ML081090246

2008/04/15-Pilgrim April 2008 Evidentiary Hearing - Applicant Exhibit 2, Pilgrim License Renewal Application, Pages from Appendix B

ML081090246
Person / Time
Site:	Pilgrim
Issue date:	04/15/2008
From:	Entergy Nuclear Generation Co, Entergy Nuclear Operations
To:	NRC/SECY/RAS
SECY RAS
References
50-293-LR, ASLBP 06-848-02-LR, RAS J-35
Download: ML081090246 (27)

Text

~~A6 Docket No.)'50AR'**-u Official Exhibit No.

0FFERE Intervenor . L, K Pilgrim Nuclear Power Station NRC Staff Other License Renewal Application IDENTIFIED V;.ivitness;Panei Technical Information Mon Taken: A REJECTED WITIODRAW Administrative Controls

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PNPS quality assurance (QA) procedures, review and approval processes, and administrative controls are implemented in accordance with the requirements of 10 CFR Part 50, Appendix B.

The Entergy Quality Assurance Program applies to PNPS safety-related structures and components. Administrative (document) control for both safety-related and nonsafety-related structures and components is accomplished per the existing document control program. The PNPS administrative controls are consistent with NUREG-1801.

B.0.4 OPERATING EXPERIENCE Operating experience for the programs and activities credited with managing the effects of aging was reviewed. The operating experience review included a review of corrective actions resulting in program enhancements. For inspection programs, reports of recent inspections, examinations, or tests were reviewed to determine if aging effects have been. identified on applicable components. For monitoring programs, reports of sample results were reviewed to determine if parameters are being maintained as required by the program. Also, program owners contributed evidence of program success or weakness and identified applicable self-assessments, QA audits, peer evaluations, and NRC reviews.

B.0.5 AGING MANAGEMENT PROGRAMS The following aging management programs are described in the sections listed of this appendix.

Programs are identified as either existing or new. The programs are either comparable to programs described in NUREG-1 801 or are plant-specific. The correlation between NUREG-1801 programs and PNPS programs is shown in Table B-2, with plant-specific programs listed near the end.

Table B-1 Aging Management Programs

1) Boraflex Monitoring Program B. 1.1 existing

2) Buried Piping and Tanks Inspection B.1.2 new Program

3) BWR CRD Return Line Nozzle Program B.1.3 existing

4) BWR Feedwater Nozzle Program B.1.4 existing DOCKETED 5), BWR Penetrations Program B.1.5 existing USNRC

6) BWR Stress Corrosion Cracking Program B.1.6 existing April 15, 2008 (10:00am)

OFFICE OF SECRETARY 7) BWR Vessel ID Attachment Welds B.1.7 existing RULEMAKINGS AND Program ADJUDICATIONS STAFF Appendix B Aging Management Programs and Activities Page 6-3

Pilgrim Nuclear Power Station License Renewal Application Technical Information Table B-1 Aging Management Programs (Continued)

8) BWR Vessel Internals Program B.1.8 existing

9) Containment Leak Rate Program B.1.9 existing

10) Diesel Fuel Monitoring Program B.1.10 existing

11) Environmental Qualification (EQ) of B.1.11 existing Electric Components Program

12) Fatigue Monitoring Program B. 1.12 existing

13) Fire Protection - Fire Protection Program B.1.13.1 existing

14) Fire Protection - Fire Water System B.1.13.2 existing Program

15) Flow-Accelerated Corrosion Program B. 1.14 existing

16) Heat Exchanger Monitoring Program B. 1.15 new

17) Inservice Inspection - Containment B.1.16.1 existing Inservice Inspection (Cll) Program

18) Inservice Inspection - Inservice Inspection B.1.16.2 existing (ISl) Program

19) Instrument Air Quality Program B.1.17 existing

20) Metal-Enclosed Bus Inspection Program B.1.18 new

21) Non-EQ Inaccessible Medium-Voltage B.1.19 new Cable Program

22) Non-EQ Instrumentation Circuits Test B.1.20 new Review Program

23) Non-EQ Insulated Cables and B.1.21 new Connections Program

24) Oil Analysis Program B.1.22 existing

25) One-Time Inspection Program B.1.23 new

26) Periodic Surveillance and Preventive B.1.24 existing Maintenance Program Appendix B Aging Management Programs and Activities Page B-4

Pilgrim Nuclear Power Station License Renewal Application Technical Information Table B-1 Aging Management Programs (Continued)

27) Reactor Head Closure Studs Program B.1.25 existing

28) Reactor Vessel Surveillance Program B.1.26 existing

29) Selective Leaching Program B.1.27 new

30) Service Water Integrity Program B.1.28 existing

31) Structures Monitoring - Masonry Wall B.1.29.1 existing Program

32) Structures Monitoring - Structures B. 1.29.2 existing Monitoring Program

33) Structures Monitoring - Water Control B.1.29.3 existing Structures Monitoring Program

34) System Walkdown Program B.1.30 existing

35) Thermal Aging and Neutron Irradiation B.1.31 new Embrittlement of Cast Austenitic Stainless Steel (CASS) Program

36) Water Chemistry Control - Auxiliary B.1.32.1 existing Systems Program

37) Water Chemistry Control - BWR Program B.1.32.2 existing

38) Water Chemistry Control - Closed Cooling B.1.32.3 existing Water Program Appendix B Aging Management Programs and Activities Page B-5

Pilgrim Nuclear Power Station License Renewal Application Technical Information B.0.6 CORRELATION WITH NUREG-1801 AGING MANAGEMENT PROGRAMS The correlation between NUREG-1 801 programs and PNPS programs is shown below. For the PNPS programs, links to appropriate sections of this appendix are provided.

