ML051650086
| ML051650086 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/09/2005 |
| From: | Le N NRC/NRR/DRIP/RLEP |
| To: | Constellation Energy Group |
| Le N. B., NRR/DRIP/RLEP, 415-1458 | |
| Shared Package | |
| ML051660508 | List: |
| References | |
| TAC MC3272, TAC MC3273 | |
| Download: ML051650086 (23) | |
Text
I ..
Nine Mile Pointo nits 1 and 2 tLRAStatus Upda.te I
June 9, 2005
Agenda Opening Remarks M. Flaherty
.:,. -O er ie
- ..Recovery-.. Plan Overview D. Dellario
- Focus ,A-.reas
- ;Road Map:-of LRA Changes
- . Summary M. Flaherty 2
Opening Remarks,
- Purpose, of meeting Povide r Status Update of Recovery Project
-Review "'Road Map" for LRA
~.Building, Qualit.y into Recovery Project
- xtniv ndusr License Renewal Experience
-:-- - Rvie onteam ngeaBoapfo R
- Brunswick, Cook, Ginna., Monticello, Palisades, Robinson. and Point Beach
- Use of checks and Balances
- Use of Site Champions and Experts
- Use oChalle rds for all Products
- Senior Constellation Management Oversight 3
NieMile' Point License Renew'al Recovery- Poect, FocusAreas
- Non-Safety-Related Affecting Safety-Reated-,- Sc'oping 1CR4.()2
- Qualityof Reuss for Additional
.1nformatio'n 4
Nine Mile Point License-Renewal RecoveryeProject
. .'N'on'-Safety-Related Affecting Safety-Related'Scoping 10CFR54,4(a)(2)
-.- CLB. Review:Complete
- .SR/NSR Interface/Anchor Point Review
..- Drawing Review Completed
- Walkdowns Completed Structural Engineering Reviews Continue
-- NSR-SR Spatial Relationship Review Completed 5
Nine Mile -P-oint Licensea Ri-enewal Recovery Proj E Quality of Requests for Additional Information
- a.:.+
.......^.:--: I :E. :.'-
_..,._ -28 S . .> S -rX
- of -28Ne'w RA responses written i ,; s -I I . , . . , - ... .. .. .
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.- C nn~
- . '. , . ' - ' a' n r Presented and Approved by Challenge Board '
- Industry" RAI Reviews - Current RAIs and NSR scoping efforts align us to industry RAIs 6
.-Nine Mi'le Polint License Renew al
-.Recovery Project Programs
...-Reviewed Draft GALL Rev 1 for LRA Impact- On Sch"edu l'
.GALL' Rev. 1 issues addressed or incorporated where applicable'
' Changes resulting from GALL Rev 1 are identified as the "latest industry and regulatory guidance" in the LRA
.. . . . Programs reflect latest NEI/NRC discussions concerning Rev. 1'(i.e.' -May 16, 2005 conference)
.Minimal
- changes, primary impact is on electrical
.programs 7
Nine Mile ... Point-License Renewa
~~~~ .......ne ....
...a.
Recovery Project
- - _. - . 4 ", __ .. , - - _.__ . ..... I I'I -Program-s - .:
(Continued)
- Program Basis Documents - On Schedule
.:'S.-, . ntia- nhancements over previous program
- Identify specific implementing procedures Document required revisions and enhancements
- Contain:more detailed GALL attribute evaluations
. Will. be used to develop or enhance programs to be used. during the PEO
- 'Ali"gned/Benchmarked with the latest applicants 8
Ninde Mile Point License -Renewal
- Recovery
~-.. - .........
- . . . Project
. O
. l . .
v Road M-p" of LRA changes
,:,-. .Incorporation of RAIs Re-Scoping.
-NSR
'Incorporation :.of. Audit Items
- Structural Re-Scoping
- Appendix A & B Changes resulting from program benchmarking'
. I r . . .
I . I . z 9
!_ __ 1. -.- I -1 r I- -
NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL APPLICATION TECHNICAL INFORMATION DRAFT 2.3.1.A.4 NMPI REACTOR RECIRCULATION SYSTEM
System Description
The NMP1 Reactor Recirculation System is designed to provide a variable reactor coolant flow in order to control reactor power levels.
