ML042300153

Section 3.5, Aging Management of Structures and Component Supports - ANO-2 SER Final W/Open and Confirmatory Items

ML042300153
Person / Time
Site:	Arkansas Nuclear
Issue date:	09/01/2004
From:	Gregory Cranston NRC/NRR/DRIP/RLEP
To:	Gregory Suber NRC/NRR/DRIP/RLEP
Cranston G, NRR/DRIP/RLEP, 415-2073
Shared Package
ML042260383	List: ML042300068 ML042300091 ML042300128 ML042300134 ML042300148 ML042300153 ML042300157
References
TAC MC1010
Download: ML042300153 (24)

Text

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS 3.5 Aging Management of Structures and Component Supports This section of the SER documents the staffs review of the applicants AMR results for the structures and component supports and commodity groups associated with the following structures:

C containment and containment internals C auxiliary building, turbine building, and yard structures C intake structure and emergency cooling pond C bulk commodities 3.5.1 Summary of Technical Information in the Application In Section 3.5 of the LRA, the applicant provided the results of the aging management review of the structures and component supports components and component types listed in Tables 2.4-1 through 2.4-4 of the LRA. The applicant also listed the materials, environments, aging effects requiring management, and aging management programs associated with each structure and component support type.

In Table 3.5.1, Summary of the Aging Management Programs for Structures and Component Supports Evaluated in Chapters II and III of NUREG-1801, of the LRA, the applicant provided a summary comparison of its AMRs with the AMRs evaluated in the GALL Report for the structures and component supports. In Section 3.5.2.2 of the LRA, the applicant provided information concerning Table 3.5.1 components for which further evaluation is recommended by the GALL Report.

3.5.2 Staff Evaluation The staff reviewed Section 3.5 of the LRA to understand the applicants review process and to determine whether the applicant provided sufficient information to demonstrate that the effects of aging for the structures and component supports that are within the scope of license renewal and subject to an AMR will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

The staff performed an audit and review to confirm the applicants claim that certain identified AMRs are consistent with the staff-approved AMRs in the GALL Report. The staff did not repeat its review of the matters described in the GALL Report. However, the staff did verify that the material presented in the LRA was applicable and that the applicant had identified the appropriate GALL AMRs. The staffs audit and review findings are summarized in Section 3.5.2.1 of this SER.

The staff also audited those AMRs that are consistent with the GALL Report and for which further evaluation is recommended. The staff verified that the applicants further evaluations were consistent with the acceptance criteria in Section 3.5.3.2 of NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, (SRP-LR).

The staffs audit and review findings are summarized in Section 3.5.2.2 of this SER.

3.5-1

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS The staff conducted a technical review of the remaining AMRs that are not consistent with the GALL Report. The review included evaluating whether all plausible aging effects were identified and whether the aging effects listed were appropriate for the combination of materials and environments specified. The staffs review findings are documented in the Section 3.5.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the UFSAR Supplement to ensure that they provide an adequate description of the programs credited with managing or monitoring aging for the structures and component supports.

The staff's review of the structures and component supports followed one of several approaches. One approach, documented in Section 3.5.2.1 of this SER, involves the staff's review of the AMR results for components in the structures and commodities that the applicant indicated are consistent with the GALL Report and do not require further evaluation. Another approach, documented in Section 3.5.2.2, involves the staff's review of the AMR results for components in the structures and commodities that the applicant indicated are consistent with the GALL Report and for which further evaluation is recommended. A third approach, documented in Section 3.5.2.3, involves the staff's review of the AMR results for components in the structures and commodities that the applicant indicated are not consistent with the GALL Report or are not addressed in the GALL Report. The staff's review of AMPs that are credited to manage or monitor aging effects of the structures and component supports is documented in Section 3.0.3 of this SER.

3.5.2.1 Aging Management Evaluations that are Consistent With the GALL Report, for Which No Further Evaluation is Required Summary of Technical Information in the Application In Section 3.5.2.1 of the LRA, the applicant identified the materials, environments, and aging effects requiring management. The applicant identified the following programs that manage the aging effects related to the structures and component supports components:

C Boric Acid Corrosion Prevention Program C Containment Leak Rate Program C Inservice Inspection - Containment Inservice Inspection (IWE and IWL) Program C Inservice Inspection (IWF) Program C Structures Monitoring Program C Structures Monitoring - Masonry Wall Program C Water Chemistry Control Program C Service Water Integrity Program C Periodic Surveillance and Preventive Maintenance Program C Fire Protection Program Staff Evaluation In Tables 3.5.2-1 through 3.5.2-4 of the LRA, the applicant provided a summary of AMRs for the containment and containment internals, auxiliary building, turbine building and yard structures, intake structure and emergency cooling pond, and bulk commodities components 3.5-2

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS and identified which AMRs it considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report does not recommend further evaluation, the staff performed an audit and review to determine whether the plant-specific components contained in these GALL Report component groups were bounded by the GALL Report evaluation The applicant provided a note for each AMR line item. The notes described how the information in the tables aligns with the information in the GALL Report. The staff audited those AMRs with Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP is consistent with the AMP identified in the GALL Report. The staff audited these line items to verify consistency with the GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify consistency with the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff also determined whether the AMP identified by the applicant was consistent with the AMP identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different, but consistent with the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent with the AMP identified by the GALL Report. This note indicates that the applicant was unable to find a listing of some system components in the GALL Report. However, the applicant identified a different component in the GALL Report that had the same material, environment, aging effect, and AMP as the component that was under review. The staff audited these line items to verify consistency with the GALL Report. The staff also determined whether the AMR line item of the different component was applicable to the component under review and whether the AMR was valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different, but consistent with the GALL Report for material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify consistency with the GALL Report. The staff verified whether the AMR line item of the different component was applicable to the component under review. The staff verified whether the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff also determined whether the AMP identified by the applicant was consistent with the AMP identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material, environment, and aging effect, but a different aging management program is credited. The staff audited these line items to verify consistency with the GALL Report. The staff also determined whether the identified AMP would manage the aging effect consistent with the AMP 3.5-3

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS identified by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review to confirm the applicants claim that certain identified AMRs are consistent with the staff-approved AMRs in the GALL Report. The staff reviewed the information provided in the LRA and program bases documents, which were available at the applicants engineering office. The staff did not repeat its review of the matters described in the GALL Report. However, the staff did verify that the material presented in the LRA was applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff evaluation is discussed below.