Table B-2 PNPS AMP Correlation with NUREG-1801 Programs NUREG-1801 NUREG-1801 Program PNPS Program Number Environmental Qualification (EQ) Environmental Qualification (EQ) of X.EI of Electric Components Electric Components Program [B. 1.11]

X.MI Metal Fatigue of Reactor Coolant Fatigue Monitoring Program [B.1.12]

Pressure Boundary X $1 ~Prestress Concrete Containment Tendon Ntapial Not applicable ASME Section XI Inservice See plant-specific Inservice Inspection XI.M1 Inspection, Subsections IWB, - Inservice Inspection (ISI) Program IWC, and IWD [B. 1.16.2]

XI.M2 Water Chemistry Water Chemistry Control - BWR aCProgram [B.1.32.2]

XI.M3 Reactor Head Closure Studs B.2] Head Closure Studs Program Reactor

[B. 1.25]

XI.M4 BWR Vessel ID Attachment Welds BWR Vessel ID Attachment Welds Program [B.1.7]

BWR Feedwater Nozzle Program XI:M5 BWR Feedwater Nozzle [BA .4]

BWR Control Rod Drive Return BWR CRD Return Line Nozzle XI.M6 Line Nozzle Program [B.1.31 BWR Stress Corrosion Cracking XI.M7 BWR Stress Corrosion Cracking Program B. .6]

XI.M8 BWR Penetrations BWR Penetrations Program.[B.1.5]

XI.M9 BWR Vessel Internals BWR Vessel Internals Program [B.1.8]

Page B-6 B Programs and Management Programs Aging Management Activities Appendix B Aging and Activities Page B-6

Pilgrim Nuclear Power Station License Renewal Application Technical Information Table B-2 PNPS AMP Correlation with NUREG-1801 Programs (Continued)

NUREG-1801 NUREG-1801 Program PNPS Program Number XI.M10 Boric Acid Corrosion Not applicable XI.M1I Nickel-Alloy Nozzles and Not applicable Penetrations Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Not applicable XI.M11A Vessel Closure Heads of Pressurized Water Reactors Thermal Aging Embrittlement of XI.M12 Cast Austenitic Stainless Steel Not applicable (CASS)

Thermal Aging and Neutron Embrittlement of Cast Austenitic XI.M13 Irradiation Embrittlement of Cast Stainless Steel (CASS) Program Austenitic Stainless Steel (CASS) [B.1.31]

XI.M14 Loose Part Monitoring Not applicable XI.M15 Neutron Noise Monitoring Not applicable XI.M16 PWR Vessel Internals Not applicable Flow-Accelerated Corrosion Program XI.M 17 Flow-Accelerated Corrosion[B1.4 [B,.1. 14]

XI.M18 Bolting Integrity Not applicable XI.M19 Steam Generator Tube Integrity Not applicable XI.M20 Open-Cycle Cooling Water Service Water Integrity Program System [B.1.28]

XI.M21 Closed-Cycle Cooling Water Water Chemistry Control - Closed System Cooling Water Program [B.1.32.3]

XI.M22 Boraflex Monitoring Boraflex Monitoring Program [B.1.1]

Appendix B Aging Management Programs and Activities Page B-7

Pilgrim Nuclear Power Station License Renewal Application Technical Information Table B-2 PNPS AMP Correlation with NUREG-1801 Programs (Continued)

NUREG-1801 NUREG-1801 Program PNPS Program Number Inspection of Overhead Heavy XI.M23 Load and Light Load (Related to Not applicable Refueling) Handling Systems XI.M24 Compressed Air Monitoring Not applicable XI.M25 BWR Reactor Water Cleanup Not applicable System XI.M26 Fire Protection Fire Protection Program [B.1.13.1]

XI.M27 Fire Water System Fire Water System Program [B.1.13.21 XI.M28 Buried Piping and Tanks Not applicable Surveillance XI.M29 Aboveground Steel Tanks Not applicable Diesel Fuel Monitoring Program XI.M30 Fuel Oil Chemistry [B,1.10]

XI.M31 Reactor Vessel Surveillance Reactor Vessel Surveillance Program

[B.1.26]

XI.M32 One-Time Inspection One-Time Inspection Program [B.1.23]

XI.M33 Selective Leaching of Materials Selective Leaching Program [B.1.27]

Buried Piping and Tanks Buried Piping and Tanks Inspection Inspection Program [B.1.2]

One-time Inspection of ASME One-Time Inspection Program [B.1.231 XI.M35 Code Class 1 Small-Bore Piping XI.M36 External Surfaces Monitoring System Walkdown Program [B.1.30]

XI.M37 Flux Thimble Tube Inspection Not applicable Appendix B Aging Management Programs and Activities Page B-8