The Reactor Recirculation System Is part of the reactor coolant pressure boundary and consists of five, external loops. Each loop draws suction from the downcomer annulus region of the RPV and discharges reactor coolant to the RPV lower plenum. Each loop consists of a variable speed pump, blocking valves, bypass line and associated instrumentation. The reactor recirculation pumps are controlled by separate variable frequency motor-generator sets, each having associated controls and instrumentation. Other systems that connect directly to the Reactor Recirculation System piping are the Emergency Cooling System, Shutdown Cooling System, Reactor Water Cleanup System and the Sampling System.
This system is in scope for license renewal for the following reasons:
- It performs a safety-related function(s) per 10 CFR 54.4(a)(1).
- It contains NSR SCs whose failure could prevent satisfactory accomplishment of any of the functions identified in 10 CFR 54.4(a)(1).
- It contains SCs relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48),
anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).
The portion of the Reactor Recirculation System containing components subject to AMR includes the entire main Reactor Recirculation flow path, which begins at the suction nozzle to, and ends at the discharge nozzle of, each recirculation loop. Safety-related instrumentation piping and associated components connected to the recirculation loops are also subject to AMR. The components subject to an AMR for this system also include the NSR piping, fittings, and equipment containing liquidindtho Roator-BuiWing valves in Comment [MRF1]: Chnge due to instrumentation loons. NSR re-scoping, Page 2.3-1 SCOPING SCOPING AND SCREENING REVIEW AND SCREENING REVIEW Page 2.3-1
NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL APPLICATION TECHNICAL INFORMATION DRAFT USAR Reference(s)
More information about the Reactor Recirculation System can be found in USAR Sections V.B.3 and XVI.D.2.1.
License Renewal Drawings [List of dwgs. in the LRAJ Components in scone under 10 CFR 54.4(a)(1) and (3) requiring an Comment [MRF21: Added for clarificadon.
AMR for the Reactor Recirculation System are highlighted on the following drawings:
Comnonents Subiect to an AMR The component types requiring an AMR for the Reactor Recirculation System and their intended functions are shown in Table 2.3:1.A.4-1.
The AMR results for these component types are provided in Table 3.1 .2.A-4.
Table 2.3.1.AA-1 NMPI Reactor Recirculation System Comment [MRF3]: Changes due to NSR re-scoping.
ComponentType Intended Functions Closure Bolting Pressure Boundary Flow Elements Pressure Boundary NSR-pipingrfitigs-and Prevent Failurc from Affecting-SR equ ipmeenter Pressure Boundary Piping and Fittings Leakage Boundary (Spatial)
Structural Integrity (Attached)
Pumps Pressure Boundary Pump Seal Flanges Pressure Boundary Pressure Boundary Valves Leakaae Boundary (Spatial)
_ Structural Integrity (Attached)
Page 2.3-2 SCOPING AND SCOPING REVIEW SCREENING REVIEW AND SCREENING Page 2.3-2
NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL APPLICATION TECHNICAL INFORMATION Table 3.1.2.A-4 Reactor Vessel, Internals, and Reactor Coolant System NMP1 Reactor Recirculation System - Summary of Ag Ing Management Evaluation Aging Effect N4UREG-Component Intended Material Environment Requiring Aging Management 1801 Table I Notes Type Function Maaeet Program Volume 2 Item Management ~Item _____
Closure Bolting PB Carbon or Low Closure Bolting GraGking Fat IV.C1.2-f 3.1.1 .A-01 A Alloy Steel for Non- Cumulative PpTLA. IV.C1.3-g 3.1.1.A-01 A Comment ICIOS]: NUPIL 1892, 18 (Yield Strength > Borated Water Fatigue evaluated in AMR Audit Itemts 100 Ksi) Systems with Damage accordance with 10 operating CFR 54.21(c) Comment [MRFiO6]: NNIPIL xxxx, temperatures Loss of ASME-Section-XI IV.C1.2-d 3.1.1 .A-26 E RAI3.1.2-20 Z212 0F Material 'n'e'-"~" '&'e"'i" IV.C1.3-e 3.1.1.A-26 E (Subsections,4WB-ProgramBolting
- Comment 1C107]: NMPIL 1919, Inteqritv Proaram RAIT3.1-3 Loss of Preload ASME Seci ion Xl IV.C1.2-e 3.1.1.A-26 E Comment [C108]: NMIIL 1892, lnseyioe4ns~etioon AMRAuditItents7,94&214 (S IV.C1 .3-f 3.1.1 .A-26 E PfeoaamBoltina
- Comment [C1Og]: NMPIL 1919, ntegrity Program RAI T3.1-3 Flow Elements PB Wrought Treated Water Cracking BWR Stress IV.C1.1-f 3.1.1.A-29 e. 20 Austenitic or Steam, Corrosion Crackina Stainless Steel temperature Program 24820F I Water Chemistry Control Program .
