ULNRC-06118, Updated RAI Response to the License Renewal Application, Enclosures 1 and 2

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Updated RAI Response to the License Renewal Application, Enclosures 1 and 2
ML14127A151
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Site: Callaway Ameren icon.png
Issue date: 05/06/2014
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Ameren Missouri
To:
Office of Nuclear Reactor Regulation
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ULNRC-06118
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ULNRC-06118 May 6, 2014 Page 1 of 11

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CALLAWAY PLANT UNIT 1 LICENSE RENEWAL APPLICATION UPDATED RAI RESPONSES

  • RAI 3.0.3-2a, Loss of Coating Integrity
  • RAI 3.3.2-2a, Submerged Bolting

ULNRC-06118 May 6, 2014 Page 2 of 11 RAI 3.0.3-2a, Loss of Coating Integrity (Followup)

Background:

1. RAI 3.0.3-2 Request (c) requested that the frequency of coating inspections be stated. The response to the RAI, dated December 20, 2013, stated in part, "[i]f no indications are found during inspection of one train, the redundant train would not be inspected". The response further stated that the scope of internally coated components includes heat exchangers, air conditioners, and strainers.
2. The response to the RAI stated that the interior surfaces of the fuel oil storage tanks are managed by the Fuel Oil Chemistry program. The "detection of aging effects" program element of GALL Report AMP XI.M30, "Fuel Oil Chemistry," states that, at least once every 10 years, each diesel fuel tank is drained and cleaned, and the internal surfaces are visually inspected. LRA Section B2.1.16 states that the Fuel Oil Chemistry program is consistent with GALL Report AMP XI.M30. LRA Section B2.1.16, "operating experience" example number five describes a 10-year cleaning and inspection frequency for emergency fuel oil system storage tanks.
3. The response to the RAI stated that peeling and delamination are not permitted and testing will be performed to confirm that the blisters are completely surrounded by sound coating bonded to the surface.
4. The response to the RAI did not address inspection of a component's base material if its coatings are credited for corrosion prevention (e.g., the corrosion allowance in design calculations is zero, the "preventive actions" program element credits the coating) and the base metal has been exposed.
5. The revised LRA Sections A1.10 and A1.23 state that the internal coatings are periodically inspected.
6. LRA Sections B2.1.10 and A1.23 were revised to address activities associated with coating inspections; however:
a. LRA Sections B2.1.10 and B2.1.23 do not state: (a) that a baseline inspection will be conducted in the 10-year period prior to the period of extended operation, (b) the inspection interval for subsequent inspections, (c) the extent of inspections, (d) a summary description of how monitoring and trending of the coatings will be conducted, and (e) a summary description of corrective actions when coating degradation is detected.
b. LRA Section B2.1.23 does not state the qualifications for individuals performing activities associated with coating inspections, and acceptance criteria.
7. The response to the RAI states, "[m]onitoring and trending will include pre-inspection reviews of previous inspection results. Inspection results will be compared to previous inspection results."
8. LRA Tables 3.3.2-4, 3.3.2-5, 3.3.2-7, 3.3.2-11, and 3.3.2-20 state that carbon steel (with coating or lining) components exposed to raw water (internal) are being managed for loss of material by the Open-Cycle Cooling Water System, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, and Fire Water System programs.

ULNRC-06118 May 6, 2014 Page 3 of 11 Issue:

1. The staff has concluded that if no indications are found during inspection of one train, the redundant train would not need to be inspected as long as components within the redundant trains are not subject to turbulent conditions. Turbulent conditions are those where fluid flow is such that the velocity at a given point varies erratically in magnitude and direction and mechanical damage to coatings can occur (e.g., heat exchanger end bells). The staff has also concluded that baseline inspections of the internal coatings on the in-scope heat exchangers, air conditioners, and strainers in all trains conducted in the 10-year period prior to the period of extended operation would demonstrate whether coatings are being degraded due to turbulent conditions.
2. The staff has concluded that coating inspections for diesel fuel oil storage tanks may be conducted at the frequency stated in the Fuel Oil Chemistry program as long as: (a) no peeling, delamination, blisters, or rusting are observed during inspections, and (b) any cracking and flaking has been found acceptable by a coating specialist. If this is not the case, inspections should be conducted more frequently. The staff noted that the Fuel Oil Chemistry program was not revised to include activities associated with coatings inspections (e.g., acceptance criteria, inspector qualifications).
3. The staff has concluded that where the visual inspection of the coated surfaces determines that the coating is deficient or degraded, physical tests, where physically possible are performed in conjunction with the visual inspection. The staff also concluded that physical testing should consist of destructive or nondestructive adhesion testing using ASTM International standards endorsed in RG 1.54 with a minimum of three sample points being conducted adjacent to the defective area. Physical testing is necessary to ensure that the extent of underlying degradation is detected.
4. The staff has concluded that if coatings are credited for corrosion prevention and the component's base material has been exposed or is beneath a blister, the base metal should be examined to determine if minimum wall thickness is met and will be met until the next inspection.
5. The staff has concluded that the UFSAR Supplement should include key aspects of the program associated with coating degradation such as the inspection method; follow-up testing that will be conducted when degradation is determined not to meet acceptance criteria, and the basis for the training and qualification of individuals involved in coating inspections.
6. The staff has concluded that the programs credited for detecting loss of coating integrity should include a summary description of (a) when baseline inspections will be conducted, (b) the inspection interval for subsequent inspections, (c) the extent of inspections, (d) qualifications for individuals performing activities associated with coating inspections, (e) a summary description of how monitoring and trending of the coatings will be conducted, (f) acceptance criteria, and (g) a summary description of corrective actions when coating degradation is detected.

ULNRC-06118 May 6, 2014 Page 4 of 11

7. The staff has concluded that a coatings specialist should prepare a post inspection report to include: a list and location of all areas evidencing deterioration, a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where repair can be postponed to the next refueling outage, and where possible, photographic documentation indexed to inspection locations. The RAI response and associated LRA changes lacks this specificity. The post inspection report should be compiled or approved by a coatings specialist and it should include sufficient information to ensure that degraded areas are appropriately dispositioned through the corrective action program and future inspection locations are selected based on known areas where degradation has occurred.
8. Draft LR-ISG-2013-01, "Aging Management of Loss of Coating Integrity for Internal Service Level III (augmented) Coatings," states that the applicable aging effect for internal coatings is loss of coating integrity. In addition, GALL Report Items CP-152 and TP-301 state that the aging effect for Service Level I coatings is loss of coating integrity. While the GALL Report definition of loss of material incorporates aging mechanisms that are applicable to coatings (e.g., fretting, erosion, wastage, wear), the definition of loss of coating integrity in LR-ISG-2013-01 includes the concepts of consequential damage due to unanticipated or accelerated corrosion and debris generation that are not described in the definition of loss of material.

Request:

1. State the basis for why turbulent conditions sufficient to degrade internal coatings on the in-scope heat exchangers, air conditioners, and strainers described in the RAI response cannot occur. Alternatively, revise the Open Cycle Cooling Water System and Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components programs to include baseline inspections of all trains conducted in the 10-year period prior to the period of extended operation of the internal coatings on the in-scope heat exchangers, air conditioners, and strainers described in the RAI response and revise the proposed frequency of inspections (i.e., redundant trains would be inspected for components susceptible to turbulent flow) based on the results of the inspections.
2. Confirm that the internal surfaces of the internally coated fuel oil storage tanks are inspected every 10 years. State the periodicity of inspections, and basis for the periodicity of inspections if the prior inspection detected peeling, delamination, blisters, rusting, or unacceptable cracking and flaking. State how activities associated with coatings inspections (e.g., acceptance criteria, inspector qualifications) will be managed given that they are not included in the Fuel Oil Chemistry program. Revise LRA Sections A1.16 and B2.1.16 accordingly as described in Issue items 5 and 6 above.
3. State what testing will be performed when peeling, delamination or blisters are detected during inspections and the coating is not repaired or replaced. If the testing does not include destructive or nondestructive adhesion testing, state why the testing will effectively detect the extent of the degraded condition. State how it will be determined that a repair or replacement of a coating is extended to sound coating material.
4. State whether a component's base material will be inspected if its coatings have been credited for corrosion prevention and the base metal has been exposed or is beneath a blister. In addition, state the inspection method and acceptance criteria. If inspections will not be conducted, state the basis for why there is reasonable assurance that the current licensing basis intended function of the component will be met.

ULNRC-06118 May 6, 2014 Page 5 of 11

5. Revise LRA Sections A1.10 and A1.23 to include a summary description of the follow-up testing that will be conducted when degradation is determined not to meet acceptance criteria and the basis for the training and qualification of individuals involved in coating inspections.
6. Revise LRA Sections B2.1.10 and B2.1.23 to include (a) when baseline inspections will be conducted, (b) the inspection interval for subsequent inspections, (c) the extent of inspections, (d) qualifications for individuals performing activities associated with coating inspections, (e) a summary description of how monitoring and trending of the coatings will be conducted, (f) acceptance criteria, and (g) a summary description of corrective actions when coating degradation is detected.
7. State who will prepare and approve post-inspection reports and the key information that will be included in the report.
8. State why the term "loss of material" as an aging effect for coatings as cited in LRA Tables 3.3.2-4, 3.3.2-5, 3.3.2-7, 3.3.2-11, and 3.3.2-20 is sufficient to convey the consequential concepts of unanticipated or accelerated corrosion, and debris generation. Alternatively, revise the aging effect to loss of coating integrity in the cited AMR tables.

Callaway Response

1. With exception of piping, 100% baseline inspections will be conducted in the ten year period prior to the period of extended operation on the accessible internal surfaces coatings of the in-scope components noted below. Piping baseline inspection will include a representative 73 1-foot axial length circumferential segments of piping. The inspection surface includes the entire inside surface of the 1-foot sample. An equivalent 73 1-foot axial length circumferential segments will be used if geometric limitations impede movement of the inspection tools. If loss of coating integrity due to turbulent conditions is observed during the baseline inspections, corrective actions will be initiated and the redundant train would be inspected for susceptibility to turbulent flow. Alternating train inspection frequencies would not apply to internally coated components that are subjected to turbulent flow. The Open Cycle Cooling Water Systems Program and the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, as well as the Fuel Oil Chemistry, programs have been revised as shown in Enclosure 2 to include baseline inspections.

Essential Service Water (ESW)

(B2.1.10 Open Cycle Cooling Water Systems Program)

  • component cooling water heat exchangers,
  • class 1E electrical equipment air conditioners,
  • control room air conditioners (in the Control Building HVAC System), and
  • essential service water self-cleaning strainers Service Water and Circulation Water (B2.1.23 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components)

ULNRC-06118 May 6, 2014 Page 6 of 11 Emergency Diesel Engine Fuel Oil Storage and Transfer System (B2.1.16 Fuel Oil Chemistry)

  • Emergency Diesel Fuel Oil Storage Tanks and Day Tanks Re-inspection of the coatings will be conducted as follows:
  • Coatings are inspected every six years on an alternating train basis based on no observed degradation or cracking and flaking that has been evaluated as acceptable.
  • Coatings with blisters, peeling, delaminations or rusting that has been determined not to require remediation are inspected on a four year frequency.
  • Coatings requiring remediation will be repaired or replaced and inspected every six years on an alternating train basis.
2. The internal surfaces of the internally coated emergency fuel oil storage tanks are inspected every six years based on an alternating train basis with no observable degradation or cracking or flaking that has been evaluated as acceptable. Coatings with blisters, peeling, delaminations or rusting that has been determined not to require remediation are inspected on a six year frequency. A six year frequency is based on operating experience, coating installation in a monitored, non-turbulent environment, and the same coating being installed on each train. There have been no failures at Callaway of the internal coatings in the emergency fuel oil storage tanks that resulted in loss of the intended function. The internal coatings in the emergency fuel oil storage tanks are located in a non-turbulent environment that is monitored and controlled by the Fuel Oil Chemistry program that would detect tank corrosion products or paint debris in the sediment monitoring or particulate analysis.

Because both emergency fuel oil storage tanks use the same coating, alternating train inspections would also provide an indication of coating performance.

The Fuel Oil Chemistry Program in LRA Sections A1.16 and B2.1.16 has been revised as noted in Enclosure 2 to identify the following:

a. When baseline inspections are conducted (B2.1.16 only)
b. Inspection intervals for subsequent inspections (B2.1.16 only)
c. Extent of inspections and inspection method
d. Training and qualifications for individuals performing activities associated with coating inspections
e. Summary description of how monitoring and trending of the coatings will be conducted (B2.1.16 only)
f. Acceptance criteria (B2.1.16 only)
g. Summary description of corrective actions when a coating degradation is detected.
3. For peeling, delaminations and blisters determined to not meet acceptance criteria and that will not be repaired or replaced, physical testing is performed where physically possible (i.e.,

sufficient room to conduct testing). Testing consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Plants. For repaired or replaced coating, a minimum of three sample points adjacent to the defective area are tested to verify sound coating material.

ULNRC-06118 May 6, 2014 Page 7 of 11

4. None of the internally coated components within the scope of license renewal have credited the coatings for corrosion prevention either in a documented corrosion allowance in a design analysis or as a preventative action in an aging management program. If the base metal is exposed due to coating degradation the applicable inspection requirements for management of loss of material in the metallic component will apply. Blisters will be evaluated by a qualified coating specialist to determine extent of coating degradation and exposure of the metallic surface. Based on the potential exposure of the metallic surfaces and their susceptibility to corrosion, corrective actions will be determined by the corrective action program.
5. The Open Cycle Cooling Water Systems program in LRA Section A1.10, and the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components in LRA Section A1.23 have been revised as noted in Enclosure 2 to identify the following:
  • A summary description of the follow-up testing that will be conducted when degradation is determined not to meet acceptance criteria
  • Training and qualifications for individuals performing activities associated with coating inspections
6. The Open Cycle Cooling Water Systems program in LRA Section B2.1.10, and the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components in LRA Section B2.1.23 have been revised as noted in Enclosure 2 to identify the following:
a. When baseline inspections are conducted
b. Inspection intervals for subsequent inspections
c. Extent of inspections and inspection method
d. Training and qualifications for individuals performing activities associated with coating inspections
e. Summary description of how monitoring and trending of the coatings will be conducted
f. Acceptance criteria
g. Summary description of corrective actions when a coating degradation is detected.
7. A coatings specialist prepares and approves the post-inspection report to include: a list and location of all areas evidencing deterioration, a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where repair can be postponed to the next refueling outage, and where possible, photographic documentation indexed to inspection locations.
8. The following LRA Tables have been revised as noted in Enclosure 2 to identify loss of coating integrity for the internal coatings of applicable components.
  • Table 3.3.2-7 Component Cooling Water
  • Table 3.3.2-11 Control Building HVAC
  • Table 3.3.2-20 Fire Protection System
  • Table 3.3.2-21 Emergency Diesel Engine Fuel Oil Storage and Transfer System

ULNRC-06118 May 6, 2014 Page 8 of 11 Loss of coating integrity is only applicable to the service water supply piping that connects to the ESW system supply piping. Loss of coating integrity is not applicable to the service water and circulating water system return piping downstream of in-scope ESW components because the degradation of coatings cannot result in downstream effects such as reduction in flow, drop in pressure, or reduction in heat transfer for in-scope components. The internal coating for the service water and circulating water return line is not credited for corrosion prevention.