Pilgrim Nuclear Power Station License Renewal Application Technical Information Table B-2 PNPS AMP Correlation with NUREG-1801 Programs (Continued)

NUREG-1801 NUREG-1801 Program PNPS Program Number Inspection of Internal Surfaces in XI.M38 Miscellaneous Piping and Ducting Not applicable Components XI.M39 Lubricating Oil Analysis Oil Analysis Program [B.1.22]

Electrical Cables and Connections XI.E1 Not Subject to 10 CFR 50.49 Non-EQ Insulated Cables and Environmental Qualification Connections Program [B.1.21]

Requirements Electrical Cables and Connections Not Subject to 10 CFIR 50.49 Non-EQ Instrumentation Circuits Test XL.E2 Environmental Qualification Requiemens Usd inReview Program [B.1.20]

Requirements Used in Instrumentation Circuits Inaccessible Medium-Voltage Cables Not Subject to 10 CFR Non-EQ Inaccessible Medium-Voltage 50.49 Environmental Qualification Cable Program [B.1.19]

Requirements Metal-Enclosed Bus Inspection XI.E4 Metal Enclosed Bus Program Porm[..8 [B.1.18]

XI.E5 Fuse Holders Not applicable Electrical Cable Connections Not XI.E6 Subject to 10 CFR 50.49 Environmental Qualification Not applicable Requirements See plant-specific Inservice Inspection XI.S1 ASME Section X1, Subsection IWE - Containment Inservice Inspection (CII) Program [B.1.16.1]

XI.S2 ASME Section XI, Subsection IWL Not applicable Appendix B Aging Management Programs and Activities Page B-9

Pilgrim Nuclear Power Station License Renewal Application Technical Information Table B-2 PNPS AMP Correlation with NUREG-1801 Programs (Continued)

NUREG-1801 NUREG-1801 Program PNPS Program Number See plant-specific Inservice Inspection XI.S3 ASME Section Xl, Subsection IWF - Inservice Inspection (ISI) Program

[B.1.16.2]

xI.s4 10 CFR 50, Appendix J Containment B19 Leak Rate Program

[B. 1. 9]

Structures Monitoring - Masonry Wall Xl.S5 Masonry Wall Program Program [B.1.29.1]

XI.S6 Structures Monitoring Program Structures Monitoring - Structures Monitoring Program [B.1.29.2]

RG 1.127, Inspection of Water- Structures Monitoring - Water Control XI.S7 Control Structures Associated with Structures Monitoring Program Nuclear Power Plants [B.1.29.3]

XI.58 Protective Coating Monitoring and Not applicable I Maintenance Program Plant-Specific Programs Heat Exchanger Monitoring Program NA Plant-specific program [B. 1.15]

Inservice Inspection - Containment NA Plant-specific program Inservice Inspection (CII) Program

[B.1.16.1]

NA Plant-specific program Inservice Inspection - Inservice Inspection (ISI) Program [B.1.16.2]

A"f Instrument Air Quality Program NA Plant-specific program [B. 1.17]

Periodic Surveillance and Preventive NA Plant-specific program Maintenance Program [B.1.24]

NA Plant-specific program Water Systems ProgramControl Chemistry - Auxiliary

[B.1.32.1]

Appendix B Aging Management Programs and Activities Page B-10

Pilgrim Nuclear Power Station License Renewal Application Technical Information PNPS programs have been compared to the NUREG-1801 programs with the results being shown in Table B-3 as programs consistent with NUREG-1 801; programs with enhancements; programs with exception to NUREG-1801; not comparable to NUREG-1 801 (plant-specific)

Table B-3 PNPS Program Consistency with NUREG-1801 NUREG-1801 Comparison Programs Plant PntPrograms Consistent with Programs with Program Name Specific with NUREG- Enhancements Exceptions to Name SNUREG-1801 1801 Boraflex Monitoring Program X Buried Piping and Tanks X Inspection Program BWR CRD Return Line Nozzle X Program BWR Feedwater Nozzle X Program BWR Penetrations Program X BWR Stress Corrosion Cracking X X Program BWR Vessel ID Attachment X Welds Program BWR Vessel Internals Program X X Containment Leak Rate X Program Diesel Fuel Monitoring Program X X Environmental Qualification (EQ) X of Electric Components Program Appendix B Aging Management Programs and Activities Page B-11

Pilgrim Nuclear Power Station License Renewal Application Technical Information Table B-3 PNPS Program Consistency with NUREG-1801 (Continued)

NUREG-1801 Comparison Programs Consistent Programs Plant Programs with with Program Name Specific with Enhancements Exceptions to NUREG- NUREG-1801 1801 Fatigue Monitoring Program X Fire Protection - Fire Protection X X Program Fire Protection - Fire Water X X System Program Flow-Accelerated Corrosion X Program Heat Exchanger Monitoring X Program Inservice Inspection - X Containment Inservice Inspection (CII) Program Inservice Inspection - Inservice X Inspection (ISI) Program Instrument Air Quality Program X Metal-Enclosed Bus Inspection X Program Non-EQ Inaccessible Medium- X Voltage Cable Program Non-EQ Instrumentation Circuits X Test Review Program Non-EQ Insulated Cables and X Connections Program Oil Analysis Program X X One-Time Inspection Program X Appendix B Aging Management Programs and Activities Page B-12