Cumulative Fatigue-Monitoring IV.C1.1-h 3.1.1 .A-01 C 20 Fatigue R2+9mTLAA.
Damage evaluated in accordance with 10
_ __ CFR 54.21(c)
See Table 2.0-1 for definitions of Intended Functions, Table 3.0-1 for descriptions of Environments, and Table 3.0-2 for descriptions of Aging Effects.
A. N MA _ EM N RE IE AGING MANAGEMENT REVIEW Pag 3.1..-75_
Page 3.1-75
..... "-1
NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL APPLICATION TECHNICAL INFORMATION DRAFT.
Table 2.4.A1-1 NMP1 Primary Containment Structure Comment [MRF1]: Changes due to the re-scoping of structural components (RAI 2.41) and the response to RAI Component Component Type In Table Intended Functions 3.5.1-20.
____________ ____3.5.2.A -1 Beam Seats Low Alloy Steel) in Air Structural Suomort Bearing Plates Copoer Alloy (Zinc < 15%) in Structural Supoort Air Concrete & Grout Concrete in Air Structural Support Containment Penetrations Structural Steel (Carbon and Structural Sunort (Electrical) Low Alloy Steel) In Air Structural Pressure Barrier StutrlPressure Boundar r Structural Steel (Carbon and Structural Sundort Low Alloy Steel) in Air Structural Pressure Barrier Structural Steel (Carbon and Pressure Boundary Containment Penetrations Low Alloy Steel) in Structural Sumort (Instrument) Demineralized Untreated Structural Pressure Barrier WaterSLow Fow Structural Steel (Wrought Pressure Boundary Austenitic Stainless Steel) in Structural Suooort Air Structural Pressure Barrier Pressure Boundary StrctuAllo Steel) (Cin And Structural Suonort Low Alloy Steel) Iir Air Structural Pressure Barrier Structural Steel (Carbon and Pressure Boundary Containment Penetrations Low Alloy Steel) in ________________
(Mechanical) Demineralized Untreated Structural Suoreort Water, Low Flow Structural Pressure Barrier Structural Steel (Wrought Pressure Boundary Austenitic Stainless Steel) in Structural SuDDort Air Structural Pressure Barrier Fasteners (High Strength Carbon and Low Alloy Steel) Structural Support in Demineralized Untreated Downcomer Tie Straos Water, Low Flow Structural Steel (Carbon and Low Alloy Steel) in Structural Support Demnineralized Untreated Srcua upr Water, Low Flow HELB Shielding Missile Barrier Structural Steel (Carbon and Pressure Boundary Drywell Lo lo te)i iStructural Pressure Barrier LowlloyStee)
InAirShielding Shelter/Protection Structural Support Page 2.4-2 SCOPING AND SCREENING REVIEW AND SCREENING REVIEW Page 2.4-2 SCOPING
NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL APPLICATION TECHNICAL INFORMATION DRAFT.