Corresponding Amendment Changes Refer to the Enclosure 2 Summary Table "Amendment 34, LRA Changes for a description of LRA changes with this response.

ULNRC-06118 May 6, 2014 Page 9 of 11 RAI 3.3.2-2a, Submerged Bolting (Followup)

Background:

By letter dated December 2, 2013, the staff issued RAI 3.3.2-2, requesting details on the parameters that would be inspected to detect bolting degradation in submerged environments.

The response dated January 16, 2014, described the bolting inspections as follows:

1. Essential Service Water (ESW) Pump Closure Bolting: a representative sample of submerged closure bolting of the ESW pumps will be visually inspected for degradation when they are made accessible during dewatering of the ESW intake bays for structures monitoring inspections. Dewatering of the ESW pump house intake bays is performed on a four refueling outage frequency (six years). The ESW pumps are tested at least quarterly and are repaired or refurbished when necessary, based on trending of pump parameters such as pressure, flow, and vibration.
2. Service Water Pump Closure Bolting: each service water pump is replaced nominally every six years with a refurbished pump. Because the pumps are periodically replaced every six years with a refurbished pump, the pumps and associated bolting are not subject to aging management requirements.
3. Waste Water Pump Closure Bolting: a representative sample of submerged pump closure bolting in the oily waste system and the floor and equipment drainage system will be visually inspected for degradation when they are made accessible during pump maintenance activities. The bolting will be inspected on a four refueling outage frequency (six years) if an opportunistic inspection has not been performed. The waste water sumps are monitored during operator rounds to confirm that the sumps are being drained.

The RAI response deleted pumps from LRA Table 2.3.3-5, "Service Water System." And closure bolting and pumps from LRA Table 3.3.2-5.

Issue:

1. Visual inspections of the ESW and waste water pump closure bolting are capable of detecting loss of material of only the exposed bolt heads. Given that crevices (e.g., threaded regions or the shank below the bolt heads) likely represent locations with the most aggressive environments, the staff considers it important that these areas are evaluated for loss of material on at least an opportunistic basis (e.g. , during repair and replacement activities).
2. The staff does not agree with the proposal that managing the aging effects of the service water pump and its closure bolting is not required. Pump refurbishments frequently result in many passive long-lived parts being reused (e.g., casings, closure bolting).
3. The staff requires greater specificity regarding the frequency of the operator rounds that confirm that the waste water sumps are being drained.

ULNRC-06118 May 6, 2014 Page 10 of 11 Request:

1. For the ESW and waste water pumps' closure bolting, describe how loss of material will be identified in crevice locations that are not readily visible, or describe an alternative method for evaluating degradation of those regions. If opportunistic inspections are proposed, provide historical information regarding how often the pumps have been disassembled in the past such that an inspection of crevice regions could have been conducted.
2. For the service water pumps and associated closure bolting, state whether the in-scope components are replaced every 6 years during refurbishment without using condition monitoring to conclude that replacement was not necessary. If these components are not necessarily replaced, propose appropriate means to manage the applicable aging effects.
3. State the frequency of the operator rounds that confirm that the waste water sumps are being drained.
4. State what procedures or logs have been revised to appropriately capture the basis of these aging management activities (e.g., operator rounds to inspect waste water sumps, work orders that contain steps to conduct a visual inspection of bolt regions that are not readily observable, quarterly pump testing procedure).

Callaway Response

1. Submerged closure bolting of the ESW pumps will be visually inspected for degradation on a four refueling outage frequency (six years) if an opportunistic inspection has not been performed. Opportunistic inspections of the submerged ESW pump closure bolts will be performed when the pumps are disassembled for maintenance activities. There have been no documented maintenance activities that would allow opportunistic inspections on the submerged ESW pump closure bolts since the pumps were replaced with stainless steel pumps in 1999 and 2009. Degradation of waste water pumps is identified through operator rounds, as described in the response to question #3. LRA Appendix A1.8, Table A4-1 item 5, and Appendix B2.1.8 have been revised as shown in Enclosure 2 to clarify the enhancement to the Bolting Integrity program associated with submerged bolting inspections.
2. Each service water pump is replaced nominally every six years with a refurbished pump.

As part of the refurbishment activities, the submerged pump casing closure bolting and the interior pump coating are replaced. Condition monitoring is not used for the replacement of the service water pump coatings or submerged pump casing closure bolting of the refurbished pump. The submerged pump casing is inspected and reworked as necessary to like new condition during the refurbishment activities. The refurbished pump casing will be considered as a long lived, passive component that requires aging management. Since the internal and external environments for this component are the same, the External Surfaces Monitoring of Mechanical Components program (B2.1.21) is credited to manage the aging of the internal surfaces and the external surfaces of the pump casing. LRA Table 2.3.3-5, LRA Table 3.3-1 item 134, and Table 3.3.2-5 have been revised as shown in Enclosure 2 to require aging

ULNRC-06118 May 6, 2014 Page 11 of 11 management of the service water pump casing by the External Surfaces Monitoring of Mechanical Components program (B2.1.21).

3. As required by the Operations Technician General Inspection Guide, inspections are conducted once every twelve hours to confirm waste water sump pumps are operating as required and sump liquid levels, if visible, are within normal range. The Operations Technician General Inspection Guide has been identified as an implementing procedure in the Bolting Integrity program (B2.1.8) basis document.
4. See the response to question #3 for the procedure and logs that identify the basis for waste water sump inspections.

Corresponding Amendment Changes Refer to the Enclosure 2 Summary Table "Amendment 34, LRA Changes for a description of LRA changes with this response for changes made in ULNRC-06117 dated April 23, 2014.

Refer to the Enclosure 2 Summary Table "Amendment 35, LRA Changes for a description of LRA changes with this response.

ULNRC-06118 May 6, 2014 Page 1 of 64 Amendment 35, LRA Changes Enclosure 2 Summary Table Affected LRA Section LRA As-Submitted Page Number(s)

Table 2.4-4 2.4-13 and 2.4-14 Section 2.4.6 and Table 2.4-6 2.4-16 through 2.4-18 Section 3.3.2.1.29 3.3-35 Table 3.3.2-29 3.3-283 Section 3.5.2.1.4 3.5-7 and 3.5-8 Table 3.5.2-4 3.5-87 Table 3.5.2-6 3.5-101 through 3.5-103 Table 4.1-1 Section 6 4.1-5 Section 4.7.3 4.7-7 and 4.7-8 Section 4.8 4.8-2 Section A1.8 A-5 and A-6 Section A1.14 A-8 Section A1.23 A-13 Section A1.25 A-13 and A-14 Section A1.32 A-16 and A-17 Section A3.6.3 A-33 and A-34 Table A4-1, item 5 A-37 Table A4-1, item 10 A-38 and A-39 Table A4-1, item 23 A-43 Table A4-1, item 45 A-49 Table A4-1, item 46 A-49 Section B2.1.8 B-34 through B-37 Section B2.1.14 B-53 through B-56 Section B2.1.23 B-81 through B-83 Section B2.1.25 B-87 through B-90 Section B2.1.31 B-104 through B-107 Section B2.1.32 B-108 and B-109

ULNRC-06118 May 6, 2014 Page 2 of 64 Callaway Plant License Renewal Application Amendment 35 Deleted intended function associated with the submerged concrete component that directs circulating water and was reassigned to the scope of miscellaneous in-scope structures. The submerged concrete component provides a return path to the cooling tower basin for the circulating water. The cooling tower basin is currently evaluated in miscellaneous in-scope structures.

Table 2.4-4 (Pages 2.4-13 and 2.4-14) is revised as follows (deleted text shown in strikethrough):

Table 2.4-4 Turbine Building Component Type Intended Function Bolting (Structural) Structural Support Caulking and Sealant Flood Barrier Shelter, Protection Compressible Joints and Seals Expansion/Separation Shelter, Protection Concrete Block (Masonry Walls) Fire Barrier Flood Barrier Shelter, Protection Structural Support Concrete Elements Flood Barrier Missile Barrier Shelter, Protection Structural Pressure Boundary Structural Support Door Shelter, Protection Fire Barrier Doors Fire Barrier Shelter, Protection Fire Barrier Seals Fire Barrier Hatch Missile Barrier Shelter, Protection Hatches and Plugs Missile Barrier Shelter, Protection Structural Support High Strength Bolting Structural Support Metal Siding Shelter, Protection Penetrations Electrical Shelter, Protection Structural Support

ULNRC-06118 May 6, 2014 Page 3 of 64 Table 2.4-4 Turbine Building (continued)

Component Type Intended Function Penetrations Mechanical Shelter, Protection Structural Support Roofing Membrane Flood Barrier Shelter, Protection Stairs, Platforms and Grates Structural Support Structural Steel Shelter, Protection Structural Support

ULNRC-06118 May 6, 2014 Page 4 of 64 Callaway Plant License Renewal Application Amendment 35 The submerged reinforced concrete component under the turbine building and the reinforced concrete pipe in the circulating water system were added to the scope of miscellaneous in-scope structures. The submerged reinforced concrete component under the turbine building and the reinforced concrete pipe provide a return flowpath for the circulating water system to the cooling tower basin.

Section 2.4.6 (Pages 2.4-16 through 2.4-18) is revised as follows (new text shown underlined) 2.4.6 Miscellaneous In-Scope Structures Structure Description The purpose of the miscellaneous in-scope structures is to support and shelter and protect equipment required for fire protection or station blackout recovery. The miscellaneous in-scope structures include the following structures:

  • fire pumphouse
  • security diesel generator building
  • security building (main access facility)

The fire pumphouse is a single story metal sided enclosure supported by structural steel framing on three sides and a concrete masonry block wall on the west face. The fire pumphouse is supported by reinforced concrete footings on structural backfill. The fire pumphouse has a built-up roof over rigid insulation and metal deck supported by metal roof joists. There are also interior block walls which serve as fire barriers.

The adjacent fire water storage tanks foundations are evaluated in Section 2.4.7, In-Scope Tank Foundations and Structures.

The security diesel generator building is a single story metal sided enclosure with a built-up roof. The security diesel generator building is supported by a reinforced concrete foundation on structural backfill.

The security building (main access facility) is a multistory reinforced concrete structure with furred metal siding. The main access facility intermediate floor framing and reinforced concrete bearing walls are supported by reinforced concrete footings on structural backfill.

The facility has a reinforced concrete roof deck with built-up roofing over rigid insulation.

ULNRC-06118 May 6, 2014 Page 5 of 64 The switchyard control building is a single story concrete masonry block wall building with a built-up roof. The switchyard control building is supported by reinforced concrete footings on structural backfill.

The circulating and service water pumphouse is a multistory reinforced concrete and structural steel framed building. The circulating and service water pumphouse is supported by reinforced concrete footings on structural backfill. The circulating and service water pumphouse has a built-up roof over rigid insulation and metal deck supported by metal roof joists.

The cooling tower basin is a reinforced concrete slab with sidewalls and is founded on reinforced concrete piers and structural backfill. The cooling tower basin provides water for the service water pumps supplying fire water to hose stations located in the essential service water pumphouse. Reinforced concrete structures under the turbine building and in the yard are part of the piping system that provides a return flowpath for the circulating water between the turbine building and the cooling tower basin. The service water system is evaluated in Section 2.3.3.5, Service Water System. The circulating water system is evaluated in Section 2.3.3.29, Circulating Water System.

Structure Intended Function Portions of the miscellaneous in-scope structures provide structural support and shelter and protection for SSCs that are within the scope of license renewal to support fire protection and station blackout requirements based upon criteria of 10 CFR 54.4(a)(3).

Callaway FSAR References Additional details of the Miscellaneous In-Scope Structures are included in FSAR Sections 8.3A.4.a SP, and 9.2.5.3 SA Component-Function Relationship Table The component types subject to aging management review are indicated in Table 2.4 Miscellaneous In-Scope Structures.

Table 2.4-6 Miscellaneous In-Scope Structures Component Type Intended Function Barrier Shelter, Protection Bolting (Structural) Structural Support Caulking and Sealant Flood Barrier Shelter, Protection Concrete Block (Masonry Walls) Fire Barrier Shelter, Protection Structural Support Concrete Elements Shelter, Protection Structural Pressure Boundary Structural Support

ULNRC-06118 May 6, 2014 Page 6 of 64 Table 2.4-6 Miscellaneous In-Scope Structures (continued)

Component Type Intended Function Door Shelter, Protection Metal Siding Shelter, Protection Penetrations Electrical Structural Support Penetrations Mechanical Structural Support Roofing Membrane Flood Barrier Shelter, Protection Structural Steel Shelter, Protection Structural Support The AMR results for these component types are provided in Table 3.5.2-6, Containments, Structures, and Component Supports - Summary of Aging Management Evaluation -

Miscellaneous In-Scope Structures.

ULNRC-06118 May 6, 2014 Page 7 of 64 Callaway Plant License Renewal Application Amendment 35 Deleted applicable materials and aging effects associated with reinforced concrete pipe that was reassigned to the scope of miscellaneous in-scope structures. The reinforced concrete pipe provides a return path to the cooling tower basin for the circulating water and is attached to the cooling tower basin that is currently evaluated in miscellaneous in-scope structures.