3.5.2.1.1 Structures and Components Supports, Containment and Containment Internals The staff reviewed The staff reviewed Table 3.5.1, Item 3.5.1-3 of the LRA, and associated AMRs consistent with the GALL Report.

In Table 3.5.2-1 of the LRA, the applicant associated the incorrect Table 3.5.1 Item Number 3.5.1-3 for loss of material of carbon steel tendon anchorage and the tendon wires component type (page 3.5-27). The staff requested that the applicant revise the LRA Table 3.5.2-1 line entry with the correct Table 3.5.1 item number.

By letter dated March 24, 2004, the applicant submitted a clarification to reference the correct Table 3.5.1, Item Number 3.5.1-15, to anchorage and tendon wires. The applicant also submitted a clarification that Table 3.5.1, Item Number 3.5.1-15 (LRA page 3.5-17) should credit the inservice inspection (IWL) program rather than the inservice inspection (IWE) program in the discussion column.

The staff reviewed the inservice inspection - containment inservice inspection program (AMP B.1.13) and determined that containment anchorage and tendon wires are managed by the ASME Section XI, Subsection IWL program. On the basis of its review, the staff concludes that this line item is acceptable.

3.5.2.1.2 Structures and Components Supports, Bulk Commodities In Table 3.5.2-4 (page 3.5-38) of the LRA, the applicant associated component type HVAC missile barrier with the GALL Report, Volume 2, Chapter III.A2.2-a. The staff requested that the applicant revise the LRA Table 3.5.2-4 line entry with the correct GALL Report, Volume 2, item number.

By letter dated March 24, 2004, the applicant submitted a clarification to reference the correct GALL Report, Volume 2, Item Number III.A3.2-a.

The staff reviewed the GALL Report ,Volume 2, Item Number III.A3.2-a and determined that the HVAC missile barrier component group should reference the GALL Report ,Volume 2, Chapter III for Group 3 structures rather than Chapter II, Group 2 structures. On this basis, the staff concludes that this line item is acceptable.

On the basis of its audit and review, the staff concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended function(s) will be 3.5-4

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

Staff RAIs Pertaining to Recent Operating Experience and Emerging Issues Because the GALL Report and SRP-LR were issued in July 2001, these documents do not reflect the most current recommendations for managing certain aging effects that have been the subject of recent operating experience or the topic of an emerging issue. As a result, the staff issued RAIs to determine how the applicant proposed to address these items for license renewal. The applicants responses to these RAIs, and the staffs evaluations of the responses, are documented as follows.

< Evaluation To Be Provided by DE/EMEB >

Conclusion The staff has verified the applicants claim of consistency with GALL Report. The staff also has reviewed information pertaining to the applicants consideration of recent operating experience and proposals for managing associated aging effects. On the basis of its review, the staff finds that the AMR results, which the applicant claimed to be consistent with the GALL Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds that the applicant has demonstrated that the effects of aging for these components will be adequately managed so that their intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.5.2.2 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Recommended In Section 3.5.2.2 of the LRA, the applicant provided further evaluation of aging management as recommended by the GALL Report for structures and component supports. The applicant provided information concerning how it will manage the following aging effects:

C (PWR containments) aging of inaccessible concrete areas C (PWR containments) cracking, distortion, and increase in component stress levels due to settlement; reduction of foundation strength due to erosion of porous concrete subfoundations, if not covered by structures monitoring program C (PWR containments) reduction of strength and modulus of concrete structures due to elevated temperature C (PWR containments) loss of material due to corrosion in inaccessible areas of steel containment shell or liner plate C (PWR containments) loss of prestress due to relaxation, shrinkage, creep, and elevated temperature C (PWR containments) cumulative fatigue damage C (PWR containments) cracking due to cyclic loading and SCC C (Class I structures) aging of structures not covered by structures monitoring program C (Class I structures) aging management of inaccessible areas C (component supports) aging of supports not covered by structures monitoring program C (component supports) cumulative fatigue damage due to cyclic loading 3.5-5

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS C quality assurance for aging management of non-safety-related components Staff Evaluation For component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report recommends further evaluation, the staff reviewed the applicants evaluation to determine whether it adequately addressed the issues that were further evaluated. In addition, the staff reviewed the applicants further evaluations against the criteria contained in Section 3.5.2.2 of the SRP-LR. Details of the staffs audit and review are documented in the staffs audit and review report.

The GALL Report indicates that further evaluation should be performed for the aging effects described in the following sections of this SER.

3.5.2.2.1 PWR Containments The staff reviewed Section 3.5.2.2.1 of the LRA against the criteria in Section 3.5.2.2.1 of the SRP-LR, which addresses several areas discussed below.

3.5.2.2.1.1 Aging of Inaccessible Concrete Areas In Section 3.5.2.2.1.1 of the LRA, the applicant addressed aging of inaccessible concrete areas for the containment.

For inaccessible portions of the containment structure, 10 CFR 50.55a(b)(2)(ix) requires that the licensee evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to inaccessible areas.

The AMP recommended by the GALL Report for managing the aging of the accessible portions of the containment structures is the GALL AMP XI.S2, ASME Section XI, Subsection IWL.

The applicant addressed this with LRA AMP B.1.13, Inservice Inspection - Containment Inservice Inspection which is evaluated in Section 3.0.3.3.4 of this SER. Subsection IWL exempts from examination those portions of the concrete containment that are inaccessible (e.g., foundation, below-grade exterior walls, or concrete covered by liner).

The applicant also credited the structures monitoring - structures monitoring program (AMP B.1.27), where accessible areas are monitored for evidence of aging effects that may be applicable to containment structures. This program, which is consistent with GALL AMP XI.S6, Structures Monitoring Program, is evaluated in Section 3.0.3.1 of this SER. It is also used for the examination of below-grade concrete when it is exposed by excavation.

In the GALL Report, Volume 2, Chapter II, Table A1 (as modified by ISG-3), further evaluation is recommended to manage the aging effects for containment concrete components located in inaccessible areas if the aging mechanisms of (1) freeze-thaw, (2) leaching of calcium hydroxide, (3) aggressive chemical attack, (4) reaction with aggregates, or (5) corrosion of embedded steel are significant. Possible aging effects for containment concrete structural components due to these five aging mechanisms are cracking, change in material properties, and loss of material.