Component Component Type In Table Intended Functions 3.5.2.A .1_ _ _ __ _ _ _ _ __ _ _ _ _
Shielding Drywell Eauirment Hatch Eauipment Hatches Structural Pressure Barrier Shelter/Protection Shielding Drvwell Escape Airlock Airdocks Structural Pressure Barrier Shelter/Protection Shielding Structural Pressure Barrier Drvwell Floor Concrete in Air Shelter/Protection Stnuctural Support NSR Stnuctural Support Drywell Floor Seal Seals and Gaskets Structural Pressure Barrier comment [MRF2]: RAI 3.5.1-20 Shielding Drvwell Head Eauipment Hatches Structural Pressure Barrier Shelter/Protection Fasteners (Wrought . Structural Support Drvwell Head Closure Bolts Austenitic Stainless Steel) in Structural Pressure Barrier Air Shielding Drvwell Head Manway Equipment Hatches Structural Pressure Barrier Shelter/Protection Structural Steel (Carbon and Direct Flow Low Allo Steel in Air Shelter/Protection Drywell Jet Deflector Structural Steel (Wrought Austenitic Stainless Steel) In Dielow Air Shelter/Protection Shielding Drvwell Personnel Airlock Airlocks Structural Pressure Barrier
.Shelter/Protection Drvwell Ring Girder Structural Steel (Carbon and Stnuctural Support Low Alloy Steel) in Air Shielding Drywell Stabilizer Hatches Equipment Hatches Structural Pressure Barrier Shelter/Protection Embedded Structural Plates Structural Steel (Carbon and Structural Support Low Alloy Steel) in Air Expansion Joints Expansion Joints Pressure Bounda (Mechanical) (Mechanical)
ExoansiontGrouted Anchors Expansion/Grouted Anchors (Carbon and Low Alloy Steel) Stnuctural Support in Air Moisture Barriers Moisture Barrier Structural Pressure Barrier
_ __ ___ ___ ____ ___ ___ ___ Shelter/Protection Comment [MRF3]: RAI 3.5.1-20 Nicel-ase AloysIn ir, Pressure Boundary Primary Containment Bellows Nickel-Based Alloys in Air. Structural Support Structural Pressure Barrier Primary Containment Sump Concrete In Air Direct Flow Reactor Pedestal Concrete in Air Structural Surmort Page 2.4-3 SCOPING AND SCREENING REVIEW AND SCREENING REVIEW Page 2.4-3
NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL APPLICATION TECHNICAL INFORMATION DRAFT -
Component Component Type In Table Intended Functions 3.5.2.A-1 _ _ _ _ _ _ _ _ _ _ _ _ _ _
Reactor Pedestal Anchor Fasteners (Carbon and Low Structural Support Bolts Alloy Steel) in Air__ _ _ _ _ _ _ _ _ _ _ _ _ _
Shielding Reactor Shield Wall Concrete in Air Shelter/Protection
___ ___ ___ Structural Support Reactor Stabilizers Structural Steel (Carbon and Structural SuoDort Low Alloy Steel) In Air__ _ _ _ _ _ _ _ _ _ _ _ _ _
Fasteners (Carbon and Low Structural Suport R feigSa PltomAlloy Steel) in Air______ _________
Refueling Seal Plafom Structural Steel (Carbon and a Support Low Allov Steel) in Air Structural Suport Refueling Seal Platform Structural Steel (Wrought BAustenitic Stainless Steel) in Structural Pressure Barrier BeAir Cvcic Loading Refueling Seal Platform Aluminum Alloy in Air Shelter. Protection C overs__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Refueling Seals Polymer in Treated Water Structural Pressure Barrier Seals and Gaskets Seals and Gaskets Structural Pressure Barrier Comment [MRF4]: RAI 3.5.1-20 Structural Beams Structural Steel (Carbon and Structural Supoort Low Alloy Steel) inAir Structu Columns Structural Steel (Carbon and Shelter/Protection SucuraLow Allov Steel) in Air Structural Support Structural Fasteners Fasteners (Carbon and Low Structural Support Alloy Steel) in Air Structural Steel: Platforms. Structural Steel (Carbon and Stairways, Mezzanines Low Allov Steel) in Air Structural Sunoort Structural Steel (Carbon and Pressure Boundarv Low Allo Steel) in Air Souus Structural Support TStructural Pressure Barrier Torus Access Manhole Fasteners (High Strenath FastnersCarbon and Low Alloy Steel) Structural Support Fastnersin Air Shielding Torus Access Manholes Enuioment Hatches Structural Pressure Barrier l Shelter/Protection Vacuum Breaker Small Bore Piping (Mechanica. Pressure Bounda.