Section 3.3.2.1.29 (Page 3.3-35) is revised as follows (deleted text shown in strikethrough):

3.3.2.1.29 Circulating Water System Materials The materials of construction for the circulating water system component types are:

  • Carbon Steel (with coating or lining)
  • Concrete
  • Atmosphere/Weather
  • Buried
  • Plant Indoor Air
  • Changes in Material Properties
  • Cracking
  • Cracking and Changes in Material Properties
  • Cracking, Spalling, Corrosion of Rebar
  • Hardening and Loss of Strength

ULNRC-06118 May 6, 2014 Page 8 of 64

  • Loss of material
  • Bolting Integrity (B2.1.8)
  • Selective Leaching (B2.1.19)
  • External Surfaces Monitoring of Mechanical Components (B2.1.21)
  • Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.23)
  • Buried and Underground Piping and Tanks (B2.1.25)

ULNRC-06118 May 6, 2014 Page 9 of 64 Callaway Plant License Renewal Application Amendment 35 Deleted applicable aging evaluations from Table 3.3.2-29 associated with reinforced concrete pipe that was reassigned to the scope of miscellaneous in-scope structures. The reinforced concrete pipe provides a return path to the cooling tower basin for the circulating water and is attached to the cooling tower basin that is currently evaluated in miscellaneous in-scope structures.

Table 3.3.2-29 (Page 3.3-283) is revised as follows (deleted text shown in strikethrough):

Table 3.3.2-29 Auxiliary Systems - Summary of Aging Management Evaluation - Circulating Water System Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping PB Concrete Atmosphere/ Cracking External Surfaces VII.C1.AP-251 3.3.1.074 A Weather (Ext) Monitoring of Mechanical Components (B2.1.21)

Piping PB Concrete Atmosphere/ Loss of material External Surfaces VII.C1.AP-252 3.3.1.077 A Weather (Ext) Monitoring of Mechanical Components (B2.1.21)

Piping PB Concrete Atmosphere/ Changes in External Surfaces VII.C1.AP-253 3.3.1.073 A Weather (Ext) material Monitoring of properties Mechanical Components (B2.1.21)

Piping PB Concrete Buried (Ext) Cracking and Buried and Underground VII.C1.AP-157 3.3.1.103 A Changes in Piping and Tanks material (B2.1.25) properties Piping PB Concrete Buried (Ext) Cracking, spalling, Buried and Underground VII.C1.AP-178 3.3.1.105 A corrosion of rebar Piping and Tanks (B2.1.25)

ULNRC-06118 May 6, 2014 Page 10 of 64 Table 3.3.2-29 Auxiliary Systems - Summary of Aging Management Evaluation - Circulating Water System (continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Piping PB Concrete Raw Water (Int) Cracking Inspection of Internal VII.C1.AP-248 3.3.1.031 E, 1 Surfaces in Miscellaneous Piping and Ducting Components (B2.1.23)

Piping PB Concrete Raw Water (Int) Loss of material Inspection of Internal VII.C1.AP-249 3.3.1.033 E, 1 Surfaces in Miscellaneous Piping and Ducting Components (B2.1.23)

Piping PB Concrete Raw Water (Int) Changes in Inspection of Internal VII.C1.AP-250 3.3.1.030 E, 1 material Surfaces in properties Miscellaneous Piping and Ducting Components (B2.1.23)

ULNRC-06118 May 6, 2014 Page 11 of 64 Callaway Plant License Renewal Application Amendment 35 Deleted applicable environments and aging management programs associated with the submerged concrete component that directs circulating water and was reassigned to the scope of miscellaneous in-scope structures. The submerged concrete component provides a return path to the cooling tower basin for the circulating water. The cooling tower basin is currently evaluated in miscellaneous in-scope structures.

Section 3.5.2.1.4 (Pages 3.5-7 and 3.5-8) is revised as follows (deleted text shown in strikethrough):

3.5.2.1.4 Turbine Building Materials The materials of construction for the turbine building component types are:

  • Concrete
  • Concrete Block (Masonry Walls)
  • Elastomer
  • High Strength Low Alloy Steel (Bolting)

Environment The turbine building component types are exposed to the following environments:

  • Atmosphere/ Weather (Structural)
  • Buried (Structural)
  • Concrete (Structural)
  • Plant Indoor Air (Structural)
  • Submerged (Structural)

Aging Effects Requiring Management The following turbine building aging effects require management:

  • Cracking
  • Cracking and distortion
  • Cracking; loss of bond; and loss of material (spalling, scaling)

ULNRC-06118 May 6, 2014 Page 12 of 64

  • Increase in porosity and permeability; cracking; loss of material (spalling, scaling)
  • Increase in porosity and permeability; loss of strength
  • Increased hardness; shrinkage; loss of strength
  • Loss of material
  • Loss of material (spalling, scaling) and cracking
  • Loss of preload
  • Fire Protection (B2.1.13)
  • Masonry Walls (B2.1.30)
  • RG 1.127, Inspection of Water-Control Structures Assocaited with Nuclear Power Plants (B2.1.31)
  • Structures Monitoring (B2.1.31)

ULNRC-06118 May 6, 2014 Page 13 of 64 Callaway Plant License Renewal Application Amendment 35 Deleted applicable aging evaluations from Table 3.5.2-4 associated with the submerged concrete component that directs circulating water and was reassigned to the scope of miscellaneous in-scope structures. The submerged concrete component provides a return path to the cooling tower basin for the circulating water. The cooling tower basin is currently evaluated in miscellaneous in-scope structures.

Table 3.5.2-4 (Page 3.5-87) is revised as follows (deleted text shown in strikethrough):

Table 3.5.2-4 Containments, Structures, and Component Supports - Summary of Aging Management Evaluation - Turbine Building Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Program Item Management Concrete SPB, SS Concrete Submerged Loss of material RG 1.127, Inspection III.A6.T-20 3.5.1.056 A Elements (Structural) of Water-Control (Ext) Structures Associated with Nuclear Power Plants (B2.1.32)

Concrete SPB, SS Concrete Submerged Increase in RG 1.127, Inspection III.A6.TP-37 3.5.1.061 A Elements (Structural) porosity and of Water-Control (Ext) permeability; loss Structures of strength Associated with Nuclear Power Plants (B2.1.32)

ULNRC-06118 May 6, 2014 Page 14 of 64 Callaway Plant License Renewal Application Amendment 35 The submerged reinforced concrete component under the turbine building and the reinforced concrete pipe in the circulating water system were added to the scope of miscellaneous in-scope structures and resulted in the following additions to Table 3.5.2-6.

The submerged reinforced concrete component under the turbine building and the reinforced concrete pipe provide a return flowpath for the circulating water system to the cooling tower basin.

Table 3.5.2-6 (Pages 3.5-101 through 3.5-103) is revised as follows (new text underlined shown underlined):

Table 3.5.2-6 Containments, Structures, and Component Supports - Summary of Aging Management Evaluation -

Miscellaneous In-Scope Structures Component Type Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Function Requiring Program Item Management Concrete Elements SH, SPB, Concrete Atmosphere/ Loss of material Structures Monitoring III.A3.TP-23 3.5.1.064 A SS Weather (Structural) (spalling, scaling) (B2.1.31)

(Ext) and cracking Concrete Elements SH, SPB, Concrete Atmosphere/ Increase in Structures Monitoring III.A3.TP-24 3.5.1.063 A SS Weather (Structural) porosity and (B2.1.31)

(Ext) permeability; loss of strength Concrete Elements SH, SPB, Concrete Atmosphere/ Cracking Structures Monitoring III.A3.TP-25 3.5.1.054 A SS Weather (Structural) (B2.1.31)

(Ext)

Concrete Elements SH, SPB, Concrete Atmosphere/ Cracking; loss of Structures Monitoring III.A3.TP-26 3.5.1.066 A SS Weather (Structural) bond; and loss of (B2.1.31)

(Ext) material (spalling, scaling)

Concrete Elements SH, SPB, Concrete Atmosphere/ Increase in Structures Monitoring III.A3.TP-28 3.5.1.067 A SS Weather (Structural) porosity and (B2.1.31)

(Ext) permeability; cracking; loss of material (spalling, scaling)

ULNRC-06118 May 6, 2014 Page 15 of 64 Table 3.5.2-6 Containments, Structures, and Component Supports - Summary of Aging Management Evaluation -

Miscellaneous In-Scope Structures (continued)

Component Type Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Function Requiring Program Item Management Concrete Elements SH, SPB, Concrete Buried Increase in porosity Structures Monitoring III.A3.TP-29 3.5.1.067 A SS (Structural) (Ext) and permeability; (B2.1.31) cracking; loss of material (spalling, scaling)

Concrete Elements SH, SPB, Concrete Buried Cracking and Structures Monitoring III.A3.TP-30 3.5.1.044 A SS (Structural) (Ext) distortion (B2.1.31)

Concrete Elements SH, SPB, Concrete Buried Cracking; loss of Structures Monitoring III.A3.TP-212 3.5.1.065 A SS (Structural) (Ext) bond; and loss of (B2.1.31) material (spalling, scaling)

Concrete Elements SH, SPB, Concrete Submerged Increase in porosity Structures Monitoring III.A3.TP-24 3.5.1.063 A SS (Structural) (Ext) and permeability; (B2.1.31) loss of strength Concrete Elements SH, SPB, Concrete Submerged Cracking Structures Monitoring III.A3.TP-25 3.5.1.054 A SS (Structural) (Ext) (B2.1.31)

Concrete Elements SH, SPB, Concrete Submerged Loss of material Structures Monitoring III.A6.T-20 3.5.1.056 E, 3 SS (Structural) (Ext) (B2.1.31)

Notes for Table 3.5.2-6:

Standard Notes:

A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

C Component is different, but consistent with NUREG-1801 item for material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.

E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.

Plant Specific Notes:

1 NUREG-1801 does not provide a line in which concrete masonry is inspected per the Fire Protection program (B2.1.13).

2 NUREG-1801, Chapter III.A3 does not provide a line to evaluate carbon structural steel in a submerged environment.

3. Component is not associated with emergency cooling water systems or flood protection, so the Structures Monitoring program (B2.1.31) is used instead of the RG 1.127, Inspection of Water-Control Structures Associated With Nuclear Power Plants program (B2.1.32).

ULNRC-06118 May 6, 2014 Page 16 of 64 Callaway Plant License Renewal Application Amendment 35 The Table 4.1-1 Section 6 disposition for the corrosion analysis of the reactor vessel cladding indications was revised from validation (i) to aging management (iii) to be consistent with disposition described in LRA Section 4.7.3.

Table 4.1-1 Section 6 (Page 4.1-5) is revised as follows (new text shown underlined and deleted text shown in strikethrough):

Table 4.1-1 List of TLAAs

6. Other Plant-Specific Time-Limited Aging Analyses N/A 4.7 Containment Polar Crane, Fuel Building Cask Handling Crane, Spent Fuel Pool Bridge Crane, and i 4.7.1 Refueling Machine CMAA 70 Load Cycle Limits In-service Flaw Analyses that Demonstrate Structural i 4.7.2 Integrity for 40 years Corrosion Analysis of the Reactor Vessel Cladding i iii 4.7.3 Indications Reactor Vessel Underclad Cracking Analyses i 4.7.4 Reactor Coolant Pump Flywheel Fatigue Crack Growth i 4.7.5 Analysis High Energy Line Break Postulation Based on Fatigue iii 4.7.6 Cumulative Usage Factors Fatigue Crack Growth Assessment in Support of a Fracture Mechanics Analysis for the Leak-Before-i 4.7.7 Break (LBB) Elimination of Dynamic Effects of Piping Failures Replacement Class 3 Buried Piping i 4.7.8 Replacement Steam Generator Tube Wear iii 4.7.9 Mechanical Environmental Qualification iii 4.7.10

ULNRC-06118 May 6, 2014 Page 17 of 64 Callaway Plant License Renewal Application Amendment 35 A recent revision of calculation BB-183 removed the use of the ASME Section III calculations referring to allowable unreinforced holes and tentative thickness. The revised calculation compares the projected corrosion of the as-found thickness to the reactor pressure vessel minimum design thickness.

Section 4.7.3 (Pages 4.7-7 and 4.7-8) is revised as follows (new text shown underlined and deleted text shown in strikethrough):

4.7.3 Corrosion Analysis of the Reactor Vessel Cladding Indications FSAR Section 5.2.3.2.2 SP identifies two areas where the reactor pressure vessel low-alloy steel has been left exposed to the reactor coolant. The first area is 1.5 in. x 0.75 in. and is located between penetrations #54 and 58 and approximately 6 inches above the penetrations. The second area is 0.53 in. x 0.3 in. and is located approximately 4 in. above penetration #51. The existence of these areas has been evaluated as acceptable.

The first area was identified during Refuel 13 (Spring 2004) while performing bottom mounted instrumentation inspections inside the reactor pressure vessel, when a small rust colored mark was identified on the lower reactor vessel wall. The rust stain is indicative of exposed low-alloy steel. These findings support the characterization of this indication as an area where the cladding is missing. This indication was determined to be acceptable with IWB-3510.1(d) which states that indications entirely within the cladding are acceptable that indicates cladding damage is not detrimental, and calculation BB-183 that showed any metal loss due to corrosion would be minimal.

The second area was identified during Refuel 15 (Spring 2007). The flaw was characterized as the same type of flaw identified during Refuel 13 and the analysis, calculation BB-183 (Reference 11), was updated to include both flaws within the scope of its structural integrity evaluation.

The evaluation demonstrated that the ASME Code criteria will continue to be met relative to the corrosion exposure vessel minimum wall thickness. The corrosion evaluation projected future corrosion losses on the as-found condition of the reactor vessel and concluded that adequate margin above design minimum wall thickness will continue to exist over the life of the plant compared the exposed area of the reactor pressure vessel low-alloy steel, 1.5 in. x 0.625 in. and 0.53 in. x 0.3 in., to the NB-3332.1 acceptance criteria for openings not requiring reinforcement, 4.356 in. diameter. This limit would Design minimum wall thickness will not be approached even when considering the metal would experience 0.119 in. of corrosion. The evaluation considered a plant life of 40 years, which includes 20 years under the current license plus 20 years for plant life extension. The amount of corrosion was calculated assuming a corrosion rate of 0.001 in/yr for normal operating conditions; an outage corrosion rate of 0.015 in./yr with the average outage duration of less than 8 weeks every 18 months; and a 2-week startup period after each outage with a corrosion rate of 0.010 in./yr. The corrosion rates are from EPRI Technical Report, Boric Acid Corrosion Guidebook, Revision 1.

