indoor air, ventilation atmosphere, atmosphere/weather, condensation, borated water leakage, diesel exhaust, lubricating oil, and any water system environment not managed by Open-Cycle Cooling Water System (B2.1.10), Closed Treated Water System (B2.1.11),
Fire Water System (B2.1.14), and Water Chemistry (B2.1.2) programs.
Internal inspections are performed opportunistically whenever the internal surfaces are made accessible, such as periodic system and component surveillance activities or maintenance activities. Visual inspections of internal surfaces of plant components are performed by qualified personnel. For certain materials, such as polymers, visual inspections will be augmented by physical manipulation of at least 10 percent of the accessible surface area or pressurization to detect hardening, loss of strength, and cracking. Volumetric evaluations are performed when appropriate for the component environment and material. Volumetric evaluations such as ultrasonic examinations are used to detect stress corrosion cracking of internal surfaces such as stainless steel components exposed to diesel exhaust.
If work opportunities are not sufficient to allow inspection of a representative sample of components, supplemental inspections are also performed. A representative sample size is 20 percent of the accessible and inaccessible component population (defined as components having the same material and environment combination) up to a maximum of 25 components. The locations and intervals for supplemental inspections are based on assessments of the likelihood of significant aging effects, derived from current industry and plant-specific operating experience.
At a minimum, in each 10-year period during the period of extended operation a representative sample of 20 percent of the population (defined as components having the same combination of material, environment, and aging effect) or a maximum of 25 components per population is inspected. Where practical, the inspections focus on the bounding or lead components most susceptible to aging because of time in service, and severity of operating conditions. Opportunistic inspections continue in each period despite meeting the sampling limit.
Identified aging deficiencies are documented and evaluated by the Corrective Action Program. Acceptance criteria are established in the maintenance and surveillance procedures or are established during engineering evaluation of the degraded condition. If the inspection results are not acceptable, the condition is evaluated to determine whether the component intended function is affected, and a corrective action is implemented.
ULNRC-06090 March 13, 2014 Page 17 of 19 Callaway Plant Unit 1 Page B-82 License Renewal Application Amendment 32 Appendix B AGING MANAGEMENT PROGRAMS Components having the same material-environment combination with repetitive failures due to aging require a plant-specific program, unless the component material has been replaced by a material of more corrosion resistance for the environment of interest.
Following a failure due to recurring internal corrosion, this program may be used if the failed material is replaced by one that is more corrosion-resistant in the environment of interest, or corrective actions have been taken to prevent recurrence of the recurring internal corrosion.
In addition, the internal coatings of the service water pump strainers are periodically visually inspected to ensure that loss of coating integrity is detected prior to (1) loss of component intended function, including loss of function due to accelerated degradation caused by localized coating failures, and (2) degradation of downstream component performance due to flow blockage.
The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that will be implemented prior to entering the period of extended operation.
NUREG-1801 Consistency The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that, when implemented, will be consistent with exception to NUREG-1801,Section XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.
Exceptions to NUREG-1801 Program Elements Affected:
Scope of Program (Element 1), Parameters Monitored or Inspected (Element 3),
Detection of Aging Effects (Element 4), and Monitoring and Trending (Element 5)
NUREG-1801 requires a visual examination of the internal surface of components within the scope of this program. The diesel exhaust is not available for internal surface inspection, so a volumetric examination will be performed for this component. The volumetric examination is adequate for detecting loss of material (wall thinning) and cracking of piping and tubing.
Enhancements None
ULNRC-06090 March 13, 2014 Page 18 of 19 Callaway Plant Unit 1 Page B-83 License Renewal Application Amendment 32 Appendix B AGING MANAGEMENT PROGRAMS Operating Experience The following discussion of operating experience provides objective evidence that the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation.
- 1. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will be a new program at Callaway. Internal surface monitoring through visual inspections conducted during maintenance activities and surveillance testing are already in effect in Callaway. The results of the inspections provide data for performance trending, are an input to work planning and prioritization process, and are communicated in the System Health Reports and System Performance Monitoring Indicators. Plant-specific operating experience since 2000 was reviewed to ensure that the operating experience discussed in the corresponding NUREG-1801 aging management program is bounding, i.e., that there is no unique plant-specific operating experience in addition to that described in NUREG-1801. The review also showed that the Plant Health and Performance Monitoring Program had been effective in maintaining the condition of component internal surfaces.
- 2. In 2007, during maintenance activities, the threaded tube end plugs on the 'B' centrifugal charging pump room cooler were found to have a loss of material due to corrosion as introduced by wear and deformation to the plugs from the repeated assembly/disassembly and cleanings. None of the plugs were leaking. An evaluation determined that 125 plugs would be replaced, future inspections of the room cooler coils would include inspection of tube plugs for loss of material due to corrosion, and replacements would be determined on a case-by-case basis. Later in 2007, the 'A' containment spray pump room cooler was inspected. There was no noticeable damage to the plugs in this cooler. Additional corrective action was to ensure a continuous on-site availability of enough plugs to replace all the plugs in one room cooler.
Internal inspections conducted during maintenance activities and surveillance testing and the Plant Health and Performance Monitoring Program have been effective in maintaining the condition of component internal surfaces. Occurrences that would be identified under the Internal Surfaces in Miscellaneous Piping and Ducting Components program will be evaluated to ensure there is no significant impact to safe operation of the plant and corrective actions will be taken to prevent recurrence. Guidance for re-evaluation, repair, or replacement is provided for locations where aging is found. There is confidence that the implementation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will effectively identify aging prior to loss of intended function.
Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.
ULNRC-06090 March 13, 2014 Page 19 of 19 Callaway Plant Unit 1 Page B-84 License Renewal Application Amendment 32 Conclusion The implementation of the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.