Pip ing _Mechanicl) _Pressue ________
Vacuum Relief Piping Piping (Mechanical) Pressure Boundary Vacuum Relief Valves Valves (Mechanical) Pressure Boundary Vt Header Deflector Structural Steel (Carbon and Direct Flow en ea o Low Allov Steel) in Air Shelter/Protection Vent Header Supports Structural Steel (Carbon and Structural Suonort Low Alloy Steel) in Air__ _ _ _ _ _ _ _ _ _ _ _ _ _
Structural Steel (Carbon and Low Alloy Steel) in Demineralized Untreated Structural Support I Water, Low Flow SCOPING AND SCREENING REVIEW Page 2.4-4
NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL APPLICATION TECHNICAL INFORMATION DRAFT Componen Component Type In Table Intended Functions
____________ ____3.5.2.A -1 Structural Steel (Wrought Austenitic Stainless Steel) In Structural Support Air Structural Steel (Wrouaht Austenitic Stainless Steel) in Structural Suort Demineralized Untreated Water_ Low Flow I _ _ _ _ _ _ _ __ _ _ _ _ _ _
I Component417ype Intended-Functions I Airlecks Prcscuro Boundary cwete4n- SttU Fai'SUPPOF1 Stru~tr+"al qpGt!03a0-SUpport
{r NSRC!
Equipme Pte-Hm-1clndaf (including ctabilizore)
I ExpansioGoliGts4MechaneaI) Pressure Boundary Eixpansion,!G rou cd Anc -r (Cr b and Low Alloy Stccl) in Air Fsteners (Carbon and Low Alley Steel) Structural!Functional- et i"Ak Structural Support for NSR Fasteners (High Strength Carbon and Strutaluntionalport Low Alloy Stcol) in Air Fastencr (High Strength Carbon and Loew Alloy Stcel) in DImincralizAd StricturallFunctional Surpprt Utteated-WatearLow-Flow I PpinMeMeGhanical) Pressuo Beoundary
_ Press6ure-1ourdary P erinAir ShltrPtti Mlissle-Barrier Structural Stocl (Carbon and Low Alloy r reB Stee$ Sl`)4n4 ;0nap Strustural Support for NSR Sturutural Steel (Carbon and Low Alloy Steel) in Deminealized-Untreated ProcUreBZ Watcr, Low Flow Structual/Functional.qort Structural Steeol o.
PtAustenie Prscure Bounda(
Stainlez Stel) in Air ralFunctio Structural Stocl (Wrought AustoniG6 Stainlosc Stcol) In Dominoralized Sturutua!Xunctioneal-prt Untreated-Water-LwFow Valvos (Mechanical) Proesuro Boundary N C E NN E I WP g ..
SC P N SCOPING AND SCREENING REVIEW Page 2.4-5
NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL APPLICATION APPENDIX A2 - USAR SUPPLEMENT DRAFT -
A1.1.27 NON-SEGREGATED BUS INSPECTION PROGRAM The Non-Segregated Bus Inspection Program is a-newan existing plant-specific program that manages aging effects for components and materials internal to the non-segregated bus ducts that connect the reserve auxiliary transformers to the 41 60V buses required for the recovery of offsite power following a Station Blackout (SBO) event. These normally-energized components are not subject to the environmental qualification requirements of 10 CFR 50.49, but can be affected by elevated temperatures prior to the end of the period of extended operation. Program activities include visual Comment [Cl]: NMIPIL 1912, RAI 3.62.C-6 inspections of internal portions of the bus ducts to detect cracks, corrosion, debris, dust, and moisture; visual inspections of the bus insulating system to detect embrittlement, cracking, melting, swelling, and discoloration; visual inspections of bus supports (insulators) to detect cracking and lack of structural integrity; and atrque test-iora resistance test of a sample of Comment [c2]: At the May 16.2005 NRCINEI conference. the staffyielded on accessible bolted connections. The program considers the technical the issue of retorquing the bolted information and guidance provided in applicable industry publications. connections.
Analytical trending will not be included in this activity because ability to trend inspection results is limited.tho paramteirs inspected-are not roadily gaiablenR-an-f This is an exception to the 'Monitoring Comment [c3]: Text revised tobe consistent with the Draft Rev I of the and Trending" element in Appendix A.1.2.3.5 to NUREG-1800. This program GALL.
will be implemented prior to the period of extended operation.
A1.1.28 ONE-TIME INSPECTION PROGRAM The One-Time Inspection Program is a new program that manages aging effects with potentially long incubation periods for susceptible components WSLR. Program activities include visual, volumetric, and other established inspection techniques consistent with industry practice to provide a means of verifying that an aging effect is either (1) not occurring, or (2) progressing so slowly that it has a negligible effect on the Intended function of the structure or component. The program also provides measures for verifying the effectiveness of existing aging management programs. This program is a new program that will be implemented prior to the period of extended operation.