ULNRC-06118 May 6, 2014 Page 18 of 64 If an outage corrosion rate was assumed for the entire 40 years, the metal would experience 0.6 in. of corrosion and the diameter of the damaged area would still be is much less than the allowable diameter.

The vessel minimum wall thickness evaluation demonstrated that the wall thickness, 5.38 in.,

minus the maximum degraded area depth, 0.28 in., meets the criterion of NB-3324.2, 4.329 in. It is assumed that the vessel wall thickness of 5.38 in. includes the nominal cladding thickness of 0.22 in. The ultrasonic testing indicated a maximum defect depth of 0.14 in. from the inner surface, but the evaluation assumes that the low-allow base metal depth is reduced by an additional 0.14 in. The 0.28 in. defect depth bounds the measured indications plus the calculated maximum 40 year corrosion loss of 0.119 in. Even if the outage corrosion rate was assumed for 40 years, the resulting wall loss would be only 0.6 in.

A 0.6 in. wall loss added to the larger assumed defect depth of 0.28 inches would still leave the reactor wall thickness at 4.5 inches (5.38 inches - 0.28 inches - 0.6 inches = 4.5 inches).

This still satisfies the minimum wall thickness requirement based on the criterion of NB-3324.2 of 4.329 in.

The minimum required thickness of the reactor vessel, without cladding, in the area of the indications is 5.38 inches. The minimum measured thickness of the reactor vessel, including cladding, in the area of the cladding indications is 6.08 inches. The maximum average cladding thickness in the area of the cladding indications is 0.23 inches. The maximum depth of the cladding indications is 0.15 inches. The projected corrosion loss over 40 years is 0.119 inches. Subtracting from the minimum measured thickness of the reactor vessel wall the thickness of the cladding, the depth of the indication, and the projected corrosion loss over 40 years, leaves a wall thickness of 5.58 inches (6.08 inches - 0.23 inches - 0.15 inches - 0.119 inches = 5.58 inches) which is greater than the minimum required thickness of 5.38 inches.

Visual inspections of the flaws are performed when the opportunity permits, but the inspection frequency and characterization of the indications will not change as the evaluation determined that frequent inspections of the damaged area would not be required. Profiles of the flaws, or vessel thickness readings in the area of the flaws, will continue to be performed concurrent with the ASME Section XI Category B-N-3 examinations. Previous inspection results are compared to the current results and reconciled to be consistent with the corrosion analysis that includes the period of extended operation. ASME Section XI Category B-N-3 examinations are performed on a 10 year frequency by the ASME Section XI Inservice Inspection, Subsection IWB, IWC, and IWD program summarized in Appendix B2.1.1 (ISI program). Periodic inspection of the reactor vessel indications and reconciliation of the results with the corrosion analysis ensures the analytical bases of the analysis are maintained; therefore, the TLAA is dispositioned in accordance with 10 CFR 54.21(c)(1)(iii).

The corrosion analysis includes the period of extended operation. Therefore the TLAA is dispositioned in accordance with 10 CFR 54.21(c)(1)(i).

ULNRC-06118 May 6, 2014 Page 19 of 64 Callaway Plant License Renewal Application Amendment 35 TLAA reference number 11 is updated to reflect the recent revision of calculation BB-183 described in LRA Section 4.7.3.

Section 4.8 (Page 4.8-2) is revised as follows (new text shown underlined and deleted text shown in strikethrough):

4.8 REFERENCES

11 Ameren Missouri Calculation BB-183. Evaluation of Reactor Vessel Cladding Indication Inside Bottom Head During Refuel 13. Rev. 1 Rev .2.

ULNRC-06118 May 6, 2014 Page 20 of 64 Appendix A Final Safety Analysis Report Supplement A1.8 BOLTING INTEGRITY The Bolting Integrity program manages cracking, loss of material and loss of preload for pressure retaining bolting. The program includes periodic inspection of closure bolting for pressure-retaining components consistent with recommendations as delineated in NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants and EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants, Volume 1 and 2 with the exceptions noted in NUREG-1339. The Bolting Integrity program also includes activities for preload control, material selection and control, and use of lubricants/sealants as delineated in EPRI TR-104213, Bolted Joint Maintenance and Application Guide.

The ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD program supplements the Bolting Integrity program by providing the requirements for inservice inspection of ASME Class 1, 2, and 3 safety-related pressure retaining bolting. The integrity of non-ASME Class 1, 2, 3 system and component bolted joints is evaluated by detection of visible leakage during maintenance or routine observation such as system walkdowns.

A sample of submerged bolting heads in raw water and waste water environments is visually inspected every four refueling outages (six years) when the pumps are dewatered or opportunistically inspect the bolting threads when the pumps are disassembled during maintenance activities. A sample of submerged bolting on the fuel oil storage tank transfer pumps is visually inspected every 10 years when the pumps are disassembled during maintenance activities. The sample for submerged bolting will be 20% of the population with a maximum of 25 for each environment. The inspection of submerged bolting focuses on the bounding or lead components most susceptible to aging due to time in service and severity of operating conditions.

Safety-related and nonsafety-related structural bolting is managed by the following programs:

(a) ASME Section XI, Subsection IWE program (A1.26) provides the requirements for inspection of structural bolting.

(b) ASME Section XI, Subsection IWF program (A1.28) provides the requirements for inservice inspection of safety-related component support bolting.

(c) Structures Monitoring program (A1.31) monitors the condition of structures and structural supports that are within the scope of license renewal.

(d) RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program (A1.32) provides the requirements for inspection of water control structures associated with emergency cooling water systems.

Callaway Plant Unit 1 Page A-5 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 21 of 64 Appendix A Final Safety Analysis Report Supplement (e) Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems program (A1.12) provides the requirements for inspection of handling systems within the scope of license renewal.

Reactor pressure vessel head closure studs are managed by the Reactor Head Closure Stud Bolting program (A1.3).

Inspection activities for bolting in buried and underground applications is performed in conjunction with inspection activities for the Buried and Underground Piping and Tanks (A1.25) program due to the restricted accessibility to these locations.

Callaway Plant Unit 1 Page A-6 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 22 of 64 Appendix A Final Safety Analysis Report Supplement A1.14 FIRE WATER SYSTEM The Fire Water System program manages loss of material and flow blockage for water-based fire protection systems. This program manages aging effects through the use of flow testing and visual inspections performed consistent with provisions of the 2011 Edition of National Fire Protection Association (NFPA) 25 noted in Table A1.14-1. Unless noted in Table A1.14-1, flow testing and visual inspections are performed at intervals specified in the 2011 Edition of NFPA 25. Testing or replacement of sprinklers that have been in place for 50 years is performed in accordance with the 2011 Edition of NFPA 25.

In addition to NFPA codes and standards, portions of the water-based fire protection system that are: (a) normally dry but periodically subjected to flow (e.g., dry-pipe or preaction sprinkler system components) and (b) cannot be drained or allow water to collect are to be subjected to augmented testing beyond that specified in NFPA 25, including (a) periodic full flow tests at the design pressure and flow rate or internal visual inspections and (b) volumetric wall-thickness examinations.

The water-based fire protection system is normally maintained at required operating pressure and is monitored such that loss of system pressure is immediately detected and corrective actions initiated.

Non-intrusive wall thickness examinations are performed on fire water piping to identify loss of material. Wall thickness examinations will be performed on fire water piping every three years. Each three year sample will include at least three locations for a total of 100 feet of above-ground fire water piping and be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. The basis for the frequency is that three years is the frequency required by the FSAR for the yard fire loop flush and for the flow tests of the fire water loops.

Internal visual internal inspections are used when the internal surface of the piping is exposed during plant maintenance Samples are collected for microbiologically-influenced corrosion quarterly and when fire water piping and components are opened for maintenance or are accessible. Biofouling is prevented by periodically adding treatment chemicals such as an anti-scalant, a biopenetrant, and a biostat to the fire water system annually and when monitoring indicates they should be added. The MIC Index is trended to evaluate treatment effectiveness in specific locations.

Inspections of wetted normally dry piping segments that cannot be drained or that allow water to collect begin five years before the period of extended operation. The program's remaining inspections begin during the period of extended operation.

Callaway Plant Unit 1 Page A-8 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 23 of 64 Appendix A Final Safety Analysis Report Supplement Table A1.14-1 Fire Water System Aging Management NFPA 25 Component Aging Management Performed Section Sprinkler 5.2.1.1 Sprinklers are inspected for signs of leakage, corrosion, Systems: and foreign material.

Sprinkler inspections Sprinkler 5.3.1 Prior to 50 years in service, the Fire Water System Systems: program requires sprinkler heads to be replaced or have Sprinkler testing representative samples submitted for field-service testing by a recognized testing laboratory in accordance with NFPA 25. The program field-service tests additional representative samples every 10 years thereafter during the period of extended operation to ensure signs of aging are detected in a timely manner.

Standpipe and 6.3.1 Flow testing is conducted at least every five years at the Hose Systems: hydraulically most remote hose connections of each Flow Tests zone of an automatic standpipe system to verify the water supply provides the design pressure at the required flow.

Private Fire 7.3.1 Underground and exposed piping is flow tested at flows Service Mains: representative of those during a fire to determine the Underground internal condition of the piping at minimum 3-year and Exposed intervals.

Piping Private Fire 7.3.2 Hydrants are flow tested annually to ensure proper Service Mains: functioning.

Hydrants Fire Pumps: 8.3.3.7 Not applicable. Callaway's fire protection pumps do not Suction Screens have suction screens.

Water Storage 9.2.5.5 The exterior painted surface of the fire water storage Tanks: Exterior tanks (FWSTs) is inspected annually for signs of Inspections degradation.

Water Storage 9.2.6, The interior of each FWST is inspected every other Tanks: Interior 9.2.7 refueling cycle for signs of aging. Testing of interior inspections surfaces is performed for coating integrity and tank bottom integrity when FWSTs exhibit signs of interior pitting, corrosion, or coating failure.

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ULNRC-06118 May 6, 2014 Page 24 of 64 Appendix A Final Safety Analysis Report Supplement NFPA 25 Component Aging Management Performed Section Valves and 13.2.5 Main drain tests are performed on a representative System-Wide sample of 20% of the main drains within the scope of Testing: Main License Renewal annually in order to check for potential Drain Test flow blockage in system risers. During annual testing, one of the tests is performed in a radiologically controlled area.

Valves and 13.4.3.2.2 A full flow test using air or water is performed every System-Wide to refueling outage by trip testing each deluge valve to Testing: Deluge 13.4.3.2.5 verify that spray/sprinkler nozzles are unobstructed.

Valves Water Spray 10.2.1.6, Spray system strainers are inspected and cleaned every Fixed Systems: 10.2.1.7, refueling outage and after each system actuation.

Strainers 10.2.7 Callaway does not have main line strainers.

Water Spray 10.3.4.3 A full flow test is performed every refueling cycle using Fixed Systems: air or water to verify that spray/sprinkler nozzles are Operation Test unobstructed.

Foam Water 11.2.7.1 Not applicable. Callaway does not have a foam water Sprinkler sprinkler system.

Systems:

Strainers Foam Water 11.3.2.6 Not applicable. Callaway does not have a foam water Sprinkler sprinkler system.

Systems:

Operational Test Discharge Patterns Foam Water Visual Not applicable. Callaway does not have a foam water Sprinkler inspection sprinkler system.

Systems: for Storage tanks internal corrosion Callaway Plant Unit 1 Page A-10 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 25 of 64 Appendix A Final Safety Analysis Report Supplement NFPA 25 Component Aging Management Performed Section Obstruction 14.2 and Wet pipe suppression systems are inspected every five Investigation: 14.3 years. For buildings containing multiple systems, half Obstruction, are inspected in the first 5 year interval, and the Internal remaining half inspected in the next 5 year interval. If Inspection of sufficient foreign material is found in any system in a Piping building, then all systems in the building will be inspected. Dry pipe preaction systems will be inspected following actuation, prior to return to service.

If sufficient foreign material is found to obstruct pipe or sprinklers, then an obstruction investigation is conducted. If the visual inspection detects surface irregularities that could indicate wall loss below nominal pipe wall thickness, then follow-up volumetric examinations will be performed.

Callaway Plant Unit 1 Page A-11 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 26 of 64 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 also manages loss of coating integrity on components with an internal coating. 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.

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.

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.

Visual inspections are performed on all accessible internal surface coatings of the service water self-cleaning strainers and a representative 73 1-foot axial length circumferential segments of service water piping from the circulating and service water pumphouse to the ESW system connection. For coated surfaces determined to not meet the acceptance criteria and that will not be repaired or replaced, physical testing is performed where physically possible (i.e., sufficient room to conduct testing). The test consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Plants. The training and Callaway Plant Unit 1 Page A-13 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 27 of 64 Appendix A Final Safety Analysis Report Supplement qualification of individuals involved in coating inspections are conducted in accordance with ASTM International Standards endorsed in RG 1.54 including guidance from the staff associated with a particular standard.

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.

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ULNRC-06118 May 6, 2014 Page 28 of 64 Appendix A Final Safety Analysis Report Supplement A1.25 BURIED AND UNDERGROUND PIPING AND TANKS The Buried and Underground Piping and Tanks program manages loss of material, cracking, blistering, and change of color of the external surfaces of buried and underground piping and tanks. The program augments other programs that manage the aging of internal surfaces of buried and underground piping and tanks. The materials managed by this program include steel, stainless steel, concrete, and high-density polyethylene. The program manages aging through preventive, mitigative, and inspection activities.

Preventive and mitigative actions include selection of component materials, external coatings for corrosion control, backfill quality control and the application of cathodic protection. The cathodic protection system is operated consistent with the guidance of NACE SP 0169-2007 for piping, and NACE RP 0285-2002 for tanks. Trending of the cathodic protection system is performed to identify changes in the effectiveness of the system and to ensure that the rectifiers are available to protect buried components. An annual cathodic protection survey is performed consistent with NACE SP 0169-2007.

Soil samples will be conducted during the 10-year period prior to the period of extended operation and in each subsequent 10-year period during the period of extended operation.