Pilgrim Nuclear Power Station License Renewal Application Technical Information Table B-3 PNPS Program Consistency with NUREG-1801 (Continued)

NUREG-1801 Comparison Programs Programs Plant Consistent Programs with with Program Name Specific with Enhancements Exceptions to NUREG- NUREG-1801 1801 Periodic Surveillance and X Preventive Maintenance Program Reactor Head Closure Studs X Program Reactor Vessel Surveillance X X Program Selective Leaching Program X Service Water Integrity Program X Structures'Monitoring - Masonry X Wall Program Structures Monitoring - X X Structures Monitoring Program Structures Monitoring - Water X X Control Structures Monitoring Program System Walkdown Program X Thermal Aging and Neutron X Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program Water Chemistry Control - X Auxiliary Systems Program Water Chemistry Control - BWR X Program Appendix B Aging Management Programs and Activities Page B-13

Pilgrim Nuclear Power Station License Renewal Application Technical Information Table B-3 PNPS Program Consistency with NUREG-1801 (Continued)

NUREG-1801 Comparison Programs Programs Plant Consistent Programs with with Program Name Specific with Enhancements Exceptions to NUREG- NUREG-1801 1801 Water Chemistry Control - X Closed Cooling Water Program Page B-14 and Activities Appendix B Appendix B Aging Management Programs Aging Management Programs and Activities Page B-14

Pilgrim Nuclear Power Station License Renewal Application Technical Information B.1.2 BURIED PIPING AND TANKS INSPECTION Program Description The Buried Piping and Tanks Inspection Program at PNPS is comparable to the program described in NUREG-1801,Section XI.M34, Buried Piping and Tanks Inspection.

This program includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel, stainless steel, and titanium components. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance.

A focused inspection will be performed within the first 10 years of the period of extended operation, unless an opportunistic inspection (or an inspection via a method that allows assessment of pipe condition without excavation) occurs within this ten-year period.

NUREG-1801 Consistency The Buried Piping and Tanks Inspection Program at PNPS will be consistent with program attributes described in NUREG-1801,Section XI.M34, Buried Piping and Tanks Inspection, with one exception.

Exceptions to NUREG-1801 The Buried Piping and.Tanks Inspection Program at PNPS will be consistent with program attributes described in NUREG-1801,Section XI.M34, Buried Piping and Tanks Inspection, with the following exception.

Attributes Affected Exception

4. Detection of Aging Effects Inspections via methods that allow assessment of pipe condition without excavation may be substituted for inspections requiring excavation solely for 1

the purpose of inspection.

Exception Note

1. Methods such as phased array UT technology provide indication of wall thickness for buried piping without excavation. Use of such methods to identify the effects of aging is preferable to excavation for visual inspection, which could result in damage to coating or wrappings.

Appendix B Aging Management Programs and Activities Page B-17

Pilgrim Nuclear Power Station License Renewal Application Technical Information Enhancements None Operating Experience The Buried Piping and Tanks Inspection Program at PNPS is a new program for which there is no operating experience.

Conclusion Implementation of the Buried Piping and Tanks Inspection Program will provide reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Appendix B Aging Management Programs and Activities ,Page B-1 8

Pilgrim Nuclear Power Station License Renewal Application Technical Information B.1.16 INSERVICE INSPECTION Regulation 10 CFR 50.55a, imposes inservice inspection (ISI) requirements of ASME Code,Section XI, for Class 1, 2, and 3 pressure-retaining components, their integral attachments, and supports in light-water cooled power plants. Inspection, repair, and replacement of these components are covered in Subsections IWB, IWC, IWD, and IWF respectively. The program includes periodic visual, surface, and volumetric examination and leakage tests of Class 1, 2, and 3 pressure-retaining components, their integral attachments and supports.

Inservice inspection of supports for ASME piping and components is addressed in Section XI, Subsection IWF. ASME Code Section XI, Subsection IWF constitutes an existing mandated program applicable to managing aging of ASME Class 1, 2, 3, and MC supports for license renewal.

Additionally, 10 CFR 50.55a imposes inservice inspection requirements of ASME Code Section Xl for class MC and class CC containment structures. Subsection IWE contains inspection requirements for class MC metal containments and class CC concrete containments. The scope of IWE includes steel liners for concrete containment and their integral attachments; containment hatches and airlocks; moisture barriers; and pressure-retaining bolting.

The program uses nondestructive examination (NDE) techniques to detect and characterize flaws. Three different types of examinations are volumetric, surface, and visual. Volumetric examinations are the most extensive, using methods such as radiographic, ultrasonic or eddy current examinations to locate surface and subsurface flaws. Surface examinations, such as magnetic particle or dye penetrant testing, are used to locate surface flaws.

Three levels of visual examinations are specified. VT-1 visual examination is conducted to assess condition of the surface of the part being examined, looking for cracks and symptoms of wear, corrosion, erosion or physical damage. It can be done with either direct visual observation or with remote examination using various optical/video devices. The VT-2 examination is conducted specifically to locate evidence of leakage from pressure retaining components (period pressure tests). While the system is under pressure for a leakage test, visual examinations are conducted to detect direct or indirect indication of leakage. The VT-3 examination is conducted to determine the general mechanical and structural condition of components and supports and to detect discontinuities and imperfections. For containment inservice inspection, general visual and detailed visual examinations are used in addition to VT examinations as allowed by 10 CFR 50.55a to include applicable relief requests.