3.5-6

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS (1) Freeze-thaw Section 3.5.2.2.1.1 of the SRP-LR does not address freeze-thaw as an aging mechanism for concrete containments because no further evaluation is recommended in the GALL Report.

However, ISG-3 clarifies the staff position that further evaluation is appropriate if the applicants facility is subject to moderate to severe weathering conditions unless the concrete meets certain specifications and subsequent inspections have confirmed that the aging mechanism has not caused degradation of the concrete.

ANO-2 is located in a region considered to be subject to moderate weathering conditions. In the LRA, the applicant stated that ANO-2 concrete structures are designed in accordance with American Concrete Institute (ACI) specification ACI 318-63, Building Code Requirements for Reinforced Concrete, which results in low permeability and resistance to aggressive chemical solutions by requiring the following:

C high cement content C low water-to-cement ratio C proper curing C adequate air entrainment The applicant stated in the LRA that ANO-2 concrete also meets the requirements of the guideline ACI 201.2R-77, Guide to Durable Concrete. ACI 318-63 and ACI201.2R-77 use the same ASTM standards for selection, application and testing of concrete.

The staff interviewed members of the applicants technical staff and reviewed relevant operating experience to confirm that loss of material from freeze-thaw has not been observed, either through the containment ISI program or the structures monitoring program.

On the basis that concrete that satisfies the requirements of ACI 318-63 will meet the requirements of ISG-3, and on the basis of an audit of operating experience evaluated under the containment ISI and structures monitoring programs, the staff finds that loss of material and cracking due to freeze-thaw will be adequately managed by the containment inservice inspection program.

(2) Leaching of calcium hydroxide Section 3.5.2.2.1.1 of the SRP-LR states that cracking, spalling, and increases in porosity and permeability due to leaching of calcium hydroxide could occur in inaccessible areas of PWR concrete and steel containments. The GALL Report, as updated by ISG-3, recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific criteria cannot be satisfied.

The GALL Report states that leaching of calcium hydroxide becomes significant only if the concrete is exposed to flowing water. Even if reinforced concrete is exposed to flowing water, such leaching is not significant if the concrete is constructed to ensure that it is dense, well-cured, has low permeability, and that cracking is well controlled.

The applicant stated in the LRA that ANO-2 concrete structures are designed in accordance 3.5-7

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS with specification ACI 318-63 and meet the requirements of guideline ACI 201.2R-77.

The staff finds that because ACI 318 provides assurance that the recommendations of the GALL Report and ISG-3 are met, leaching of calcium hydroxide is not significant at ANO-2, and therefore concludes that the containment ISI program will be sufficient for management of increases in porosity and permeability from this aging mechanism. A plant-specific aging management program is not required to address this aging effect.

(3) Aggressive chemical attack Section 3.5.2.2.1.1 of the SRP-LR states that cracking, spalling, and increases in porosity and permeability due to aggressive chemical attack could occur in inaccessible areas of PWR concrete and steel containments. The GALL Report recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific recommendations of the GALL Report and updated in ISG-3 cannot be satisfied.

The GALL Report, as updated by ISG-3, states that aggressive chemical attack is not significant unless pH is <5.5, chlorides are >500 ppm, or sulfates are >1500 ppm. ISG-3 also states that a plant-specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

The applicant stated in the LRA that the below-grade environment is not aggressive (pH >5.5, chlorides <500 ppm, and sulfates <1,500 ppm). In addition, the staff noted that the applicant uses the structures monitoring program for the examination of below-grade concrete when it is exposed by excavation.

On the basis of the information provided by the applicant in the LRA and the guidelines provided in the SRP-LR, the GALL Report, and ISG-3, the staff finds that increases in porosity and permeability, loss of material (spalling, scaling) and cracking due to aggressive chemical attack are not significant for concrete in inaccessible areas. The staff found that an appropriate plant-specific program for examination of below-grade concrete has been identified.

(4) Reaction with aggregates Section 3.5.2.2.1.1 of the SRP-LR does not address reaction with aggregates as an aging mechanism for concrete containments because no further evaluation is recommended in the GALL Report. However, ISG-3 clarifies the staff position that further evaluation is appropriate if investigations, tests, or examinations have demonstrated that the aggregates are reactive.

The applicant stated in the LRA that ANO-2 concrete structures are designed in accordance with specification ACI 318-63 and meet the requirements of guideline ACI 201.2R-77. The ACI standards call for the testing of aggregates at the time of construction. On the basis of interviews with the applicants technical staff, the staff confirmed that the results of those tests show that the aggregates used for concrete containment at ANO-2 are not reactive.

3.5-8

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS (5) Corrosion of embedded steel Section 3.5.2.2.1.1 of the SRP-LR states that loss of material due to corrosion of embedded steel could occur in inaccessible areas of PWR concrete and steel containments. The GALL Report (updated in ISG-3) recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific recommendations of the GALL Report cannot be satisfied.

For cracking, loss of bond, and loss of material (spalling, scaling) due to corrosion of embedded steel, the GALL Report states that a plant-specific program is only required if the below-grade environment is aggressive. ISG-3 also states that a plant-specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

The applicant stated in the LRA that the below-grade environment is not aggressive (pH >5.5, chlorides <500 ppm, and sulfates <1,500 ppm). In addition, the staff noted that the applicant uses the structures monitoring program for the examination of below-grade concrete when it is exposed by excavation.

On the basis of interviews with the applicants technical staff, the staff determined that the environment at the time of construction was not aggressive and on the basis of subsequent testing it has remained within the limits identified in the GALL Report. The staff finds that in accordance with the recommendations of the GALL Report, this aging effect is not significant and is adequately managed.

The staff reviewed the results of the applicants AMR for inaccessible concrete areas. On the basis of its review, the staff finds that the applicant appropriately evaluated AMR results involving management of aging of inaccessible concrete areas for containment, as recommended in the GALL Report and ISG-3.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.5.2.2.1.2 Cracking, Distortion, and Increase in Component Stress Level Due to Settlement; Reduction of Foundation Strength Due to Erosion of Porous Concrete Subfoundations, if Not Covered by Structures Monitoring Program In Section 3.5.2.2.1.2 of the LRA, the applicant addressed (1) cracking, distortion and increase in component stress level due to settlement and (2) reduction of foundation strength due to erosion of porous concrete subfoundations in the containment. The applicant used the structures monitoring - structures monitoring program (AMP B.1.27), where accessible areas are monitored for evidence of aging effects that may be applicable to containment structures.