Soil samples will be performed in the vicinity of buried steel piping in which the cathodic protection system does not meet the following availability or effectiveness requirements:

  • Cathodic protection has been operational (available) at least 85 percent of the time since either 10 years prior to the period of extended operation or since installation/refurbishment, whichever is shorter; or
  • Cathodic protection has provided effective protection for buried piping as evidenced by meeting the acceptance criteria of -850 mV relative to a copper/copper sulfate electrode, instant off, at least 80 percent of the time since either 10 years prior to the period of extended operation or since installation/refurbishment, whichever is shorter.

Inspection activities include non-destructive evaluation of pipe or tank wall thickness, and visual inspection of the exterior, as permitted by opportunistic or directed excavations.

The Buried and Underground Piping and Tanks program is a new program that will be implemented within the 10-year period prior to entering the period of extended operation.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

Callaway Plant Unit 1 Page A-13 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 29 of 64 Appendix A Final Safety Analysis Report Supplement A1.32 RG 1.127, INSPECTION OF WATER-CONTROL STRUCTURES ASSOCIATED WITH NUCLEAR POWER PLANTS The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program, which is implemented as part of the Structures Monitoring program (SMP),

manages the following aging effects:

  • Cracking; loss of bond; and loss of material (spalling, scaling)
  • Increase in porosity and permeability; loss of strength
  • Loss of material
  • Loss of material (spalling, scaling) and cracking
  • Loss of material; loss of form The scope of this program also includes structural steel and structural bolting associated with water-control structures. SNUPPS-Callaway positions are compliant with that of the Regulatory Guide 1.127 with respect to the ultimate heat sink (UHS) retention pond. The Structures Monitoring program (A1.31) includes all water-control structures within the scope of Regulatory Guide 1.127. The UHS retention pond, the essential service water pumphouse, the ESW supply lines yard vault, the UHS cooling tower and associated submerged discharge structures, and the concrete structures in the turbine building that provide a flowpath for the circulating water system are the water-control structures within the scope for license renewal that are monitored by this program. The UHS retention pond and its associated structures receive periodic in-service inspections for assessment of their structural safety and operational adequacy every five years. Callaway performs algae treatment and riprap inspections along the UHS retention pond to ensure smooth operation of the essential service water pumps. Callaway maintains benchmarks for monitoring settlement in any of the Category 1 structures including the UHS cooling tower. The inspections of all structural components, including masonry walls and water-control structures, are performed at intervals no more than 5 years.

Callaway Plant Unit 1 Page A-16 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 30 of 64 Appendix A Final Safety Analysis Report Supplement A3.6.3 Corrosion Analysis of the Reactor Vessel Cladding Indications Two areas where identified during Refuel 13 (Spring 2004) and Refuel 15 (Spring 2007) where the reactor pressure vessel low-alloy steel has been left exposed to the reactor coolant. The evaluation demonstrated that the ASME Code criteria will continue to be met relative to the corrosion exposure area (NB-3332.1) and reactor vessel design minimum wall thickness (NB 3324.2) will be maintained after corrosion is considered. The evaluation considered a plant life of 40 years, which includes 20 years under the current license plus 20 years for the period of extended operation. The corrosion analysis includes the period of extended operation. Therefore the TLAA is dispositioned in accordance with 10 CFR 54.21(c)(1)(i). Periodic inspection of the reactor vessel indications and reconciliation of the results with the corrosion analysis ensures the analytical bases of the analysis are maintained; therefore, the TLAA is dispositioned in accordance with 10 CFR 54.21(c)(1)(iii).

Callaway Plant Unit 1 Page A-33 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 31 of 64 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule 5 Enhance the Bolting Integrity program procedures to: B2.1.8 Completed no later

  • include bolting in the list of items to be inspected during walkdowns. (Completed LRA Inspections and Amendment 15) testing to be
  • include a visual inspection of a sample of submerged bolting heads in raw water and completed no later waste water environments every four refueling outages (six years) when the pumps are than six months prior dewatered or opportunistically inspect the bolting threads when the pumps are to PEO or the end of disassembled during maintenance activities. A sample of submerged bolting on the fuel the last refueling oil storage tank transfer pumps will be visually inspected every 10 years when the outage prior to the pumps are disassembled during maintenance activities. The sample for submerged PEO, whichever bolting will be 20% of the population with a maximum of 25 for each environment. The occurs later.

inspection of submerged bolting will focus on the bounding or lead components most susceptible to aging due to time in service and severity of operating conditions.

Callaway Plant Unit 1 Page A-37 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 32 of 64 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule 10 Recoat the internal surface of fire water storage tanks. B2.1.8 Implementation is started five years Enhance the Fire Water System program procedures to: before the period of

  • Internal inspections will be performed on accessible exposed portions of fire water extended operation.

piping during plant maintenance activities. When visual inspections are used to detect Recoat the internal loss of material, the inspection technique is capable of detecting surface irregularities surface of the fire that could indicate wall loss to below nominal pipe wall thickness due to corrosion and water storage tanks, corrosion product deposition. Where such irregularities are detected, follow-up and, inspections of volumetric wall thickness examinations are performed. wetted segments that

  • replace sprinkler heads prior to 50 years in service or have a recognized testing cannot be drained or laboratory field-service test a representative sample in accordance with NFPA 25 and that allow water to test additional samples every 10 years thereafter to ensure signs of aging are detected collect to be in a timely manner. completed no later
  • review and evaluate trends in flow parameters recorded during the NFPA 25 fire water than six months prior flow tests. to PEO or the end of
  • perform annual hydrant flow testing in accordance with NFPA 25. the last refueling
  • perform annual hydrostatic testing of fire brigade hose. outage prior to the
  • The Fire Water System program will be enhanced to include non-intrusive pipe wall PEO whichever thickness examinations. Wall thickness measurements will be performed on fire water occurs later.

piping every three years. Each three year sample will include at least three locations The programs for a total of 100 feet of above-ground fire water piping, and will be selected based on remaining inspections system susceptibility to corrosion or fouling and evidence of performance degradation begin during the during system flow testing or periodic flushes. Pipe wall thickness examinations and period of extended internal inspections will be performed commencing after 2014 and throughout the operation.

period of extended operation.

Callaway Plant Unit 1 Page A-38 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 33 of 64 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule

 Perform augmented tests and inspections of water-based fire protection system components that have been wetted but are normally dry. The augmented tests and inspections are conducted as follows on piping segments that cannot be drained or that allow water to collect:

  • In each five-year interval, beginning five years prior to the period of extended operation, either conduct a flow test or flush sufficient to detect potential flow blockage, or conduct a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or allow water to collect.
  • A 100% baseline inspection will be performed prior to the period of extended operation. In each five-year interval of the period of extended operation, 20 percent of the length of piping segments that cannot be drained or that allow water to collect is subject to volumetric wall thickness inspections.

Measurement points will be obtained to the extent that each potential degraded condition can be identified (e.g., general corrosion, MIC). The 20 percent of piping that is inspected in each five-year interval will be in different locations than previously inspected piping.

If the results of a 100 percent internal visual inspection are acceptable, and the segment is not subsequently wetted, no further augmented tests or inspections will be performed.

 require the inspection of the interior of the fire water storage tanks to include checking for evidence of voids beneath the floor.

 change the frequency of trip testing each deluge valve from every three years to every refueling outage.

 change the frequency of tests of spray/sprinkler nozzle discharge patterns from every three years to every refueling outage.

Callaway Plant Unit 1 Page A-39 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 34 of 64 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule

 perform the following additional inspections if pitting, corrosion, or coating failure is found during the inspection of the fire water storage tanks: (1) tank coatings are evaluated using an adhesion test consistent with ASTM D 3359, Standard Test Methods for Measuring Adhesion by Tape Test; (2) dry film thickness measurements are taken at random locations to determine the overall coating thickness; (3) nondestructive ultrasonic readings are taken to evaluate the wall thickness where there is evidence of pitting or corrosion; (4) interior surfaces are spot wet-sponge tested to detect pinholes, cracks, or other compromises in the coating; (5) tank bottoms are tested for metal loss on the underside by use of ultrasonic testing where there is evidence of pitting or corrosion; (6) bottom seams are vacuum-box tested in accordance with NFPA 22, Standard for Water Tanks for Private Fire Protection.

 Require the removal of foreign material if its presence is found during pipe inspections to obstruct pipe or sprinklers. In addition, the source of the material is determined and corrected.

 Perform main drain tests consistent with NFPA 25, Section 13.2.5 of a representative sample of 20% of the main drains within the scope of License Renewal annually in order to check for potential flow blockage in system risers. During annual testing, one of the tests is performed in a radiologically controlled area.

 Inspect wet pipe suppression systems every five years consistent with NFPA 25, Section 14.2. For buildings containing multiple systems, half are inspected in the first 5 year interval, and the remaining half inspected in the next 5 year interval. If sufficient foreign material is found in any system in a building, then all systems in the building will be inspected. The NFPA 25, Section 14.2 inspection of dry pipe preaction systems will be performed following actuation, prior to return to service. If sufficient foreign material is found to obstruct pipe or sprinklers, then an obstruction investigation is conducted per NFPA 25 Annex D. If the visual inspection detects surface irregularities that could indicate wall loss below nominal pipe wall thickness, then follow-up volumetric examinations will be performed.

Callaway Plant Unit 1 Page A-40 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 35 of 64 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule

  • Revise the implementation procedure and calculation for changing test and inspection frequencies associated with the NFPA 805 license amendment (Amendment 206) to note the following restrictions when changing license renewal Fire Water System program and Fire Protection program test and inspection frequencies.
  • EPRI Report 1006756, Fire Protection Equipment Surveillance Optimization and Maintenance Guide will be used to adjust test and inspection frequencies.
  • Data to be used in analyzing the potential for modifying test and inspection frequencies would not be obtained any earlier than 5 years prior to the period of extended operation.
  • A Minimum sample size consistent with EPRI Report 1006756 Section 11.2 will be used to modify test and inspection frequencies.
  • EPRI Report 1006756 would not be used to modify: fire water storage tank inspections/tests, underground flow tests, and inspections of normally dry but periodically wetted piping that will not drain due to its configuration.

Callaway Plant Unit 1 Page A-41 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 36 of 64 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule 23 Enhance the Structures Monitoring program procedures to: B2.1.31 Completed no later

  • include the main access facility, the nitrogen storage tank foundation and pipe trench, than six months prior and the reinforced concrete structures under the turbine building and in the yard that to the PEO with the provide a return flowpath for the circulating water system into the scope of the exception of item Structures Monitoring program. indicated by *, which
  • specify that whenever replacement of bolting is required, bolting material, installation will be completed by torque or tension, and use of lubricants and sealants are in accordance with the December 31, 2017, guidelines of EPRI NP-5769, EPRI NP-5067, EPRI TR-104213, and the additional and item indicated by recommendations of NUREG-1339. #, for which initial
  • specify the preventive actions for storage, lubricants, and stress corrosion cracking inspections were potential discussed in Section 2 of Research Council for Structural Connections completed by publication Specification for Structural Joints Using ASTM A325 or A490 Bolts for ASTM December 31, 2012, A325, ASTM F1852, and/or ASTM A490 structural bolts. and any corrective
  • specify inspections of penetrations, transmission towers, electrical conduits, raceways, actions resulting from cable trays, electrical cabinets/enclosures, and associated anchorages, and complete a initial inspections will baseline inspection of these components*. be completed no later
  • specify that groundwater is monitored for pH, chlorides and sulfates, and every five than December 31, years at least two samples are tested and the results are evaluated by engineering to 2017. Inspections assess the impact, if any, on below grade structures. and testing to be
  • specify inspector qualifications in accordance with ACI 349.3R-96. completed no later
  • quantify acceptance criteria and critical parameters for monitoring degradation, and to than six months prior provide guidance for identifying unacceptable conditions requiring further technical to PEO or the end of evaluation or corrective action in accordance with the three tier quantitative evaluation the last refueling criteria recommended in ACI 349.3R. outage prior to the PEO, whichever
  • incorporate applicable industry codes, standards and guidelines for acceptance criteria.

occurs later.

  • specify that degradation associated with seismic isolation gaps, obstructions of these gaps, or questionable material in these gaps, will be evaluated by an engineer familiar with the seismic design of the plant, and the evaluation will consider the seismic isolation function in determining what corrective actions may be required. #

Callaway Plant Unit 1 Page A-43 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 37 of 64 Appendix A Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule 45 Enhance the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power B2.1.32 Completed no later Plants program procedures to: than six months prior

  • include the concrete structures in the turbine building that provide a flowpath for the to the PEO.

circulating water system in the scope of the program. Inspections to be completed no later (Moved to item 23 to be managed by the Structures Monitoring program - LRA Amendment than six months prior

35) to PEO or the end of the last refueling outage prior to the PEO, whichever occurs later.

46 Enhance the ASME Section XI Inservice Inspection, Subsection IWB, IWC, and IWD program 4.7.3 Completed no later to perform periodic inspection of the reactor vessel cladding indications identified in FSAR than six months prior Section 5.2.3.2.2 SP and reconcile the inspection results with the corrosion analysis to ensure to the PEO.

the analytical basis of the analysis are maintained. Inspections to be completed no later than six months prior to PEO or the end of the last refueling outage prior to the PEO, whichever occurs later.

Callaway Plant Unit 1 Page A-49 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 38 of 64 Appendix B AGING MANAGEMENT PROGRAMS B2.1.8 Bolting Integrity Program Description The Bolting Integrity program manages cracking, loss of material and loss of preload for pressure retaining bolting. The program includes preload control, selection of bolting material, use of lubricants/sealants, and performance of periodic inspections for indication of aging effects.

The general practices that are established in this program are consistent with the recommendations, as delineated in NUREG-1339, Resolution of Generic Safety Issue 29:

Bolting Degradation or Failure in Nuclear Power Plants, and EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants, Volume 1 and 2 with the exception noted in NUREG-1339 for safety-related bolting. In addition to the inspection activities noted above, the Bolting Integrity program includes activities for preload control, material selection and control, and use of lubricants/sealants as delineated in EPRI TR-104213, Bolted Joint Maintenance and Applications Guide.

ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD program (B2.1.1) supplements the Bolting Integrity program to manage cracking, loss of preload, and loss of material by providing the requirements for inservice inspection of ASME Class 1, 2, and 3 safety-related pressure retaining bolting. Examinations are currently performed in accordance with the ASME Section XI, 1998 Edition with the 2000 Addenda, per the ISI program plan. As required by 10 CFR 50.55a(g)(4)(ii), the Callaway ISI Program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition of the Code specified twelve months before the start of the inspection interval. Callaway will use the ASME Code Edition consistent with the provisions of 10 CFR 50.55a during the period of extended operation. The extent and schedule of the inspections is in accordance with IWB-2500-1, IWC-2500-1 and IWD-2500-1 and assures that detection of leakage or fastener degradation occurs prior to loss of system or component intended functions. Bolting associated with Class 1 vessel, valve and pump flanged joints receive visual (VT-1) inspection. For other pressure retaining bolting, routine observations identify any leakage before the leakage becomes excessive.

A sample of submerged bolting heads in raw water and waste water environments is visually inspected every four refueling outages (six years) when the pumps are dewatered or opportunistically inspect the bolting threads when the pumps are disassembled during maintenance activities. A sample of submerged bolting on the fuel oil storage tank transfer pumps is visually inspected every 10 years when the pumps are disassembled during maintenance activities. The sample for submerged bolting will be 20% of the population with a maximum of 25 for each environment. The inspection of submerged bolting focuses on the bounding or lead components most susceptible to aging due to time in service and severity of operating conditions.

Callaway Plant Unit 1 Page B-34 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 39 of 64 Appendix B AGING MANAGEMENT PROGRAMS The integrity of non-ASME Class 1, 2, 3 system and component bolted joints is evaluated by detection of visible leakage during maintenance or routine observation such as system walkdowns. Inspection activities for non-ASME Class 1, 2, or 3 bolting in a submerged environment are performed in conjunction with associated component maintenance activities.

The Corrective Action Program is used to document and manage those locations where leakage was identified during routine observations including engineering walkdowns and equipment maintenance activities. Based on the severity of the leak and the potential to impact plant operations, nuclear or industrial safety, a leak may be repaired immediately, scheduled for repair, or monitored for change. If the leak rate changes (increases, decreases or stops), the monitoring frequency is re-evaluated and may be revised.

High strength bolts (actual yield strength 150 ksi) are not used on pressure retaining bolted joints within the scope of the Bolting Integrity program.

Procurement controls and installation practices, defined in plant procedures, include preventive measures to ensure that only approved lubricants, sealants, and proper torque are applied.

Safety-related and nonsafety-related structural bolting is managed by the following programs:

(a) ASME Section XI, Subsection IWE program (B2.1.26) provides the requirements for inspection of structural bolting.

(b) ASME Section XI, Subsection IWF program (B2.1.28) provides the requirements for inservice inspection of safety-related component support bolting.

(c) Structures Monitoring program (B2.1.31) monitors the condition of structures and structural supports that are within the scope of license renewal.

(d) RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program (B2.1.32) provides the requirements for inspection of water control structures associated with emergency cooling water systems.

(e) Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems program (B2.1.12) provides the requirements for inspection of handling systems within the scope of license renewal.

Reactor pressure vessel head closure studs are not included in the Bolting Integrity program. The Reactor Head Closure Stud Bolting program (B2.1.3) provides the requirements for inspection of the reactor vessel head closure studs.

Inspection activities for bolting in buried and underground applications is performed in conjunction with inspection activities for the Buried and Underground Piping and Tanks (B2.1.25) program due to the restricted accessibility to these locations.

Callaway Plant Unit 1 Page B-35 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 40 of 64 Appendix B AGING MANAGEMENT PROGRAMS NUREG-1801 Consistency The Bolting Integrity program is an existing program that, following enhancement, will be consistent with NUREG-1801,Section XI.M18, Bolting Integrity.

Exceptions to NUREG-1801 None Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

Scope (Element 1) and Parameters Monitored or Inspected (Element 3)

Procedures will be revised to include a visual inspection of a sample of submerged bolting heads in raw water and waste water environments every four refueling outages (six years) when the pumps are dewatered or opportunistically inspect the bolting threads when the pumps are disassembled during maintenance activities. A sample of submerged bolting on the fuel oil storage tank transfer pumps will be visually inspected every 10 years when the pumps are disassembled during maintenance activities. The sample for submerged bolting will be 20% of the population with a maximum of 25 for each environment. The inspection of submerged bolting will focus on the bounding or lead components most susceptible to aging due to time in service and severity of operating conditions.

Operating Experience The following discussion of operating experience provides objective evidence that the Bolting Integrity 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 Bolting Integrity program incorporates the applicable industry experience on bolting issues into the program. Actions taken include confirmatory testing/analysis or inspections. Also included are the addition of procedures of inspection, material procurement and verification processes.
2. A review of plant operating experience identified issues with corrosion, missing or loose bolts, inadequate thread engagement, and improper bolt applications.

Identified concerns were corrected or evaluated to be accepted as-is. No generic bolting failure issues or trends have been identified. There is no documented case of cracking of pressure retaining bolting due to stress corrosion cracking.

Callaway Plant Unit 1 Page B-36 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 41 of 64 Appendix B AGING MANAGEMENT PROGRAMS The operating experience of the Bolting Integrity program shows that the program effectively monitors and trends the aging effects of cracking, loss of material, and loss of preload on pressure retaining bolting and takes appropriate corrective action prior to loss of intended function. Occurrences that would be identified under the Bolting Integrity 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 continued implementation of the Bolting Integrity program will effectively identify aging prior to loss of intended function.

Conclusion The continued implementation of the Bolting Integrity program, following enhancement, provides 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.

Callaway Plant Unit 1 Page B-37 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 42 of 64 Appendix B AGING MANAGEMENT PROGRAMS B2.1.14 Fire Water System Program Description The Fire Water System program conducts full-flow testing and visual inspections to ensure that loss of material and flow blockage is adequately managed. This AMP applies to water-based fire protection system components, including sprinklers, nozzles, fittings, valve bodies, fire pump casings, hydrants, hose stations, standpipes, water storage tanks, and above ground, buried, and underground piping and components that are tested consistent with the 2011 Edition of National Fire Protection Association (NFPA) 25, "Inspection, Testing and Maintenance of Water-Based Fire Protection Systems", noted in Table B2.1.14-1. Unless noted in Table B2.1.14-1, flow testing and visual inspections are performed at intervals specified in the 2011 Edition of NFPA 25.

Either sprinklers are replaced before reaching 50 years inservice or a representative sample of sprinklers from one or more sample areas is tested by using the guidance of the 2011 Edition of NFPA 25 to ensure that signs of degradation, such as corrosion, are detected in a timely manner.

In addition to NFPA codes and standards, portions of the water-based fire protection system that are: (a) normally dry but periodically are subject to flow (e.g., dry-pipe or preaction sprinkler system piping and valves) and (b) that cannot be drained or allow water to collect, are subjected to augmented testing or inspections. Also, portions of the system (e.g., fire service main, standpipe) are normally maintained at required operating pressure and monitored such that loss of system pressure is immediately detected and corrective actions are initiated.

Non-intrusive wall thickness examinations are performed on fire water piping to identify loss of material. Wall thickness examinations will be performed on fire water piping every three years. Each three year sample will include at least three locations for a total of 100 feet of above-ground fire water piping and be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. The basis for the frequency is that three years is the frequency required by the FSAR for the yard fire loop flush and for the flow tests of the fire water loops.

Internal inspections are performed on accessible exposed portions of fire water piping during plant maintenance activities.

Samples are collected for microbiologically-influenced corrosion quarterly and when fire water piping and components are opened for maintenance or are accessible. Biofouling is prevented by periodically adding treatment chemicals such as an anti-scalant, a biopenetrant, and a biostat to the fire water system annually and when monitoring indicates they should be added. The MIC Index is trended to evaluate treatment effectiveness in specific locations.

Callaway Plant Unit 1 Page B-53 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 43 of 64 Appendix B AGING MANAGEMENT PROGRAMS External surfaces of buried fire main piping are evaluated as described in the Buried and Underground Piping and Tanks program (B2.1.25).

Inspections of wetted normally dry piping segments that canot cannot be drained or that allow water to collect begin five years before the period of extended operation. The program's remaining inspections begin during the period of extended operation.

Table B2.1.14-1 Fire Water System Aging Management NFPA 25 Component Aging Management Performed Section Sprinkler 5.2.1.1 Sprinklers are inspected for signs of leakage, corrosion, Systems: and foreign material.

Sprinkler inspections Sprinkler 5.3.1 Prior to 50 years in service, the Fire Water System Systems: program requires sprinkler heads to be replaced or have Sprinkler testing representative samples submitted for field-service testing by a recognized testing laboratory in accordance with NFPA 25. The program field-service tests additional representative samples every 10 years thereafter during the period of extended operation to ensure signs of aging are detected in a timely manner.

Standpipe and 6.3.1 Flow testing is conducted at least every five years at the Hose Systems: hydraulically most remote hose connections of each Flow Tests zone of an automatic standpipe system to verify the water supply provides the design pressure at the required flow.

Private Fire 7.3.1 Underground and exposed piping is flow tested at flows Service Mains: representative of those during a fire to determine the Underground internal condition of the piping at minimum 3-year and Exposed intervals.

Piping Private Fire 7.3.2 Hydrants are flow tested annually to ensure proper Service Mains: functioning.

Hydrants Fire Pumps: 8.3.3.7 Not applicable. Callaway's fire protection pumps do not Suction Screens have suction screens.

Water Storage 9.2.5.5 The exterior painted surface of the fire water storage Tanks: Exterior tanks (FWSTs) is inspected annually for signs of Inspections degradation.

Callaway Plant Unit 1 Page B-54 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 44 of 64 Appendix B AGING MANAGEMENT PROGRAMS NFPA 25 Component Aging Management Performed Section Water Storage 9.2.6, The interior of each FWST is inspected every other Tanks: Interior 9.2.7 refueling cycle for signs of aging. Testing of interior inspections surfaces is performed for coating integrity and tank bottom integrity when FWSTs exhibit signs of interior pitting, corrosion, or coating failure.

Valves and 13.2.5 Main drain tests are performed on a representative System-Wide sample of 20% of the main drains within the scope of Testing: Main License Renewal annually in order to check for potential Drain Test flow blockage in system risers. During annual testing, one of the tests is performed in a radiologically controlled area.

Valves and 13.4.3.2.2 A full flow test using air or water is performed every System-Wide to refueling outage by trip testing each deluge valve to Testing: Deluge 13.4.3.2.5 verify that spray/sprinkler nozzles are unobstructed.

Valves Water Spray 10.2.1.6, Spray system strainers are inspected and cleaned every Fixed Systems: 10.2.1.7, refueling outage and after each system actuation.

Strainers 10.2.7 Callaway does not have main line strainers.

Water Spray 10.3.4.3 A full flow test is performed every refueling cycle using Fixed Systems: air or water to verify that spray/sprinkler nozzles are Operation Test unobstructed.

Foam Water 11.2.7.1 Not applicable. Callaway does not have a foam water Sprinkler sprinkler system.

Systems:

Strainers Foam Water 11.3.2.6 Not applicable. Callaway does not have a foam water Sprinkler sprinkler system.

Systems:

Operational Test Discharge Patterns Foam Water Visual Not applicable. Callaway does not have a foam water Sprinkler inspection sprinkler system.

Systems: for Storage tanks internal corrosion Callaway Plant Unit 1 Page B-55 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 45 of 64 Appendix B AGING MANAGEMENT PROGRAMS NFPA 25 Component Aging Management Performed Section Obstruction 14.2 and Wet pipe suppression systems are inspected every five Investigation: 14.3 years. For buildings containing multiple systems, half Obstruction, are inspected in the first 5 year interval, and the Internal remaining half inspected in the next 5 year interval. If Inspection of sufficient foreign material is found in any system in a Piping building, then all systems in the building will be inspected. Dry pipe preaction systems will be inspected following actuation, prior to return to service.

If sufficient foreign material is found to obstruct pipe or sprinklers, then an obstruction investigation is conducted. If the visual inspection detects surface irregularities that could indicate wall loss below nominal pipe wall thickness, then follow-up volumetric examinations will be performed.

NUREG-1801 Consistency The Fire Water System program is an existing program that, following enhancement, will be consistent, with exception to NUREG-1801,Section XI.M27, Fire Water System.

Exceptions to NUREG-1801 Program Element Affected:

Detection of Aging Effects (Element 4)

NUREG-1801 requires inspection of fire protection systems in accordance with the guidance of NFPA-25. Callaway performs power block hose station gasket inspections at least once every 18 months. The inspection interval is in accordance with the approved fire protection program, as described in FSAR Table 9.5.1 SP, Section 5.4, rather than annually as specified by NFPA-25.

NUREG-1801 requires annual testing of fire hydrant hose. Callaway hydrostatically tests fire hoses at interior fire hose stations five years from installation and at least every three years thereafter. The testing interval is in accordance with the approved fire protection program, as described in FSAR Table 9.5.1 SP, Section 5.6.

Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

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ULNRC-06118 May 6, 2014 Page 46 of 64 Appendix B AGING MANAGEMENT PROGRAMS Preventive Actions (Element 2)

The Fire Water Storage Tanks internal surfaces will be recoated prior to the period of extended operation.

Parameters Monitored or Inspected (Element 3) and Detection of Aging Effects (Element 4)

The Fire Water System program will be enhanced to require augmented tests and inspections of water-based fire protection system components that have been wetted but are normally dry. The augmented tests and inspections are conducted as follows on piping segments that cannot be drained or that allow water to collect:

  • In each five-year interval, beginning five years prior to the period of extended operation, either conduct a flow test or flush sufficient to detect potential flow blockage, or conduct a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or allow water to collect.
  • A 100% baseline inspection will be performed prior to the period of extended operation.

In each five-year interval of the period of extended operation, 20 percent of the length of piping segments that cannot be drained or that allow water to collect is subject to volumetric wall thickness inspections. Measurement points will be obtained to the extent that each potential degraded condition can be identified (e.g., general corrosion, MIC).

The 20 percent of piping that is inspected in each five-year interval will be in different locations than previously inspected piping.

If the results of a 100 percent internal visual inspection are acceptable, and the segment is not subsequently wetted, no further augmented tests or inspections will be performed.