The inservice inspection programs are discussed in more detail in the following subsections

• Containment Inservice Inspection (CII)

Iinservice Inspection (ISI)

Appendix B Aging Management Programs and Activities Page B-55

Pilgrim Nuclear Power Station License Renewal Application Technical Information B.1.16.2 INSERVICE INSPECTION Program Description The PNPS Inservice Inspection (ISI) Program is a plant-specific program encompassing ASME Section XI, Subsections IWA, IWB, IWC, IWD and IWF requirements.

The ISI Program is based on ASME Inspection Program B (IWA-2432), which has 10-year inspection intervals. Every 10 years the program is updated to the latest ASME Section Xl code edition and addendum approved by the NRC in 10 CFR 50.55a. On July 1, 2005 PNPS entered the fourth ISI interval. The ASME code edition and addenda used for the fourth interval is the 1998 Edition with 2000 Addenda. The current program ensures that the structural integrity of Class 1, 2, and 3 systems and associated supports is maintained at the level required by 10 CFR 50.55a.

Evaluation

1. Scope of Program The ISI Program manages cracking, loss of material, and reduction of fracture toughness of reactor coolant system piping, components, and supports. The program implements applicable requirements of ASME Section XI, Subsections IWA, IWB, IWC, IWD and IWF, and other requirements specified in 10 CFR 50.55a with approved NRC alternatives and relief requests. Every 10 years the ISI Program is updated to the latest ASME Section XI code edition and addendum approved by the NRC in 10 CFR 50.55a.

ASME Section XI inspection requirements for Reactor Vessel Internals (Subsection IWB, Categories B-N-1 and B-N-2) are not in the ISI Program, but are included in the BWR Vessel Internals Program.

2. Preventive Actions The ISI Program is a condition monitoring program that does not include preventive actions.

3. Parameters Monitored/Inspected The program uses nondestructive examination (NDE) techniques to detect and characterize flaws. Volumetric examinations such as radiographic, ultrasonic or eddy current examinations are used to locate surface and subsurface flaws. Surface examinations, such as magnetic particle or dye penetrant testing, are used to locate surface flaws.

Appendix B Aging Management Programs and Activities Page B-59

Pilgrim Nuclear Power Station License Renewal Application Technical Information Three levels of visual examinations are specified. VT-1 visual examination is conducted to assess the condition of the surface of the part being examined, looking for cracks and symptoms of wear, corrosion, erosion or physical damage. It can be done with either direct visual observation or with remote examination using various optical and video devices. VT-2 visual examination is conducted specifically to locate evidence of leakage from pressure retaining components (period pressure tests).

While the system is under pressure for a leakage test, visual examinations are conducted to detect direct or indirect indication of leakage. VT-3 visual examination is conducted to determine general mechanical and structural condition of components and supports and to detect discontinuities and imperfections.

4. Detection of Aging Effects The ISI Program manages cracking and loss of material, as applicable, for carbon steel, low alloy steel and stainless steel/nickel based alloy subcomponents of the reactor pressure vessel using NDE techniques specified in ASME Section XI, Subsections IWB, IWC, and IWD examination categories.

The ISI Program manages cracking, loss of material, and reduction of fracture toughness, as applicable, of reactor coolant system components using NDE techniques specified in ASME Section XI, Subsections IWB, IWC and IWD examination categories.

The ISI Program manages loss of material for ASME Class MC and Class 1, 2, and 3 piping and component supports and their anchorages by visual examination of components using NDE techniques specified in ASME Section XI, Subsection IWF examination categories.

No aging effects requiring management are identified for lubrite sliding supports.

However, the ISI Program will confirm the absence of aging effects for the period of extended operation.

5. Monitoring and Trending Results are compared, as appropriate, to baseline data and other previous test results. If indications are accepted for continued use by analytical evaluation, the areas containing such flaws are monitored during successive inspection periods.

ISI results are recorded every operating cycle and provided to the NRC after each refueling outage via Owner's Activity Reports prepared by the ISI Program Coordinator. These detailed reports include scope of inspection and significant inspection results.

Appendix B Aging Management Programs and Activities Page B-60

Pilgrim Nuclear Power Station License Renewal Application Technical Information

6. Acceptance Criteria A preservice, or baseline, inspection of program components Was performed prior to startup to assure freedom from defects greater than code-allowable. This baseline data also provides a basis for evaluating subsequent inservice inspection results.

Since plant startup, additional inspection criteria for Class 2 and 3 components have been imposed by 10 CFR 50.55a for which baseline and inservice data has also been obtained. Results of inservice inspections are compared, as appropriate, to baseline data, other previous test results, and acceptance criteria of the ASME Section XI, 1998 Edition, 2000 Addenda, for evaluation of any evidence of degradation.