This program, which is consistent with GALL AMP XI.S6, Structures Monitoring Program, is evaluated in Section 3.0.3.1 of this SER.

Section 3.5.2.2.1.2 of the SRP-LR states that cracking, distortion, and increase in component stress level due to settlement could occur in PWR concrete and steel containments. Also, reduction of foundation strength due to erosion of porous concrete subfoundations could occur 3.5-9

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS in all types of PWR containments. Some plants may rely on a de-watering system to lower the site groundwater level. If the plants CLB credits a de-watering system, the GALL Report recommends verification of the continued functionality of the de-watering system during the period of extended operation. The GALL Report recommends no further evaluation if this activity is included in the scope of the applicants structures monitoring program.

The applicant stated in the LRA that ANO-2 does not rely on a dewatering system for control of settlement because Category 1 structures are founded on sound bedrock. Concrete within five feet of the highest known groundwater level is protected by membrane waterproofing, which protects the containment building concrete against exposure to groundwater. Consequently, ANO-2 was not identified in IN 97-11 as a plant susceptible to erosion of porous concrete subfoundations. Groundwater was not aggressive during plant construction and no changes in groundwater conditions have been observed. Finally, the applicant has included these components within the plant-specific structures monitoring program, which will confirm that these aging effects are adequately managed.

The staff reviewed the AMR results involving management of aging effects resulting from settling and erosion of porous concrete subfoundations and confirmed that the structures monitoring program addresses each of the affected SCs. On the basis of this review, the staff finds that the applicant has appropriately evaluated AMR results involving cracking, distortion, and increase in component stress level from settlement and reduction of foundation strength from erosion, as recommended in the GALL Report.

3.5.2.2.1.3 Reduction of Strength and Modulus of Concrete Structures Due to Elevated Temperature In Section 3.5.2.2.1.3 of the LRA, the applicant addressed reduction of strength and modulus of concrete structures due to elevated temperature in containments.

Section 3.5.2.2.1.3 of the SRP-LR states that reduction of strength and modulus of elasticity due to elevated temperatures could occur in PWR concrete and steel containments. The GALL Report calls for a plant-specific aging management program and recommends further evaluation if any portion of the concrete containment components exceeds specified temperature limits, i.e., general area temperature 66°C (150°F) and local area temperature 93°C (200°F).

The applicant stated in the LRA that during normal operation, all concrete areas within containment are below 150EF ambient temperature. The applicant concluded that its containment concrete structures are not subject to change in material properties due to elevated temperature. The applicant has included these components within the scope of AMP B.1.27, Structures Monitoring - Structures Monitoring, and AMP B.1.13, Inservice Inspection - Containment Inservice Inspection, to monitor for indications of change in material properties for containment concrete aging effects.

The staff reviewed the AMR results involving management of aging effects resulting from elevated temperature and confirmed that the containment ISI and structures monitoring program addresses each of the affected SCs. On the basis of this audit and review, the staff finds that the applicant has appropriately evaluated AMR results involving reduction of strength 3.5-10

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS and modulus due to elevated temperature, as recommended in the GALL Report.

In addition, because the concrete is not exposed to elevated temperatures, the staff finds that the plant-specific AMPs are acceptable for management of this aging effect, and no further evaluation is required.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.5.2.2.1.4 Loss of Material Due to Corrosion in Inaccessible Areas of Steel Containment Shell or Liner Plate In Section 3.5.2.2.1.4 of the LRA, the applicant addressed loss of material due to corrosion in inaccessible areas of the steel containment shell or the steel liner plate for the containment.

Section 3.5.2.2.1.4 of the SRP-LR states that loss of material due to corrosion could occur in inaccessible areas of the steel containment shell or the steel liner plate for all types of PWR containments. The GALL Report recommends further evaluation of plant-specific programs to manage this aging effect for inaccessible areas if the following specific recommendations of the GALL Report cannot be satisfied: (1) concrete meeting the requirements of ACI 318 or 349 and the guidance of 201.2R was used for the containment concrete in contact with the embedded containment shell or liner; (2) the accessible concrete is monitored to ensure that it is free of penetrating cracks that provide a path for water seepage to the surface of the containment shell or liner; (3) the accessible portion of the moisture barrier, at the junction where the shell or liner becomes embedded, is subject to aging management activities in accordance with IWE requirements; (4) borated water spills and water ponding on the containment concrete floor are not common and when detected are cleaned up in a timely manner.

The applicant stated in the LRA that the containment concrete in contact with the steel liner plate is designed in accordance with ACI 318-63, and meets the requirements of guideline ACI 201.2R-77. Accessible concrete is monitored for cracks under the structures monitoring program, evaluated in Section 3.0.3.1 of this SER. The accessible portions of the steel liner plate and moisture barrier where the liner becomes embedded are inspected in accordance with the containment ISI (IWE) program, evaluated in Section 3.0.3.3.4 of this SER. Spills (e.g.,

borated water spill) are cleaned up in a timely manner. The aging effect of loss of material due to corrosion has not been significant for this liner plate.

On the basis that all of the recommendations of the GALL Report are satisfied, the staff finds that no additional plant-specific aging management program is required to manage inaccessible areas of the steel containment liner plate.

3.5.2.2.1.5 Loss of Prestress Due to Relaxation, Shrinkage, Creep, and Elevated Temperature As stated in the SRP-LR, loss of prestress due to relaxation, shrinkage, creep, and elevated temperature is a TLAA as defined in 10 CFR 54.3. TLAAs are required to be evaluated in accordance with 10 CFR 54.21(c)(1). The staffs review of the applicants evaluation of this TLAA is documented in Section 4.5 of this SER. In performing this review, the staff followed 3.5-11

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS the guidance in Section 4.5 of the SRP-LR.

< DE to verify >

3.5.2.2.1.6 Cumulative Fatigue Damage As stated in the SRP-LR, fatigue is a TLAA as defined in 10 CFR 54.3. TLAAs are required to be evaluated in accordance with 10 CFR 54.21(c)(1). The staffs review of the applicants evaluation of this TLAA is documented in Section 4.6 of this SER. In performing this review, the staff followed the guidance in Section 4.6 of the SRP-LR.