Parameters Monitored or Inspected (Element 3), Detection of Aging Effects (Element 4), and Acceptance Criteria (Element 6)

Internal inspections will be performed on accessible exposed portions of fire water piping during plant maintenance activities. When visual inspections are used to detect loss of material, the inspection technique is capable of detecting surface irregularities that could indicate wall loss to below nominal pipe wall thickness due to corrosion and corrosion product deposition. Where such irregularities are detected, follow-up volumetric wall thickness examinations are performed.

The Fire Water System program will be enhanced to include non-intrusive pipe wall thickness examinations. Wall thickness measurements will be performed on fire water piping every three years. Each three year sample will include at least three locations for a total of 100 feet of above-ground fire water piping, and will be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. Pipe wall thickness examinations and internal inspections will be performed commencing after 2014 and throughout the period of extended operation.

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ULNRC-06118 May 6, 2014 Page 47 of 64 Appendix B AGING MANAGEMENT PROGRAMS Detection of Aging Effects (Element 4)

The Fire Water System program will be enhanced to include annual hydrostatic testing of fire brigade hose.

The Fire Water System program will be enhanced such that prior to 50 years in service, sprinkler heads will be replaced or representative samples will be submitted for field-service testing by a recognized testing laboratory in accordance with NFPA 25. The program will field-service test additional representative samples every 10 years thereafter to ensure signs of aging are detected in a timely manner.

The Fire Water System program will be enhanced to require the inspection of the interior of the fire water storage tanks to include checking for evidence of voids beneath the floor.

The Fire Water System program will be enhanced to change the frequency of trip testing each deluge valve from every three years to every refueling outage.

The Fire Water System program will be enhanced to change the frequency of tests of spray/sprinkler nozzle discharge patterns from every three years to every refueling outage.

The Fire Water System program will be enhanced to require the following additional inspections if pitting, corrosion, or coating failure is found during the inspection of the fire water storage tanks: (1) tank coatings are evaluated using an adhesion test consistent with ASTM D 3359, Standard Test Methods for Measuring Adhesion by Tape Test; (2) dry film thickness measurements are taken at random locations to determine the overall coating thickness; (3) nondestructive ultrasonic readings are taken to evaluate the wall thickness where there is evidence of pitting or corrosion; (4) interior surfaces are spot wet-sponge tested to detect pinholes, cracks, or other compromises in the coating; (5) tank bottoms are tested for metal loss on the underside by use of ultrasonic testing where there is evidence of pitting or corrosion; (6) bottom seams are vacuum-box tested in accordance with NFPA 22, Standard for Water Tanks for Private Fire Protection.

The Fire Water System program will be enhanced to perform main drain tests consistent with NFPA 25, Section 13.2.5 of a representative sample of 20% of the main drains within the scope of License Renewal annually in order to check for potential flow blockage in system risers. During annual testing, one of the tests is performed in a radiologically controlled area.

The Fire Water System program will be enhanced to inspect wet pipe suppression systems every five years consistent with NFPA 25, Section 14.2. For buildings containing multiple systems, half are inspected in the first 5 year interval, and the remaining half inspected in the next 5 year interval. If sufficient foreign material is found in any system in a building, then all systems in the building will be inspected. The NFPA 25, Section 14.2 inspection of dry pipe preaction systems will be performed following actuation, prior to return to service. If sufficient foreign material is found to obstruct pipe or sprinklers, then an obstruction investigation is conducted per NFPA 25 Annex D. If the visual inspection detects surface irregularities that could indicate wall loss below nominal pipe wall thickness, then follow-up volumetric examinations will be performed.

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ULNRC-06118 May 6, 2014 Page 48 of 64 Appendix B AGING MANAGEMENT PROGRAMS Detection of Aging Effects (Element 4) and Acceptance Criteria (Element 6)

The Fire Water System program will be enhanced to include annual hydrant flow testing in accordance with NFPA 25.

Monitoring and Trending (Element 5)

The Fire Water System program will be enhanced to review and evaluate trends in flow parameters recorded during the NFPA 25 fire water flow tests.

Acceptance Criteria (Element 6)

The Fire Water System program will be enhanced to require the removal of foreign material if its presence is found during pipe inspections to obstruct pipe or sprinklers. In addition, the source of the material is determined and corrected.

Operating Experience The following discussion of operating experience provides objective evidence that the Fire Water System program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation.

1. In 2005, during a surveillance test, 10 sprinkler heads had signs of corrosion or mechanical damage. Two of the sprinkler heads were replaced, and the other eight were cleaned. There have been no additional issues with the sprinkler heads since then.
2. In 2005, an alarm was triggered for fire protection loop jockey pump excessive run time and an investigation was initiated to identify the leak. The location of the leak was determined and promptly isolated from the main fire water loop. The isolation of the leak did not affect any required suppression systems. The leak was promptly repaired and the fire water piping was returned to service.
3. In 2006, a low C-factor lead to the fire water system being chemically cleaned, resulting in removal of approximately 8900 pounds of corrosion products. The cleaning was successful in keeping the system C-factor above 91.5 as required by plant procedure.

During the chemical cleaning, five leaks developed, all of which were repaired. Since that time, two additional leaks have occurred. One was due to a cracked valve, and the cause of the other is still under investigation.

4. In 2007, an inspection of the train B fire water storage tank, performed in accordance with the Callaway fire water storage tank inspection procedure, identified small amounts of corrosion and mineral deposits, generally at the weld seams. An evaluation determined another application of the tank coating would be planned. In 2009, an inspection of the train B fire water storage tank identified several areas of blistering in the coating, mainly near the welds, and calcium deposits. No major delaminations Callaway Plant Unit 1 Page B-59 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 49 of 64 Appendix B AGING MANAGEMENT PROGRAMS were identified, and the anodes were in good shape. Minor corrosion was identified on bare metal surfaces, with no pitting. An evaluation determined that the tank internal surfaces were satisfactory. In 2011, an inspection of the train B fire water storage tank was performed. Little to no damage or degradation was found to the internal metallic surface of the tank. There was some surface roughness/pitting when compared to clean bare metal. General blistering and some local delamination of the coating were found.

The blistering on the wall and most of the floor is intact, while there was heavy blistering near the welds with smaller blistering on general plate areas. Since the fire water storage tanks are cathodically protected and most of the blisters were intact, the substrate is not expected to degrade significantly by the next inspection or re-coating, and no repair to the exposed metal is necessary.

5. In 2008, an inspection of the train A fire water storage tank identified minor blistering and limestone deposits. No corrosion was found on the tank internal surface, and the tank cathodic protection was found in satisfactory condition. The internal surface of the tank was determined to be in satisfactory condition. In 2010, an inspection of the train A fire water tank identified discontinuities and delaminations of the coating. The weld at the floor to wall interface had the most pitting, and weld locations contained heavy blistering.

The adjustments on the rectifier of the cathodic protection system were found to be adequate. An evaluation determined that, since the cathodic protection system was determined to be effective, through voltage and current measurements, the substrate would not degrade excessively before the next planned inspection.

6. In 2008, during microbiological sampling of the fire water system, elevated levels of microbiologically influenced corrosion (MIC) were detected in stagnant portions of fire water pipe supplying fire water to hose stations. As a result, a new preventive maintenance task has been created to flush hose stations with a biocide.
7. In 2011, C-factor testing was performed on the main fire loop piping to check for restrictions due to corrosion and or biofouling. The testing results did not meet the acceptance criteria, indicating excessive pressure drop leading to reduced fire water flow. The testing results were called into question so with more accurate digital crystal gauges, the system was reevaluated and the results improved by 6% to 89.5, still less than the required acceptance criteria of 91.5. A functionality determination concluded that provided compensatory measures were taken, the reduced cleanliness could be fully offset so the required fire water flow rate could be achieved and maintained. As a corrective action, the acceptance criteria in Calculation KC-005 Addendum 2 have been modified, and the test procedure updated accordingly. These revisions provide significant margin and consider the cleanliness trends, ensuring the fire water system is capable of performing its intended function.

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ULNRC-06118 May 6, 2014 Page 50 of 64 Appendix B AGING MANAGEMENT PROGRAMS Actions have been taken to address examples of recurring corrosion identified above. Pipe wall thickness examinations will be performed in addition to the opportunistic visual inspections of the fire water system. Sections of the above-ground fire water piping will be tested every three years. Each three year sample will include at least three locations for a total of at least 100 feet of above-ground fire water piping, and will be selected based on system susceptibility to corrosion or fouling and evidence of performance degradation during system flow testing or periodic flushes. This sampling program will commence after 2014, ensuring that over 1000 feet of piping in 30 locations will be inspected during the following 30 years.

MIC samples are collected quarterly and when fire water piping and components are opened for maintenance or are accessible. The MIC Index is trended to evaluate treatment effectiveness in specific locations. Biofouling is prevented by adding treatment chemicals such as an anti-scalant, a biopenetrant, and a biostat to the fire water system annually and when monitoring indicates they should be added.

The above examples provide objective evidence that the existing Fire Water System program includes activities that are capable of detecting aging effects, evaluating system leakage, and initiating corrective actions. Occurrences that would be identified under the Fire Water System 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 continued implementation of the Fire Water System program will effectively identify aging prior to loss of intended function.

Conclusion The continued implementation of the Fire Water System program, following enhancement, provides 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.

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ULNRC-06118 May 6, 2014 Page 51 of 64 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 also manages loss of coating integrity on components with an internal coating. 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.

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.

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.

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ULNRC-06118 May 6, 2014 Page 52 of 64 Appendix B AGING MANAGEMENT PROGRAMS Visual inspections are performed on all accessible internal surface coatings of the service water self-cleaning strainers and a representative 73 1-foot axial length circumferential segments of service water piping from the circulating and service water pumphouse to the ESW system connection. Baseline inspections will be conducted in the ten year period prior to the period of extended operation on the accessible internal surfaces coatings of the in-scope components. Coatings are inspected every six years on an alternating train basis based on no observed degradation or cracking and flaking that has been evaluated as acceptable. Coatings with blisters, peeling, delaminations or rusting that has been determined not to require remediation are inspected on a four year frequency. For peeling, delaminations and blisters determined to not meet the acceptance criteria and that will not be repaired or replaced, physical testing is performed where physically possible (i.e., sufficient room to conduct testing). Testing consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Plants. Monitoring and trending of coatings is based on a review of the previous two inspections results (including repairs) with the current inspection results.

The training and qualification of individuals involved in coating inspections are conducted in accordance with ASTM International Standards endorsed in RG 1.54 including guidance from the staff associated with a particular standard.

Coating acceptance criteria are as follows:

  • Indications of peeling and delamination are not acceptable and the coatings are repaired or replaced.
  • Blisters are evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff guidance associated with use of a particular standard.
  • Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff guidance associated with use of a particular standard.
  • Adhesion testing results meet or exceed the degree of adhesion recommended in engineering documents specific to the coating and substrate.

Inspection results not meeting the acceptance criteria will be evaluated by a qualified coatings evaluator. Corrective actions will be determined using the corrective action program.

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.

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ULNRC-06118 May 6, 2014 Page 53 of 64 Appendix B AGING MANAGEMENT PROGRAMS 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 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.

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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.

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.

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ULNRC-06118 May 6, 2014 Page 55 of 64 Appendix B AGING MANAGEMENT PROGRAMS B2.1.25 Buried and Underground Piping and Tanks Program Description The Buried and Underground Piping and Tanks program manages loss of material, cracking, blistering, and changes in color of external surfaces of buried and underground piping and tanks. The program augments other programs that manage the aging of internal surfaces of buried and underground piping and tanks. The materials managed by this program include steel, stainless steel, concrete, and high-density polyethylene. The program manages aging through preventive, mitigative, and inspection activities.

Preventive and mitigative actions include the selection of component materials, external coatings for corrosion control, backfill quality control, and the application of cathodic protection. The cathodic protection system is operated consistent with the guidance of NACE SP0169-2007 for piping and NACE RP 0285-2002 for tanks. Trending of the cathodic protection system is performed to identify changes in the effectiveness of the system and to ensure that the rectifiers are available to protect buried components. An annual cathodic protection survey is performed consistent with NACE SP0169-2007.

Soil samples will be conducted during the 10-year period prior to the period of extended operation and in each subsequent 10-year period during the period of extended operation.

Soil samples will be performed in the vicinity of buried steel piping in which the cathodic protection system does not meet the following availability or effectiveness requirements:

  • Cathodic protection has been operational (available) at least 85 percent of the time since either 10 years prior to the period of extended operation or since installation/refurbishment, whichever is shorter; or
  • Cathodic protection has provided effective protection for buried piping as evidenced by meeting the acceptance criteria of -850 mV relative to a copper/copper sulfate electrode, instant off, at least 80 percent of the time since either 10 years prior to the period of extended operation or since installation/refurbishment, whichever is shorter.

Inspection activities may include nondestructive evaluation of pipe and tank wall thicknesses, and visual inspections of pipe and tank exterior surfaces, as permitted by opportunistic or directed excavations. The fire protection system jockey pump is monitored to identify changes in jockey pump activity.

Direct visual inspections will be performed on buried steel piping, stainless steel, piping, concrete piping, and carbon steel tanks. Inspection locations will be selected based on susceptibility to degradation and consequences of failure. A minimum of 10 feet of pipe of each material type must be inspected. The inspection will consist of a 100 percent visual inspection of the exposed pipe. If adverse indications are detected, inspection sample sizes within the affected piping categories are doubled. If adverse indications are Callaway Plant Unit 1 Page B-87 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 56 of 64 Appendix B AGING MANAGEMENT PROGRAMS found in the expanded sample, further increases in inspection sample size would be based on an analysis of extent of cause and extent of condition. Visual inspections of metallic components will be supplemented with surface or volumetric nondestructive testing (NDT) if significant indications are observed, to determine local area wall thickness. All buried high density polyethylene piping is encased in controlled low strength material; therefore, no direct visual inspections are required.

Direct visual inspections will be performed on underground steel, stainless steel and high density polyethylene piping, tank access covers, and valves to detect external corrosion.

Inspection locations will be selected based on susceptibility to degradation and consequences of failure.

Inspections will begin during the 10-year period prior to entering the period of extended operation. Upon entering the period of extended operation, inspections will occur every 10 years.