7. Corrective Actions If a flaw is discovered during an ISI examination, an evaluation is conducted in accordance with articles IWA-3000 and IWB-3000, IWC-3000, IWD-3000 or IWF-3000 as appropriate. If flaws exceed acceptance standards, such flaws are removed, repaired, or the component is replaced prior to its return to service. For Class 1, 2, and 3, repair and replacement is in conformance with IWA-4000. Acceptance of flaws which exceed acceptance criteria may be accomplished through analytical evaluation without repair, removal or replacement of the flawed component if the evaluation meets the criteria specified in the applicable article of the code.

8. Confirmation Process This attribute is discussed in Section B.0.3.

9. Administrative Controls This attribute is discussed in Section B.0.3.

10. Operating Experience Intergranular stress corrosion cracking was discovered during RFOO6 in the thermal sleeve at nine of the ten recirculation supply nozzles. GE has performed an evaluation to demonstrate no further crack growth with hydrogen water chemistry protection.

A scheduled ISI surface examination in 1997 detected an indication adjacent to a welded pipe support lug. The lug was removed and the indication was repaired by welding. A scheduled ISI visual examination in 1999 detected a snubber with restricted movement and cold piston setting out of tolerance. The restriction was re-worked and the cold piston setting was accepted by evaluation. Identification of degradation and corrective action prior to loss of intended function provide evidence that the program is effective for managing aging effects.

Appendix B Aging Management Programs and Activities Page B-61

Pilgrim Nuclear Power Station License Renewal Application Technical Information 142 scheduled ISI (ASME Section XI Subsections IWB, IWC, IWD, and IWF) examinations were performed on-line (between RFO13 and RFO14) and during RFO14 (April 2003). Results show that one spring hanger support in the residual heat removal system required rework because ISI visual inspection determined that bolting was loose. Identification of degradation and corrective action prior to loss of intended function provide evidence that the program is effective for managing aging effects.

194 scheduled ISI (ASME Section XI Subsections IWB, IWC, IWD, and IWF) examinations were performed on-line (between RFO14 and RFO15) and during RFO1 5 (April 2005). Results show that cracked welds on four steam dryer tie-bars were repaired, loose bolting on a hanger was reworked, a UT exam indication on a standby liquid control system weld was repaired, and a number of RPV safe-end welds were accepted by evaluation because they had wall thickness less than the screening criteria, but not less than design minimums. Identification of degradation and corrective action prior to loss of intended function provide evidence that the program is effective for managing aging effects.

A QA audit and an NRC inspection in spring 2005 revealed no issues or findings that could impact effectiveness of the program.

Conclusion The ISI Program has been effective at managing aging effects. The ISI Program provides reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

Appendix B Aging Management Programs and Activities Page B-62

Pilgrim Nuclear Power Station License Renewal Application Technical Information B.1.23 ONE-TIME INSPECTION Program Description The One-Time Inspection Program at PNPS is a new program that will be implemented prior to the period of extended operation. The program will be comparable to the program described in NUREG-1801,Section XI.M32, One-Time Inspection. The one-time inspection activity for small bore piping in the reactor coolant system and associated systems that form the reactor coolant pressure boundary, will also be comparable to the program described in NUREG-1801,Section XI.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping. The PNPS program will be consistent with the program elements described in NUREG-1801.

The program will include one activity to verify effectiveness of an aging management program and activities to confirm the absence of aging effects as described below.

Water chemistry control programs One-time inspection activity will verify the effectiveness of the water chemistry control aging management programs by confirming that unacceptable cracking, loss of material, and fouling is not occurring.

Internal surfaces of buried carbon steel One-time inspection activity will confirm pipe on the standby gas treatment system that loss of material is not occurring or is so discharge to the stack insignificant that an aging management program is not warranted.

Internal surfaces of compressed air and One-time inspection activity will confirm emergency diesel generator system that cracking (EDG system) and loss of components containing untreated air material (compressed air and EDG systems) are not occurring or are so insignificant that an aging management program is not warranted.

Internal surfaces of stainless steel, One-time inspection activity will confirm radioactive waste and sanitary soiled that loss of material is not occurring or is so waste and vent system components insignificant that an aging management containing untreated water program is not warranted.

Small bore piping in the reactor coolant One-time inspection activity will confirm system and associated systems that form that cracking and reduction of fracture the reactor coolant pressure boundary toughness are not occurring or are so insignificant that an aging management program is not warranted.

Appendix B Aging Management Programs and Activities Page B-76

Pilgrim Nuclear Power Station License Renewal Application Technical Information RV flange leakoff line One-time inspection activity will confirm that cracking is not occurring or is so insignificant that an aging management program is not warranted.

Main steam flow restrictors (CASS) One-time inspection activity will confirm that loss of material, cracking, and reduction of fracture toughness are not occurring or are so insignificant that an aging management program is not warranted.

The elements of the program include (a) determination of the sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience; (b) identification of the inspection locations in the system or component based on the aging effect; (c) determination of the examination technique, including acceptance criteria that would be effective in managing the aging effect for which the component is examined; and (d) evaluation of the need for follow-up examinations to monitor the progression of any aging degradation.

When evidence of an aging effect is revealed by a one-time inspection, routine evaluation of the inspection results will identify appropriate corrective actions.

The inspection will be performed within the 10 years prior to the period of extended operation.