< DE to verify >

3.5.2.2.1.7 Cracking Due to Cyclic Loading and Stress Corrosion Cracking In Section 3.5.2.2.1.7 of the LRA, the applicant addressed aging mechanisms that can lead to cracking of penetration sleeves and penetration bellows such as cyclic loads and SCC.

Section 3.5.2.2.1.7 of the SRP-LR states that cracking of containment penetrations (including penetration sleeves, penetration bellows, and dissimilar metal welds) due to cyclic loading or SCC could occur in containments. Further evaluation of inspection methods is recommended to detect cracking due to cyclic loading and SCC since visual VT-3 examinations may be unable to detect this aging effect.

(1) Cracking Due to Stress Corrosion Cracking The GALL AMP XI.S1, ASME Section XI Subsection IWE covers inspection of these items under examination categories E-B, E-F, and E-P (10 CFR Part 50, Appendix J pressure tests).

10 CFR 50.55a identifies examination categories E-B and E-F as optional during the current term of operation. For the extended period of operation, examination categories E-B and E-F, and additional appropriate examinations to detect SCC in bellows assemblies and dissimilar metal welds are warranted to address this issue.

To manage this aging effect, the applicant used the containment leak rate program (AMP B.1.6) and the containment inservice inspection program (AMP B.1.13). The staffs evaluation of the containment leak rate program is documented in Section 3.0.3.1 of this SER. The staff determined that the containment inservice inspection program (AMP B.1.13), which the staff evaluated in Section 3.0.3.3.4 of this SER, required enhancement, for the extended period of operation, to detect SCC in bellows assemblies and dissimilar metal welds using examination categories E-B and E-F, and additional appropriate examinations.

In a letter dated April, 14, 2004, the staff asked the applicant to provide additional information regarding the containment pressure boundary bellows, relevant operating experience, and methods used to detect their age related degradation. The staff noted that the containment inservice inspection and containment leak rate programs cannot detect cracking due to SCC (NRC IN 92-20, Inadequate Local Leak Rate Testing).

By letter dated May 19, 2004, the applicant provided its response. In its letter, the applicant 3.5-12

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS stated that the penetration bellows, (Table 3.5.1, Item Number 3.5.1-3 of the LRA), pertains to carbon steel penetrations which are not susceptible to SCC and are consistent with the GALL Report, but do not require further evaluation. In addition, the applicant stated that Table 3.5.1, Item Number 3.5.1-2 of the LRA, addressed SCC of stainless steel penetration bellows. The applicant further stated that bellows are not used for piping system containment penetrations at ANO-2 and that Item Number 3.5.1-2 applies to the fuel transfer tube sleeve, but not to the bellows, since the bellows are not part of the containment penetration boundary.

On the basis that the bellows are not used for piping system containment penetrations and on the staffs review of the applicants response, the staff finds this acceptable.

(2) Cracking Due to Cyclic Loading As stated in the SRP-LR, cracking due to cyclic loading of the liner plate and penetrations is a TLAA as defined in 10 CFR 54.3. TLAAs are required to be evaluated in accordance with 10 CFR 54.21(c)(1). The staffs review of the applicants evaluation of this TLAA is documented in Section 4.6 of this SER. In performing this review, the staff followed the guidance in Section 4.6 of the SRP-LR.

< DE to verify >

3.5.2.2.2 Class 1 Structures The staff reviewed Section 3.5.2.2.2 of the LRA against the criteria in Section 3.5.2.2.2 of the SRP-LR, which addresses several areas discussed below.

3.5.2.2.2.1 Aging of Structures Not Covered by Structures Monitoring Program In Section 3.5.2.2.2.1 of the LRA, the applicant addressed aging of Class 1 structures not covered by the structures monitoring program.

Section 3.5.2.2.2.1 of the SRP-LR states that the GALL Report recommends further evaluation of certain structure/aging effect combinations if they are not covered by the structures monitoring program. This is described in GALL Report Chapter III and includes (1) scaling, cracking, and spalling due to repeated freeze-thaw for Groups 1-3, 5, 7-9 structures; (2) scaling, cracking, spalling and increase in porosity and permeability due to leaching of calcium hydroxide and aggressive chemical attack for Groups 1-5, 7-9 structures; (3) expansion and cracking due to reaction with aggregates for Groups 1-5, 7-9 structures; (4) cracking, spalling, loss of bond, and loss of material due to corrosion of embedded steel for Groups 1-5, 7-9 structures; (5) cracks, distortion, and increase in component stress level due to settlement for Groups 1-3, 5, 7-9 structures; (6) reduction of foundation strength due to erosion of porous concrete sub-foundations for Groups 1-3, 5-9 structures; (7) loss of material due to corrosion of structural steel components for Groups 1-5, 7-8 structures; (8) loss of strength and modulus of concrete structures due to elevated temperatures for Groups 1-5; and (9) crack initiation and growth due to SCC and loss of material due to crevice corrosion of stainless steel liner for Groups 7 and 8 structures. Further evaluation is necessary only for structure/aging effect combinations not covered by the structures monitoring program.

3.5-13

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS Technical details of the aging management issue are presented in Subsection 3.5.2.2.1.2 of the SRP-LR for structure/aging effect combinations Items (5) and (6) and Subsection 3.5.2.2.1.3 of the SRP-LR for Item (8).

In Table 3.5-1, Item Number 20, the applicant credited its structures monitoring program for all types of aging effects and all component groups except Group 6 of accessible interior and exterior concrete and steel components of Class 1 structures. The program is evaluated in Section 3.0.3.1 of this SER. Additional discussion of specific structure/aging effect combinations follows.

(1) Freeze-thaw Section 3.5.2.2.1.2 of the SRP-LR does not address freeze-thaw as an aging mechanism for concrete containments because no further evaluation is recommended in the GALL Report.

However, ISG-3 clarifies the staff position that further evaluation is appropriate if the applicants facility is subject to moderate to severe weathering conditions unless the concrete meets certain specifications and subsequent inspections have confirmed that the aging mechanism has not caused degradation of the concrete.

ANO-2 is located in a region considered to be subject to moderate weathering conditions. In the LRA, the applicant states that ANO-2 structures are designed in accordance with specification ACI 318-63, which results in low permeability and resistance to aggressive chemical solutions by requiring the following:

C high cement content C low water-to-cement ratio C proper curing C adequate air entrainment In addition to ACI 318-63, ANO-2 concrete also meets requirements of the guideline of ACI 201.2R-77. ACI 318-63 and ACI201.2R-77 use the same ASTM standards for selection, application and testing of concrete.