A1.1.29 OPEN-CYCLE COOLING WATER SYSTEM PROGRAM The Open-Cycle Cooling Water System Program manages aging of components exposed to raw, untreated (e.g., service) water. This includes those portions of the Service Water (SW) system associated with the Page A2-1 NMP2 USAR NIVP2 SUPPLEMENT USAR SUPPLEMENT Page A2-1
NINE MILE POINT NUCLEAR STATION LICENSE RENEWAL APPLICATION APPENDIX A2 - USAR SUPPLEMENT DRAFT A2.1.27 NON-SEGREGATED BUS INSPECTION PROGRAM I The Non-Segregated Bus Inspection Program is a-Rewan existing plant-specific program that manages aging effects for components and materials internal to the non-segregated bus ducts that connect the reserve auxiliary transformers to the 41 60V buses required for the recovery of offsite power following a Station Blackout (SBO) event. These normally-energized components are not subject to the environmental qualification requirements of 10 CFR 50.49, but can be affected by elevated temperatures prior to the end of the period of extended operation. Program activities include visual Comment [Cl]: NMPIL 1912, RAI 3.6.2.C6 inspections of internal portions of the bus ducts to detect cracks, corrosion, debris, dust, and moisture; visual inspections of the bus insulating system to detect embrittlement, cracking, melting, swelling, and discoloration; visual inspections of bus supports (insulators) to detect cracking and lack of structural integrity; and a torque.utest o-ra resistance test of a sample of Comment [c2]: At the May 16.2005 NRC/NEI conference. the staffyielded on accessible bolted connections. The program considers the technical the issue of retorquing the bolted information and guidance provided in applicable industry publications. connections.
Analytical trending will not be included in this activity because the parameters in~spectd aro not-ability to trend inspection results is limited.Feadty quantiflable in -a-appropriate form. This is an exception to the 'Monitoring Comment [c3]: Text revised to be consistent with the Draft Rev I of the and Trending" element in Appendix A.1.2.3.5 to NUREG-1800. This program GALL will be implemented prior to the period of extended operation.
A2.1.28 ONE-TIME INSPECTION PROGRAM The One-Time Inspection Program is a new program that manages aging effects with potentially long incubation periods for susceptible components WSLR. Program activities include visual, volumetric, and other established inspection techniques consistent with industry practice to provide a means of verifying that an aging effect is either (1) not occurring, or (2) progressing so slowly that it has a negligible effect on the intended function of the structure or component. The program also provides measures for verifying the effectiveness of existing aging management programs. This program is a new program that will be implemented prior to the period of extended operation.
Page A2-14 USAR SUPPLEMENT NMP2 USAR SUPPLEMENT Page A2 14
NINE MILE POINT NUCLEAR STATION (LRA Draft: 5/20/2005 11:31 AM))
LICENSE RENEWAL APPLICATION APPENDIX B - AGING MANAGEMENT PROGRAMS AND ACTIVITIES DRAFT, B2.1.34 NON-SEGREGATED BUS INSPECTION PROGRAM The Non-Segregated Bus Inspection Program is an Rew existing plant-specific program that wil-corisists of the appropriate ten elements Comment [cl]: The bus ducts re currently inspected under S-EPMGEN-.
described in Appendix A of NUREG-1800 (Reference 1), with exceptions, yet 700, Rev. I consistent with the latest industry and regulatory guidance. This program Comment [c2]: This program inspects components and materials internal to the non-segregated bus ducts incorporates the Draft Revision I of the that connect the reserve auxiliary transformers to the 4160V buses required
- GALL and the results of the May 16,,
2005 NEl/NRC meeting. The GALL for the recovery of offsite power to both units following a Station Blackout program does not include all of the (SBO) event. They are normally energized, and therefore, the bus duct elements of NUREG1S800 (LR-SRP) so an exception is required.
insulation material will experience temperature rise due to energization, which may cause age-related degradation during the extended period of operation.
This inspection program considers the technical information and guidance provided in References 20, 21, 22, anid23, and the latest industry and regulatory information on bus duct aging management. This program will be Comment [c3]: The program incorporates the Draft Revision I of the implemented prior to the period of extended operation. GALL and tie results ofthe May 16.