NUREG-1801 Consistency The One-Time Inspection Program will be consistent with the program described in NUREG-1801,Section XI.M32, One-Time Inspection. The one-time inspection activity for small bore piping in the reactor coolant system and associated systems that form the reactor coolant pressure boundary, will also be consistent with the program described in NUREG-1 801,Section XI.M35, One-Time Inspection of ASME Code Class I Small-Bore Piping.

Exceptions to NUREG-1801 None Enhancements None Appendix B Aging Management Programs and Activities Page B-77

Pilgrim Nuclear Power Station License Renewal Application Technical Information Onerating Experience The One-Time Inspection Program is a new program for which there is no operating experience.

Industry and plant-specific operating experience will be considered in development of this program, as appropriate.

Conclusion Verification of the effectiveness of the Water Chemistry Control programs and confirmation of the absence of aging effects on specific standby gas treatment, compressed air, emergency diesel generator, radioactive waste, sanitary soiled waste and vent, and reactor coolant system components will be undertaken in the One-Time Inspection Program to ensure component intended functions can be maintained in accordance with the current licensing basis (CLB) during the period of extended operation.

Appendix B Aging Management Programs and Activities Page B-78

Pilgrim Nuclear Power Station License Renewal Application Technical Information B.1.28 SERVICE WATER INTEGRITY Program Description The Service Water Integrity Program at PNPS is comparable to the program described in NUREG-1801,Section XI.M20, Open-Cycle Cooling Water System.

This program relies on implementation of the recommendations of GL 89-13 to ensure that the effects of aging on the salt service water (SSW) system are managed for the period of extended operation. The program includes surveillance and control techniques to manage aging effects caused by biofouling, corrosion, erosion, protective coating failures, and silting in the SSW system or structures and components serviced by the SSW system.

NUREG-1801 Consistency The Service Water Integrity Program at PNPS is consistent with the program described in NUREG-1801,Section XI.M20, Open-Cycle Cooling Water System with exceptions.

ExceDtions to NUREG-1801 The Service Water Integrity Program at PNPS is consistent with the program described in NUREG-1801,Section XI.M20, Open-Cycle Cooling Water System with the following exceptions.

Attributes Affected Exceptions

2. Preventive Actions NUREG-1 801 states that system components are lined or coated.

Components are lined or coated only where necessary to protect the underlying metal 1

• surfaces.

5. Monitoring and Trending NUREG-1801 states that testing and inspections are performed annually and during refueling outages. The PNPS program requires tests and inspections 2

each refueling outage.

Exception Notes

1. NUREG-1801 states that system components are constructed of appropriate materials and lined or coated to protect the underlying metal surfaces from being exposed to aggressive cooling water environments. Not all PNPS system components are lined or coated. Components are lined or coated only where necessary to protect the underlying metal surfaces.

Appendix B Aging Management Programs and Activities Page B-92

Pilgrim Nuclear Power Station License Renewal Application Technical Information

2. NUREG-1801 program entails testing and inspections performed annually and during refueling outages. The PNPS program requires tests and inspections each refueling outage, but not annually. Since aging effects are typically manifested over several years, the difference in inspection and testing frequency is insignificant.

Enhancements None Operating Experience Results of heat transfer capability testing of the reactor building closed cooling water (RBCCW) heat exchangers from 2001 through 2004 show that the heat exchangers are capable of removing the required amount of heat. Confirmation of adequate thermal performance provides evidence that the program is effective for managing fouling of SSW cooled heat exchangers.

Results of SSW visual inspections, eddy current testing, ultrasonic testing, and radiography testing from 1998 through 2004 revealed areas of erosion and areas of corrosion on internal and external surfaces. SSW butterfly valves, pump discharge check valves, air removal valves, and pipe spools have been replaced with components made of corrosion resistant materials. Also, RBCCW heat exchanger channel assemblies have been replaced and tubes have been sleeved to address erosion and corrosion. Identification of degradation and corrective action prior to loss of intended function provide evidence that the program is effective for managing loss of material for SSW system components.

Visual inspections of SSW piping revealed degradation of the lining in original SSW carbon steel rubber lined piping. Pipe lining is intended to protect pipe internal surfaces from erosion and corrosion. Therefore, SSW piping has been replaced with carbon steel pipe with cured-in-place rubber lining, relined with a ceramic epoxy compound, or replaced with titanium pipe.

Identification of degradation and corrective action prior to loss of intended function provide evidence that the program is effective for managing loss of material for SSW system components.

Conclusion The Service Water Integrity Program has been effective at managing aging effects. The Service Water Integrity Program provides reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended function consistent with the current licensing basis for the period of extended operation.

Appendix B Aging Management Programs and Activities Page B-93

Pilgrim Nuclear Power Station License Renewal Application Technical Information Conclusion The Water Chemistry Control - Auxiliary Systems Program has been effective at managing loss of material for components exposed to treated water. The Water Chemistry Control - Auxiliary Systems Program provides reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

B.1.32.2 WATER CHEMISTRY CONTROL - BWR Program Description The Water Chemistry Control - BWR Program at PNPS is comparable to the program described in NUREG-1801,Section XI.M2, Water Chemistry.