The staff interviewed members of the applicants technical staff and reviewed relevant operating experience to confirm that loss of material from freeze-thaw has not been observed, either through the containment ISI program or the structures monitoring program.

On the basis that concrete that satisfies the requirements of ACI 318-63 will meet the requirements of ISG-3, and on the basis of an audit of operating experience evaluated under the structures monitoring programs, the staff finds that loss of material and cracking due to freeze-thaw will be adequately managed by the structures monitoring program.

(2)(a) Leaching of calcium hydroxide Section 3.5.2.2.2.1 of the SRP-LR states that cracking, spalling, and increases in porosity and permeability due to leaching of calcium hydroxide could occur in inaccessible areas of PWR concrete and steel containments. The GALL Report, as updated by ISG-3, recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas 3.5-14

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS exposed to flowing water, unless the requirements of ACI 201.2R are met.

The GALL Report states that leaching of calcium hydroxide becomes significant only if the concrete is exposed to flowing water. Even if reinforced concrete is exposed to flowing water, such leaching is not significant if the concrete is constructed to ensure that it is dense, well-cured, has low permeability, and that cracking is well controlled.

The applicant stated in the LRA that concrete structures are designed in accordance with specification ACI 318-63 and meet the requirements of guideline ACI 201.2R-77.

The staff finds that because ACI 318 provides assurance that the recommendations of the GALL Report and ISG-3 are met, leaching of calcium hydroxide is not significant at ANO-2, and therefore concludes that the structures monitoring program will be sufficient for management of increases in porosity and permeability from this aging mechanism. A plant-specific aging management program is not required to address this aging effect.

(2)(b) Aggressive chemical attack Section 3.5.2.2.2.1 of the SRP-LR states that cracking, spalling, and increases in porosity and permeability due to aggressive chemical attack could occur in inaccessible areas of Class 1 structures. The GALL Report recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific recommendations of the GALL Report and updated in ISG-3 cannot be satisfied.

The GALL Report as updated by ISG-3 states that aggressive chemical attack is not significant unless pH is <5.5, chlorides are >500 ppm, or sulfates are >1500 ppm. ISG-3 also states that a plant-specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

The applicant stated in the LRA that the below-grade environment is not aggressive (pH >5.5, chlorides <500 ppm, and sulfates <1,500 ppm). In addition, the staff noted that the applicant used the structures monitoring program for the examination of below-grade concrete when it is exposed by excavation.

On the basis of the information provided in the LRA and the guidelines provided in the SRP-LR, the GALL Report, and ISG-3; the staff finds that increases in porosity and permeability, loss of material (spalling, scaling) and cracking due to aggressive chemical attack are not significant for concrete in inaccessible areas. The staff found that an appropriate plant-specific program for examination of below-grade concrete (specifically, an enhancement to the structures monitoring program) has been identified.

(3) Reaction with aggregates Section 3.5.2.2.2.1 of the SRP-LR does not address reaction with aggregates as an aging mechanism for concrete containments because no further evaluation is recommended in the GALL Report. However, ISG-3 clarifies the staff position that further evaluation is appropriate if investigations, tests, or examinations have demonstrated that the aggregates are reactive.

3.5-15

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS The applicant stated in the LRA that ANO-2 concrete structures were designed in accordance with specification ACI 318-63 and meet the requirements of guideline ACI 201.2R-77. The ACI standards call for the testing of aggregates at the time of construction.

On the basis of interviews with the applicants technical staff, the staff confirmed that the results of those tests showed that the aggregates used for concrete Class 1 structures at ANO-2 are not reactive.

(4) Corrosion of embedded steel Section 3.5.2.2.2.1 of the SRP-LR states that loss of material due to corrosion of embedded steel could occur in inaccessible areas of Class 1 structures. The GALL Report (updated in ISG-3) recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific recommendations of the GALL Report cannot be satisfied.

For cracking, loss of bond, and loss of material (spalling, scaling) due to corrosion of embedded steel, the GALL Report states that a plant-specific program is only required if the below-grade environment is aggressive. ISG-3 also states that a plant-specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

The applicant stated in the LRA that the below-grade environment is not aggressive. In interviews with the applicants technical staff, the staff determined that the environment at the time of construction had a measured pH >5.5, chlorides <500 ppm, and sulfates <1,500 ppm and on the basis of subsequent testing, it has remained within these limits.

The staff finds that in accordance with the recommendations of the GALL Report, this aging effect is not significant and is adequately managed by the structures monitoring program as enhanced. The staffs evaluation of this program is documented in Section 3.0.3.1 of this SER.

(5) Settlement Section 3.5.2.2.2.1 of the SRP-LR refers to Section 3.5.2.2.1.2 for discussion of settlement.

Section 3.5.2.2.1.2 of the SRP-LR states that cracking, distortion, and increase in component stress level due to settlement could occur in Class 1 structures. Some plants may rely on a de-watering system to lower the site groundwater level. If the plant's CLB credits a de-watering system, the GALL Report recommends verification of the continued functionality of the de-watering system during the period of extended operation. The GALL Report recommends no further evaluation if this activity is included in the scope of the applicant's structures monitoring program.

The applicant stated in the LRA that ANO-2 does not rely on a de-watering system for control of settlement because Class 1 structures are founded on sound bedrock. Concrete within five feet of the highest known groundwater level is protected by membrane waterproofing, which protects the containment building concrete against exposure to groundwater. Consequently, ANO-2 was not identified in IN 97-11 as a plant susceptible to erosion of porous concrete subfoundations. Groundwater was not aggressive during plant construction and no changes in groundwater conditions have been observed. The applicant also included these components within the plant-specific structures monitoring program, which will confirm that these aging 3.5-16

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS effects are adequately managed.

The staff reviewed the AMR results involving management of aging effects resulting from settling and erosion of porous concrete sub-foundations and confirmed that the structures monitoring program addresses each of the affected SCs. On the basis of this review, the staff finds that the applicant has appropriately evaluated AMR results involving cracking, distortion, and increase in component stress level from settlement and reduction of foundation strength from erosion, as recommended in the GALL Report.