2005 NEUNRC meeting.
Aging Management Program Elements The key elements of aging management activities, which are used in the Non-Segregated Bus Inspection Program, are described below. The results of an evaluation of each key element against the appropriate ten elements described in Appendix A of NUREG-1800 and the latest industry and Comment [c4]: The program incorporates the Draft Revision I of the regulatory guidance are provided below. GALL and the results of the May 16, 2005 NEVJNRC meeting.
Scope of Program I This program applies to the bus ducts within the scope of license renewal:
i.e., those non-segregated bus ducts that connect the reserve auxiliary transformers to the 41 60V buses required for the recovery of offsite power to both units following an SBO event.
Preventive Actions This is an inspection program and no actions are taken as part of this program to prevent or mitigate aging degradation.
Parameters Monitored/Inspected A sample of accessible bolted connections will be check for proper connection resistance using a'low range ohmmeter. A-6aample-of Comment [cS]: Text was revised to be consistent with the Draft Rev. I of accessible boltcd connections (bus joints and ending devices) will-be GALL checked for proper torque, or the rosistane-of bolted jeints will be checked using a micro-ohm moter of sufficient current capacity-that-is AGIN AGING MANAGEMENT MAAEMNACIITE reu-ACTIVITIES Page B-1
NINE MILE POINT NUCLEAR STATION (LRA Draft: 5/20/2005 11:31 AM))
LICENSE RENEWAL APPLICATION APPENDIX B - AGING MANAGEMENT PROGRAMS AND ACTIVITIES DRAFT.-
I suitable for chocking bus bar connoctions. This program will also-inspect the internal portions of accessible bus ducts for cracks, corrosion, foreign debris, dust buildup, and moistue-water intrusion. The bus insulation Comment [c6]: At the May16 NELNRC meeting, gth staff concurred that there should be no retorquing I system wiIl-beis inspected for signs of embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating or age-related requirement Comment [c7]: Editorial.
I degradation. The internal bus supports (insulators) will be inspected for structural integrity and cracking.
Comment [CS]: Revised to be consistent with the Draft Rev. I of GALL Detection of Aging Effects Visual inspection of internal portions of bus ducts detects cracks, corrosion, debris, dust, and moisture. Visual inspection of the bus insulating system detects embrittlement, cracking, melting, swelling, and discoloration. Visual inspection of bus supports (insulators) detects cracking and lack of structural integrity. Internal portions of bus ducts, the bus insulation system, and the bus supports (insulators) are visually Comment [cC9]: Ref: PMST. It is intended to aleviate NRC concerns inspected at least onoenominally every 40-6 years. expressed atthe May 16, 2005 NEI that the 10 year visual inspection interval is to long.
AThe ta-uetest-or-a resistance test of a sample of accessible bolted connections is-will be performed ateast-en~enominally every 40-6 years.
ThisAn program initial Inspection will be completed before the end of the initial 40-year license termand-e-ery 10 ye;rF thereafte. This is an adequate period to identify failures of the bus ducts since experience has shown that aging degradation is a slow process. A nominal 640-year inspection frequency will provide twP-up to three data points during a 20-Comment [cll]: At the May 16, 2005 year period, which can be used to characterize the degradation rate. NEIMNRC meeting, the staff concurred that there should be no retorquing requirement This will be consistent with If degradation is found in any connections, as indicated by either the GALIL, revision 1.
increased resistance or visual anomalies, the inspections will be expanded Comment [CIo]: Inserted to address a to determine the extent of the condition. consnimnent in DresdenlQuads RAI B.2.2-1 Monitoring and Trending I Monitoring and trending wi-are not be-used for this program. See "Exceptions to NUREG-1 800," below.