The internal surfaces of buried and underground piping and tanks are managed through other programs. Internal surfaces may be managed by the Open-Cycle Cooling Water System (B2.1.10), Closed Treated Water Systems (B2.1.11), Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.23), Fuel Oil Chemistry (B2.1.16), Fire Water System (B2.1.14) or Water Chemistry (B2.1.2) programs. The Selective Leaching program (B2.1.19) works in conjunction with this program to manage buried or underground components subject to selective leaching.

NUREG-1801 Consistency The Buried and Underground Piping and Tanks program is a new program that, when implemented, will be consistent with NUREG-1801,Section XI.M41, Buried and Underground Piping and Tanks.

Exceptions to NUREG-1801 None Enhancements None Operating Experience The following discussion of operating experience provides objective evidence that the Buried and Underground Piping and Tanks program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation:

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1. In the winter of 2005, an alarm was triggered for fire protection loop jockey pump excessive run time and an investigation was initiated. The location of the leak was determined and promptly isolated from the main fire water loop. The isolation of the leak did not affect any required suppression systems. The leak was promptly repaired and the fire water piping was returned to service.
2. Prior to Refuel 15 (Spring 2007), Close Interval Surveys (CIS) were performed on various tanks and associated piping systems to identify cathodic protection effectiveness. The CIS testing measures cathodic protection levels along the pipeline at approximately 2.5 foot intervals. These surveys were performed on the following structures and components within the scope of license renewal: emergency fuel oil storage tanks, fire water storage tank bottoms, ESW system piping, and condensate storage tank piping. The results indicated that emergency fuel oil storage tanks, condensate storage tank piping, and one quadrant of the fire water storage tank, were not meeting the 850mV polarization potential criterion of the National Association of Corrosion Engineers (NACE). Corrective actions were taken to correct these deficiencies by adjusting the cathodic protection where possible. In some instances the cathodic protection system could not be adjusted to correct a condition. Cathodic protection system refurbishment and modifications are planned in areas where the system does not meet the NACE criteria.
3. From 2008 to 2009, the underground portions of the ESW supply from the ESW pump house and return to the ultimate heat sink cooling tower were replaced with HDPE piping. In addition, sections of above ground or underground carbon steel piping that interfaces with the buried piping was replaced with stainless steel piping. These modifications were performed as a result of the material condition of the ESW system.

These modifications were performed as a result of corrective action documents that have been written concerning pinhole leaks, pitting, and other localized degradation of the ESW piping system.

4. In the summer of 2011, the annual cathodic protection survey was performed. Several locations in the fire water system had a negative potential below the NACE criteria of 850 mV. Modification and refurbishment of the cathodic protection system will address areas of low negative potential identified during the annual survey and the CIS described above.
5. Due to industry operating experience with buried condensate system piping, Callaway reviewed cathodic protection records related to the buried carbon steel piping for the condensate storage tank to determine if the external corrosion control provided for this piping was adequate. The review of the cathodic protection for this line found that the negative potential was below the NACE criteria. The cathodic protection system will be refurbished/modified in areas where it does not meet the NACE criteria. The buried portion of the condensate storage tank suction line will be inspected prior to the period of extended operation.

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ULNRC-06118 May 6, 2014 Page 58 of 64 Appendix B AGING MANAGEMENT PROGRAMS Inspection and preventive measures that will be implemented by the Buried and Underground Piping and Tanks program will be effective in managing aging of underground and buried components. Occurrences that would be identified under the Buried and Underground Piping and Tanks 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 Buried and Underground Piping and Tanks 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 Buried and Underground Piping and Tanks 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.

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ULNRC-06118 May 6, 2014 Page 59 of 64 Appendix B AGING MANAGEMENT PROGRAMS B2.1.31 Structures Monitoring Program Description The Structures Monitoring program (SMP) monitors the condition of structures and structural supports that are within the scope of license renewal to manage the following aging effects:

  • Concrete cracking and spalling
  • Cracking
  • Cracking and distortion
  • Cracking, blistering, change in color
  • Cracking, loss of material
  • Cracking, loss of bond, and loss of material (spalling, scaling)
  • Increase in porosity and permeability, cracking, loss of material (spalling, scaling)
  • Increase in porosity and permeability, loss of strength
  • Loss of material
  • Loss of material (spalling, scaling) and cracking
  • Loss of mechanical function
  • Loss of preload
  • Loss of sealing
  • Reduction in concrete anchor capacity Plant procedures, following enhancements, will specify that whenever replacement of bolting is required, bolting material, installation torque or tension, and use of lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, Degradation and Failure of Bolting in Nuclear Power Plants, EPRI NP-5067, Good Bolting Practices, A Reference Manual for Nuclear Power Plant Maintenance Personnel, EPRI TR-104213, Bolted Joint Maintenance &

Application Guide, and the additional recommendations of NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants.

The SMP implements the requirements of 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, consistent with guidance of NUMARC 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 2 and Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Revision 2.

The SMP provides inspection guidelines and walk-down checklists for structural steel, roof systems, reinforced concrete, masonry walls and metal siding. Electrical duct banks and manholes, valve pits, access vaults, and structural supports are inspected as part of the SMP. Callaway is committed to NRC Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants and the scope of the SMP includes water-control structures. The scope of SMP also includes masonry walls. Callaway has a settlement monitoring program that monitors settlement for each major structure utilizing geotechnical monitoring techniques. The inspections of all structural components, include including masonry walls and water-control structures, are performed at intervals of no more than 5 years.

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ULNRC-06118 May 6, 2014 Page 60 of 64 Appendix B AGING MANAGEMENT PROGRAMS Groundwater is monitored for pH, chlorides and sulfates every five years, and the results are evaluated by engineering to assess the impact, if any, on below grade structures.

Callaway does not take credit for any coatings to manage the aging of structural components and coating degradation is used only as an indicator of the condition of underlying material.

NUREG-1801 Consistency The Structures Monitoring program is an existing program that, following enhancement, will be consistent with NUREG-1801,Section XI.S6, Structures Monitoring.

Exceptions to NUREG-1801 None Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

Scope of the Program (Element 1)

Procedures will be enhanced to include the main access facility, the nitrogen storage tank foundation and pipe trench, and the reinforced concrete structures under the turbine building and in the yard that provide a return flowpath for the circulating water system into the scope of the Structures Monitoring program.

Preventive Actions (Element 2)

Plant procedures will be enhanced to specify that whenever replacement of bolting is required, bolting material, installation torque or tension, and use of lubricants and sealants are in accordance with the guidelines of EPRI NP-5769, EPRI NP-5067, EPRI TR-104213, and the additional recommendations of NUREG-1339.

Plant procedures will be enhanced to specify the preventive actions for storage, lubricants, and stress corrosion cracking potential discussed in Section 2 of Research Council for Structural Connections publication Specification for Structural Joints Using ASTM A325 or A490 Bolts for ASTM A325, ASTM F1852, and/or ASTM A490 structural bolts.

Scope of the Program (Element 1) and Parameters Monitored or Inspected (Element 3)

Procedures will be enhanced to specify inspections of penetrations, transmission towers, electrical conduits, raceways, cable trays, electrical cabinets/enclosures, and associated anchorages, and to complete a baseline inspection of these components prior to December 31, 2017.

Procedures will be enhanced to specify that groundwater is monitored for pH, chlorides and sulfates, and every five years at least two samples are tested and the results are evaluated by engineering to assess the impact, if any, on below grade structures.

Callaway Plant Unit 1 Page B-105 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 61 of 64 Appendix B AGING MANAGEMENT PROGRAMS Detection of Aging Effects (Element 4)

Procedures will be enhanced to specify inspector qualifications in accordance with ACI349.3R-96.

Acceptance Criteria (Element 6)

Procedures will be enhanced to quantify acceptance criteria and critical parameters for monitoring degradation, and to provide guidance for identifying unacceptable conditions requiring further technical evaluation or corrective action in accordance with the three tier quantitative evaluation criteria recommended in ACI 349.3R.

Procedures will be enhanced to incorporate applicable industry codes, standards and guidelines for acceptance criteria.

Procedures will be enhanced to specify that degradation associated with seismic isolation gaps, obstructions of these gaps, or questionable material in these gaps, will be evaluated by an engineer familiar with the seismic design of the plant, and the evaluation will consider the seismic isolation function in determining what corrective actions may be required. Initial inspections in accordance with these criteria have been completed, and corrective actions resulting from these initial inspections will be completed no later than December 31, 2017.

Operating Experience The following discussion of operating experience provides objective evidence that the Structures Monitoring program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation:

1. A review of the most recent structure inspection reports show minor instances of cracking in concrete, corrosion in structural steel, and elastomeric degradation in various building structures which have been evaluated per acceptance criteria and with corrective action taken as needed. The northeast corner of the A' emergency diesel generator fuel vault exterior exhibited some cracking in 2010, which is not severe enough to warrant corrective action at this time but is tracked for trending purposes. The most recent reactor building inspection report (2010) cites instances of corrosion of structural steel, supports, and cable trays due to condensation.
2. Fuel building structural inspection report (2002) identified an instance of cracking on the interior face of the exterior wall, with leachate observed coming through the crack.

Engineering evaluation determined this leaking was not severe enough to warrant corrective action. Inspections performed in 2010 did not identify any further cracking or leaking of leachate in this area. Minor cracking on the exterior of fuel building plant south and west wall was identified and no water leakage, either active or inactive, was observed.

Callaway Plant Unit 1 Page B-106 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 62 of 64 Appendix B AGING MANAGEMENT PROGRAMS Callaway performs continuous monitoring of the spent fuel pool liner leak chase channels. A standpipe with automatic drain controls is used to measure the fuel pool leak rate and periodic updates of the leak rate are provided by the plant computer. The observed leakage has been small and remained steady. The leakage rate is small at approximately 0.119 gal/day, and does not challenge makeup capability. The exterior spent fuel pool walls show no evidence of external leakage, thus indicating that the leakage is contained within the leak chase channels and that there is no effect upon the structural integrity of the spent fuel pool.

3. Groundwater has been sampled monthly since November, 2009. With exception of two monitoring wells, pH, chlorides and sulfate concentrations have been within the prescribed limits for non-aggressive ground water/soil. These two wells are located north of the turbine building and adjacent to plant roads. The wells high chloride levels can be attributed to the use of winter road salts. These two well locations have shown seasonal increases in chloride levels of up to 680 mg/L while the pH and sulfate concentrations have remained non-aggressive. Callaway will continue to monitor the results from the groundwater samples and will perform an engineering evaluation to determine if any adverse aging effects have occurred in any inaccessible concrete structural elements.

The above examples provide objective evidence that the Structures Monitoring program is capable of both monitoring and detecting the aging effects associated with the program.

Occurrences that would be identified under the Structures Monitoring 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 continued implementation of the Structures Monitoring program will effectively identify aging prior to loss of intended function.

Conclusion The continued implementation of the Structures Monitoring program, following enhancement, provides 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.

Callaway Plant Unit 1 Page B-107 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 63 of 64 Appendix B AGING MANAGEMENT PROGRAMS B2.1.32 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Program Description The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program, which is implemented as part of the Structures Monitoring program (SMP), manages the following aging effects:

  • Cracking; loss of bond; and loss of material (spalling, scaling)
  • Increase in porosity and permeability; loss of strength
  • Loss of material
  • Loss of material (spalling, scaling) and cracking
  • Loss of material; loss of form The scope of this program also includes structural steel and structural bolting associated with water-control structures. SNUPPS-Callaway positions are compliant with that of Regulatory Guide 1.127 with respect to the ultimate heat sink (UHS) retention pond. The Structures Monitoring program (B2.1.31), which is in compliance with 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, includes all water-control structures within the scope of RG 1.127. The UHS retention pond, the essential service water pumphouse, the ESW supply lines yard vault, the UHS cooling tower and associated submerged discharge structures, and the concrete structures in the turbine building that provide a flowpath for the circulating water system are the water-control structures within the scope for license renewal that are monitored by this program. The UHS retention pond and its associated structures receive periodic inservice inspections for assessment of their structural safety and operational adequacy every five years. Callaway performs algae treatment and riprap inspections along the UHS retention pond. Callaway maintains benchmarks for monitoring settlement in any of the Category 1 structures including the UHS cooling tower. The inspections of all structural components, include including masonry walls and water-control structures, are performed at intervals of no more than 5 years.

NUREG-1801 Consistency The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program, is an existing program that, following enhancement, will be is consistent with NUREG-1801,Section XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants.

Exceptions to NUREG-1801 None Enhancements None Callaway Plant Unit 1 Page B-108 License Renewal Application Amendment 35

ULNRC-06118 May 6, 2014 Page 64 of 64 Appendix B AGING MANAGEMENT PROGRAMS Prior to the period of extended operation, the following enhancement will be implemented in the following program element:

Scope of the Program (Element 1)

Procedures will be enhanced to include the concrete structures in the turbine building that provide a flowpath for the circulating water system in the scope of the program.

Operating Experience The following discussion of operating experience provides objective evidence that the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program will be effective in ensuring that intended functions are maintained consistent with the current licensing basis for the period of extended operation:

1. An instance of concrete delamination occurred in 2005. Open electrical boxes that were part of the abandoned lighting system in the 'A' UHS fan deck room allowed water to enter the embedded conduits located in the concrete wall. This water contributed to the corrosion growth on the conduit which eventually deteriorated enough to cause spalling on the plant north face of the wall separating 'A' and 'B' UHS fan deck rooms.

The spalled area was patched with cement grout in 2006.

2. Similar spalling was noted on the south wall in the 'D' UHS cooling tower fan room which had an area approximately 1 ft by 1 ft where the concrete had popped out. The degradation appeared to be about two to three inches deep. The apparent cause was rainwater seeping through an abandoned electrical conduit. A job was initiated to repair both spalled areas in the "D" cooling tower fan room. To prevent recurrence of the concrete spalling, prior to installing the grout patch, a hole was drilled in the exposed part of the conduit to drain any water remaining in the abandoned conduits.

The above examples provide objective evidence that the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program is capable of both monitoring and detecting the aging effects associated with the program. Occurrences that would be identified under the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants 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 continued implementation of the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program will effectively identify aging prior to loss of intended function.

Conclusion The continued implementation of the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants program, following enhancement, provides 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.

Callaway Plant Unit 1 Page B-109 License Renewal Application Amendment 35

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