(6) Erosion of porous concrete sub-foundation Section 3.5.2.2.2.1 of the SRP-LR refers to Section 3.5.2.2.1.2 for discussion of erosion of porous concrete sub-foundation. Section 3.5.2.2.1.2 of the SRP-LR states that reduction of foundation strength due to erosion of porous concrete sub-foundations could occur in all types of Class 1 structures. Some plants may rely on a de-watering system to lower the site groundwater level. If the plants CLB credits a de-watering system, the GALL Report recommends verification of the continued functionality of the de-watering system during the period of extended operation. The GALL Report recommends no further evaluation if this activity is included in the scope of the applicants structures monitoring program.

ANO-2 was not identified in IN 97-11 as a plant susceptible to erosion of porous concrete sub-foundations. Groundwater was not aggressive during plant construction and there is no indication that groundwater chemistry has significantly changed. No changes in groundwater conditions have been observed at ANO-2. The staff finds that cracking, distortion and increase in component stress level due to settlement and reduction of foundation strength due to erosion of porous concrete sub-foundation are adequately managed by the structures monitoring program.

(7) Corrosion of structural steel components Section 3.5.2.2.1 of the SRP-LR states that corrosion of structural steel components could occur and that further evaluation is necessary only for structure/aging effect combinations not covered by the structures monitoring program.

The staff reviewed the AMR results involving management of aging effects resulting from corrosion of structural steel components and confirmed that the structures monitoring program, evaluated in Section 3.0.3.1 of this SER, addresses each of the affected SCs. On the basis of this audit and review, the staff finds that the applicant has appropriately evaluated AMR results involving this aging effect and that corrosion of structural steel components is adequately managed by the structures monitoring program.

(8) Elevated temperatures Section 3.5.2.2.2.1 of the SRP-LR refers to Section 3.5.2.2.1.3 for discussion of elevated temperatures. Section 3.5.2.2.1.3 of the SRP-LR states that reduction of strength and modulus of elasticity due to elevated temperatures could occur in Class 1 structures in Groups 1-5. The GALL Report calls for a plant-specific aging management program and recommends further evaluation if any portion of the concrete components exceeds specified temperature limits, i.e.,

3.5-17

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS general area temperature 66°C (150°F) and local area temperature 93°C (200°F).

The applicant stated in the LRA that during normal operation, all concrete areas in Class 1 structures are below 150EF ambient temperature. The applicant concluded that ANO-2 Class 1 concrete structures are not subject to change in material properties due to elevated temperature.

The staff reviewed the AMR results involving management of aging effects resulting from elevated temperature and confirmed that the structures monitoring program, evaluated in Section 3.0.3.1 of this SER, addresses each of the affected SCs. On the basis of this review, the staff finds that the applicant has appropriately evaluated AMR results involving reduction of strength and modulus due to elevated temperature, as recommended in the GALL Report, and that it is adequately managed by the structures monitoring program.

(9) Aging effects for stainless steel liners for tanks The applicant stated that no tanks with stainless steel liners are included in the structural AMRs. Tanks subject to an AMR are evaluated with their respective mechanical systems. The staff confirmed that there are no tanks with stainless steel liners included in LRA Tables 3.5.2-1 through 3.5.2-4.

On the basis of its review, the staff finds that the applicant has appropriately evaluated AMR results involving management of aging of accessible interior and exterior concrete and steel components of Class 1 structures (except Group 6, water-control structures) and all are covered by the structures monitoring program. This is consistent with the recommendations of the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.5.2.2.2.2 Aging Management of Inaccessible Areas In Section 3.5.2.2.2.2 of the LRA, the applicant addressed aging of inaccessible areas of Class 1 structures.

Section 3.5.2.2.2.2 of the SRP-LR states that cracking, spalling, and increases in porosity and permeability due to aggressive chemical attack and cracking, spalling, loss of bond, and loss of material due to corrosion of embedded steel could occur in below-grade inaccessible concrete areas. The GALL Report recommends further evaluation to manage these aging effects in inaccessible areas of Groups 1-3, 5, 7-9 structures, if an aggressive below-grade environment exists. ISG-3 identifies additional requirements.

The GALL Report as updated by ISG-3 states that aggressive chemical attack and corrosion of embedded steel is not significant unless pH is <5.5, chlorides are >500 ppm, or sulfates are

>1500 ppm. ISG-3 also states that a plant-specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

In the LRA, the applicant stated that the below-grade environment is not aggressive (pH >5.5, chlorides <500 ppm, and sulfates <1,500 ppm). The structures monitoring program, evaluated 3.5-18

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS in Section 3.0.3.1 of this SER, is used to examine below-grade concrete when it is exposed by excavation.

The applicant also stated that inspections of accessible concrete have not revealed degradation from aggressive chemical attack or corrosion of embedded steel.

On the basis that the below-grade environment is not aggressive and that excavated concrete has been and will continue to be monitored, the staff finds that increases in porosity and permeability, loss of material (spalling, scaling) and cracking due to aggressive chemical attack and cracking, spalling, loss of bond, and loss of material due to corrosion of embedded steel are adequately managed for concrete in inaccessible areas.

3.5.2.2.3 Component Supports The staff reviewed Section 3.5.2.2.3 of the LRA against the criteria in Section 3.5.2.2.3 of the SRP-LR, which addresses several areas discussed below.

3.5.2.2.3.1 Aging of Supports Not Covered by Structures Monitoring Program In Section 3.5.2.2.3.1 of the LRA, the applicant addressed aging of component supports that are not managed by the structures monitoring program.

Section 3.5.2.2.3.1 of the SRP-LR states that the GALL Report recommends further evaluation of certain component support/aging effect combinations if they are not covered by the structures monitoring program. This includes (1) reduction in concrete anchor capacity due to degradation of the surrounding concrete, for Groups B1-B5 supports; (2) loss of material due to environmental corrosion, for Groups B2-B5 supports; and (3) reduction/loss of isolation function due to degradation of vibration isolation elements, for Group B4 supports. Further evaluation is necessary only for structure/aging effect combinations not covered by the structures monitoring program.

Component supports at ANO-2 are included in the structures monitoring program and are evaluated in Section 3.0.3.1 of this SER, for Groups B2-B5. Component supports in Group B1 are managed using the inservice inspection program and are evaluated in Section 3.0.3.4 of this SER.

(1) Reduction in concrete anchor capacity due to surrounding concrete for Groups B1 through B5 supports.