Acceptance Criteria Bolted connections must meet the manufcturer's mini um teoque specifications, or the low resistance of btteod joints must meet required Comment [c12]: At the May 16, 2005 NEIVNRC meeting, the staff concurred spesifiatiensappropriate for the application. Bus ducts are to be free from that there should be no retorquing -
unacceptable, visual indications of aey-surface anomalies that suggest requiremet This will be consistent with the GALL revision 1.
that conductor insulation degradation exists. An additional acceptance ciiterien criteria includes no indication of unacceptable corrosion, cracking, Comment [c13]: Text revised to be consistent with the Draft Revision I of I foreign debris, excessive dust buildup, or moisture intrusion. Any the GALL
~
ACIISPg ~ ~ MAAEMN -
AGMIG MANAGEMENTAGING~~~
ACTIVITIES Page B-2
NINE MILE POINT NUCLEAR STATION (LRA Draft: 5/20/2005 11:31 AM))
LICENSE RENEWAL APPLICATION APPENDIX B - AGING MANAGEMENT PROGRAMS AND ACTIVITIES DRAFT.-
condition or situation that, if not corrected, could lead to a loss of intended function is considered unacceptable.
Corrective Actions Corrective actions are documented using the DER process. The Quality Assurance Program Topical Report (Appendix B to Reference 12 and Appendix B to Reference 13) documents the NMPNS commitment to the corrective action criteria of 10 CFR 50, Appendix B (Reference 3). The NMPNS Corrective Action Program includes the identification and correction of conditions adverse to quality and the identification, cause determination, correction, and actions to minimize recurrence for significant conditions adverse to quality.
Confirmation Process The Quality Assurance Program Topical Report (Appendix B to Reference 12 and Appendix B to Reference 13) documents the confirmation process for NMPNS under the corrective action criterion. At NMPNS, the confirmation process is implemented through Corrective Action Effectiveness Reviews and is performed for significant conditions adverse to quality and selected hardware related conditions adverse to quality. The Corrective Action Program includes, but is not limited to, safety-related, non-safety related and fire protection SSCs. Therefore, those SSCs required to be in-scope for License Renewal are addressed as part of the current Corrective Action Program.
Administrative Controls The Non-Segregated Bus Inspection Program WI!Hbeis implemented through documents that are subject to administrative controls. The administrative controls for NMPNS are discussed in the plant's Conduct of Operations description (Section XIII in Reference 12 and Chapter 13 in Reference 13) and the Quality Assurance Program Topical Report (Appendix B to Reference 12 and Appendix B to Reference 13).
Operating Experience The Non Segregated Bur Inspection Pnrogr am at NMPNS;ot therefGef ne pi-pa....mtie-ertin r re-o is a vaillabIe. Asperatiiig oAperin is obtained, leon lothiodr ho e)illb to du-this-pegram-as needed~inspections of the bus ducts WSLR at NMPNS have not revealed any Comment [c14]: No DERs have been ,
witten on defects found while age related degradation that could result-in a loss of intended function. i performing S-EPM-GEN-700 ACTIVITIES Page B-3 MANAGEMENT ACTIVITIES AGING MANAGEMENT Page B-3
NINE MILE POINT NUCLEAR STATION (LRA Draft: 5/20/2005 11:31 AM))
LICENSE RENEWAL APPLICATION APPENDIX B - AGING MANAGEMENT PROGRAMS AND ACTIVITIES DRAFT Exceptions to NUREG-1800 Program Elements Affected
. Monitoring and Trending:
(dVer a 2U YeaFRS~G GRpcto Period, some data may; DeavaIa~Ie-w4Iwgi .. . ...
11 aI armit a rsiiflirnive' detarrminatlon 0?dear-Adat on ao2 HO 'Jr proceduralized analytical trendingwilnotbe included in this-actity beausethe r inspected are'ndt readily quantifiable in an a fo`rm.Trending actions are not included as part of this program because the'ability to trend inspection 'results is limited by available data.
This exception is consistent with most recent industry and regulatory Comment [c15]: Monitoring and Trending are not required per the Draft guidance. Rev. I of the GALL Enhancements NeneExisting site inspection procedures will be enhanced to include expanded visual and physical inspections'of the bus ducts, their supports and insulation systems. A new procedure will be developed to perform low range
- Comment [cl6]: S-EPM-.EN-700 must be enhanced to include the visual resistance checks. inspection requirements of the GALL, Revision I (Draft).
Conclusion There is reasonable assurance that aging effects will be managed by the implementation of the Non-Segregated Bus Inspection Program such that SSCs WSLR will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
MA A EM N ACTIVITIES AGN MANAGEMENT AC. ITE Pa_
___ ... B AGING Page B-4
Rmain R0. ,:o~n target for submittal on July 115, 2005.
. Qu'alit Su bm ittalI is highest objective.
. eiwAction' tes from meeting, 10