The objective of this program is to manage aging effects caused by corrosion and cracking mechanisms. The program relies on monitoring and control of water chemistry based on EPRI Report 1008192 (BWRVIP-130). BWRVIP-130 has three sets of guidelines: one for primary water, one for condensate and feedwater, and one for control rod drive (CRD) mechanism cooling water. EPRI guidelines in BWRVIP-130 also include recommendations for controlling water chemistry in the torus, condensate storage tanks, demineralized water storage tanks, and spent fuel pool.

The Water Chemistry Control - BWR Program optimizes the primary water chemistry to minimize the potential for loss of material and cracking. This is accomplished by limiting the levels of contaminants in the RCS that could cause loss of material and cracking. Additionally, PNPS has instituted hydrogen water chemistry (HWC) to limit the potential for IGSCC through the reduction of dissolved oxygen in the treated water.

NUREG-1801 Consistency The Water Chemistry Control - BWR Program is consistent with the program described in NUREG-1801,Section XI.M2, Water Chemistry.

Exceptions to NUREG-1801 None Enhancements None Appendix B Aging Management Programs and Activities Page B-1 05

Pilgrim Nuclear Power Station License Renewal Application Technical Information Operating Experience During the period from 1998 through 2004, several condition reports were initiated due to adverse trends in parameters monitored by the Water Chemistry Control - BWR Program.

Corrective actions were taken within the Corrective Action Program to preclude reaching unacceptable values for the parameters. Continuous confirmation of water quality and corrective action prior to reaching control limits provide evidence that the program is effective in managing aging effects for applicable components.

During the period from 1998 through 2004, several condition reports were initiated due to parameters monitored by the Water Chemistry Control - BWR Program outside of administrative limits, but still within EPRI acceptance criteria. Corrective actions were taken within the Corrective Action Program to preclude violating EPRI acceptance criteria. Continuous confirmation of water quality and corrective action prior to reaching control limits provide evidence that the program is effective in managing aging effects for applicable components.

During the period from 1998 through 2004, the following two incidents were found in which parameters monitored by the Water Chemistry Control - BWR Program were outside of EPRI acceptance criteria.

Following a downpower on March 29, 2002, dissolved oxygen measurement from the B high pressure feedwater (HPFW) train was -28 ppb, below the minimum required reading of 30 ppb (EPRI action level 1). Dissolved oxygen measured from the A HPFW train and condensate demineralizer effluent (CDE) were acceptable (- 70 to 80 ppb). Root cause was B HPFW sample line contamination, not actual low oxygen in the feedwater. The B HPFW sample line was replaced.

On October 28, 2002, HPFW and CDE dissolved oxygen levels spiked to 400 to 500 ppb for about 15 minutes before returning to normal. EPRI action level 1 for HPFW dissolved oxygen is 200 ppb. Root cause was determined to be inadequate filling of the D demineralizer prior to its return to service. The procedure states, "It is EXTREMELY important that all air is vented from a Cond Demin before it is placed in service to prevent air injection into the Feedwater System." Procedural steps were emphasized that will insure proper venting and mitigate elevated oxygen levels in the feedwater system.

Continuous confirmation of water quality and timely corrective action provide.evidence that the program is effective in managing aging effects for applicable components.

QA audits in 2000 and 2002 revealed no issues or findings that could impact effectiveness of the program.

A QA audit in 2004 revealed that reactor coolant sodium and lithium analyses were not being performed weekly during the first half of 2004. Corrective action was taken to replace the analysis instrument and ensure required analyses are performed. Confirmation of water quality Appendix B Aging Management Programs and Activities Page B-106

Pilgrim Nuclear Power Station License Renewal Application Technical Information and timely corrective actions provide evidence that the program is effective in managing aging effects for applicable components.

A corporate assessment in 2003 identified areas for improvement in administrative controls, but revealed no issues or findings that could impact effectiveness of the program.

Conclusion The Water Chemistry Control - BWR Program has been effective at managing aging effects.

The Water Chemistry Control - BWR Program at PNPS provides reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

B.1.32.3 WATER CHEMISTRY CONTROL - CLOSED COOLING WATER Progqram Description The Water Chemistry Control - Closed Cooling Water Program at PNPS is comparable to the program described in NUREG-1801,Section XI.M21, Closed-Cycle Cooling Water System.

This program includes preventive measures that manage loss of material, cracking, and fouling for components in closed cooling water systems (reactor building closed cooling water, turbine building closed cooling water, emergency diesel generator cooling water, station blackout diesel cooling water, security diesel generator cooling water, and plant heating). These chemistry activities provide for monitoring and controlling closed cooling water chemistry using PNPS procedures and processes based on EPRI guidance for closed cooling water chemistry.

NUREG-1801 Consistency The Water Chemistry Control - Closed Cooling Water Program is consistent with the program described in NUREG-1 801,Section XI.M21, Closed-Cycle Cooling Water System, with one exception.

Exceptions to NUREG-11801 The Water Chemistry Control - Closed Cooling Water Program is consistent with the program described in NUREG-1801,Section XI.M21, Closed-Cycle Cooling Water System, with the following exception.

Attributes Affected Exception

4. Detection of Aging Effects The PNPS Water Chemistry Control -

Closed Cooling Water Program does not 1

include performance and functional testing.

Appendix B Aging Management Programs and Activities Page B-107