ANO-2 concrete anchors and surrounding concrete are included in the structures monitoring program (Groups B2 through B5) and inservice inspection program (Group B1).

(2) Loss of material due to environmental corrosion, for Groups B2-B5 supports.

Loss of material due to corrosion of steel support components is an aging effect requiring management at ANO-2. This aging effect is managed by the structures monitoring program.

(3) Reduction/loss of isolation function due to degradation of vibration isolation elements for 3.5-19

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS Group B4 supports.

In the LRA, no vibration isolation elements subject to aging management are identified.

The staff finds that the applicant has appropriately evaluated AMR results involving management of aging of component supports, as recommended in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.5.2.2.3.2 Cumulative Fatigue Damage Due to Cyclic Loading As stated in the SRP-LR, fatigue is a TLAA as defined in 10 CFR 54.3. TLAAs are required to be evaluated in accordance with 10 CFR 54.21(c)(1). The staffs review of the applicants evaluation of this TLAA is documented in Section 4.3 of this SER. In performing this review, the staff followed the guidance in Section 4.3 of the SRP-LR.

< DE to verify >

3.5.2.2.4 Quality Assurance for Aging Management of Non-Safety-Related Components

< Evaluation To Be Provided by NRR DIPM >

Conclusion On the basis of its review, for component groups evaluated in the GALL Report for which the applicant has claimed consistency with the GALL Report, and for which the GALL Report recommends further evaluation, the staff determined that the applicant adequately addressed the issues that were further evaluated. In addition, the staff reviewed the applicant's further evaluations against the criteria contained in the SRP-LR. Since the applicants AMR results are otherwise consistent with the GALL Report, the staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.5.2.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report Summary of Technical Information in the Application In Tables 3.5.2-1 through 3.5.2-4 of the LRA, the staff reviewed additional details of the results of the AMRs for material, environment, aging effect requiring management, and AMP combinations that are not consistent with the GALL Report.

In Tables 3.5.2-1 through 3.5.2-4, the applicant indicated, via Notes F through J, that neither the identified component nor the material and environment combination is evaluated in the GALL Report and provided information concerning how the aging effect require management will be managed.

3.5-20

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS Note F indicated that the material is not in the GALL Report for the identified component.

Note G indicated that the environment is not in the GALL Report for the identified component and material.

Note H indicated that the aging effect is not in the GALL Report for component, material, and environment combination.

Note I indicated that the aging effect in the GALL Report for the identified component, material, and environment combination is not applicable Note J indicated that neither the identified component nor the material and environment combination is evaluated in the GALL Report.

Staff Evaluation For component type, material and environment combination that are not evaluated in the GALL Report, the staff reviewed the applicants evaluation to determine whether the applicant had demonstrated that the effects of aging will be adequately managed so that the intended function will be maintained consistent with the CLB during the period of extended operation.

The staff evaluation is discussed below.

3.5.2.3.1 Containment and Containment Internals Summary of Aging Management -

Table 3.5.2-1 The staff reviewed Table 3.5.2-1 of the LRA, which summarized the results of AMR evaluations in the SRP-LR for the containment and containment internals structures component groups.

In the LRA, the AMR for tendon anchorages referred to the wrong item in Table 3.5.1. By letter dated March 24, 2004, the applicant submitted a letter to the NRC correcting the reference.

< Additional Evaluation To Be Provided by DE>

3.5.2.3.2 Auxiliary Building, Turbine Building and Yard Structures Summary of Aging Management - Table 3.5.2-2 The staff reviewed Table 3.5.2-2 of the LRA, which summarized the results of AMR evaluations in the SRP-LR for the auxiliary building, turbine building and yard structures component groups.

The staff finds that the GALL Report reference for the HVAC missile barriers was not appropriate. By letter dated March 24, 2004, the applicant revised the reference to the GALL Report Volume 2, Item III.A3.2-a. The staff finds this acceptable.

< Additonal Evaluation To Be Provided by DE>

3.5.2.3.3 Intake Structure and Emergency Cooling Pond Summary of Aging Management -

Table 3.5.2-3 3.5-21

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS The staff reviewed Table 3.5.2-3 of the LRA, which summarized the results of AMR evaluations in the SRP-LR for the intake structure and emergency cooling pond structures component groups.

For the intake canal, the applicant identified the loss of form (or shape that could affect flow) as the only potential aging effect that required aging management for the ANO-2 earthen embankments. The applicant stated that loss of form is not an applicable aging effect for the intake and discharge canals.

The staff reviewed the design characteristics of the intake and discharge canals and found them to be designed to prevent loss of form from affecting maximum flow. In addition, the staff verified that during power operations, the loss of form aging effect is monitored and maintained to ensure that sediment build-up does not affect safety systems. This normal plant operation of monitoring and maintenance will continue into the period of extended operation. On the basis of its review, the staff finds that no additional aging management program is required.

<Additional Evaluation To Be Provided by DE/EMCB >

3.5.2.3.4 Bulk Commodities Summary of Aging Management - LRA Table 3.5.2-4 The staff reviewed Table 3.5.2-4 of the LRA, which summarized the results of AMR evaluations in the SRP-LR for the bulk commodities component groups.

The GALL Report recommends both the containment leak rate and containment inservice inspection programs (IWE) to manage aging of the equipment hatch seal. The applicant credited only the former program for the equipment hatch seal. Since there is no aspect of the ASME Section XI Subsection IWE inspection that is applicable to this elastomeric component, the staff concludes that periodic leak rate testing in accordance with 10 CFR 50 Appendix J is a sufficient and acceptable method for managing aging effects for this component.

The applicant stated, for concrete equipment pads, flood curbs, hatch covers and plugs, missile shields, and support pedestals, that aging effects are managed using the structures monitoring program. On the basis that the implementing procedures for the structures monitoring program direct inspectors to monitor the aging effects identified in the GALL Report, the staff finds this to be acceptable.

<Additional Evaluation To Be Provided by DE/EMCB >

Conclusion On the basis of its review, the staff finds that the applicant appropriately evaluated AMR results involving material, environment, aging effect requiring management, and AMP combinations that are not evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.5-22

ANO-2 SER FINAL WITH OPEN AND CONFIRMATORY ITEMS 3.5.3 Conclusions The staff concluded that the applicant provided sufficient information to demonstrate that the effects of aging for the structures and component supports and commodity groups that are within the scope of license renewal and subject to an AMR will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

3.5-23