ML15196A115
| ML15196A115 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/22/2015 |
| From: | Jeffrey Mitchell License Renewal Projects Branch 1 |
| To: | |
| Mitchell J,NRR/DLR,415-3019 | |
| References | |
| TAC MF5346, TAC MF5347 | |
| Download: ML15196A115 (95) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket Nos: 50-373 and 50-374 License Nos: NPF-11 and NPF-18 Licensee: Exelon Generation Co., LLC Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Dates: March 30 - April 3, 2015 April 13 - April 17, 2015 Reviewers: J. Mitchell, Project Manager, Division of License Renewal (DLR)
D. Morey, Branch Chief, DLR M. Marshall, Branch Chief, DLR C. Hovanec, Materials Engineer, DLR S. Cuadrado de Jesús, General Engineer, DLR W. Holston, Sr. Mechanical Engineer, DLR M. Homiack, Mechanical Engineer, DLR Z. Bart Fu, Mechanical Engineer, DLR S. Min, Materials Engineer, DLR M. Yoo, General Engineer, DLR C. Doutt, Sr. Electrical Engineer, DLR J. Gavula, Mechanical Engineer, DLR V. Kalikian, Materials Engineer, DLR J. López-Ferrer, Structural Engineer, DLR G. Facco, General Engineer, DLR D. Brittner, Mechanical Engineer, DLR A. Obodoako, Materials Engineer, Division of Engineering W. Gardner, General Scientist, DLR M. Sadollah, Electrical Engineer, DLR G. Thomas, Sr. Structural Engineer, DLR C. Nolan, Mechanical Engineer, DLR Approved By: Yoira Díaz-Sanabria, Chief Projects Branch 1 Division of License Renewal Dennis Morey, Chief Aging Management of Reactor Systems Branch Division of License Renewal ENCLOSURE
Brian Wittick, Chief Aging Management of Structures, Electrical, and Systems Branch Division of License Renewal Gloria Kulesa, Chief Steam Generator Tube Integrity and Chemical Engineering Branch Division of Engineering
Introduction The U.S. Nuclear Regulatory Commission (NRC or the staff) conducted a 10-day audit at the LaSalle County Station, Units 1 and 2 (LSCS), nuclear power plant in Marseilles, IL, from March 30 to April 17, 2015. The purpose of the audit was to examine Exelon Generation Company, LLCs (Exelon or the applicant), aging management programs (AMPs) and related documentation to verify the applicants claims of consistency with the corresponding AMPs in NUREG-1801, Generic Aging Lessons Learned (GALL) ReportFinal Report, Revision 2, issued December 2010. As described in the GALL Report, the staff based its evaluation of the adequacy of each AMP on its review of the following 10 program elements in each AMP:
(1) scope of program; (2) preventive actions; (3) parameters monitored or inspected; (4) detection of aging effects; (5) monitoring and trending; (6) acceptance criteria; (7) corrective actions; (8) confirmation process; (9) administrative controls; and (10) operating experience.
Exceptions to the GALL Report AMP elements will be evaluated separately as part of the staffs review of the LSCS license renewal application (LRA) and documented in the staffs safety evaluation report (SER).
NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), Revision 2, issued December 2010, provides staff guidance for reviewing an LRA. The SRP-LR allows an applicant to reference in its LRA the AMPs described in the GALL Report. By referencing the GALL Report AMPs, the applicant concludes that its AMPs correspond to those AMPs reviewed and approved in the GALL Report and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL Report program. The applicants determination should be documented in an auditable form and maintained on site.
During the audit, the staff audited AMP elements 1 through 6 and 10 (scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, and operating experience). These elements of the applicants AMPs were claimed to be consistent with the GALL Report and were audited against the related elements of the associated AMP described in the GALL Report, unless otherwise indicated in this audit report. Elements 7 through 9 (corrective actions, confirmation process, and administrative controls) were audited during the scoping and screening methodology audit conducted March 9, 2015, to March 13, 2015, and are evaluated separately.
The staff audited all AMPs that the applicant stated were consistent with the GALL Report AMPs.
During the audit, if the applicant took credit for a program in the GALL Report, the staff verified that the plant program contained all of the elements of the referenced GALL Report program. In addition, the staff verified that the conditions at the plant were bounded by the conditions for which the GALL Report program was evaluated.
In performing the audit, the staff examined the applicants LRA, program basis documents, and related references; interviewed various applicant representatives; and conducted walkdowns of several plant areas. In total, 45 AMPs were reviewed and 36 breakout (discussion) sessions with applicant representatives were conducted. This report documents the staffs activities during the audit.
LRA AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Summary of Information in the Application. The LRA states that AMP B.2.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, is an existing program that is consistent with the program elements in GALL Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: cracking, leak, wear, loss of material, failure, degradation, damage, repair, and weld.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBS-AMP-XI.M1 Program Basis Document, ASME Section XI Inservice Inspection, Revision 1 Subsections IWB, IWC, and IWD 08/15/2014
- 2. LAS03.G03 ISI Program Plan Third 10-Year Inspection Interval Revision 2 08/10/2012
- 3. ER-AA-330 Conduct of Inservice Inspection Activities Revision 10
- 4. ER-AA-330-001 ASME Section XI Pressure Testing Revision 12
- 5. ER-AA-330-002 Inservice Inspection of Section XI Welds and Components Revision 11
- 6. ER-AA-330-009 ASME Section XI Repair/Replacement Program Revision 8
- 7. ER-AA-330-1002 LaSalle Inservice Inspection (ISI) Program Health Report Revision 7
- 8. AR00229950 Action Request, Post Qualification Required for Temper-Bead 06/20/2004 Welding
- 11. AR01623353 Action Request, ISI Exams of N2E and N2F Scope Deleted 02/19/2014
- 12. AR01651884 Action Request, IEMA Questions on 2B33-F067B Boroscope 02/25/2014 Inspection
- 13. AR02123909 Action Request, ISI Database Not Updated with Outage Scope 09/09/2014 Deletions During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by
known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the updated final safety analysis report (UFSAR) supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M1.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.2, Water Chemistry Summary of Information in the Application. The LRA states that AMP B.2.1.2, Water Chemistry, is an existing program with an exception that is consistent with the program elements in GALL Report AMP XI.M2, Water Chemistry. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff reviewed the exception associated with this AMP, which will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: water chemistry, foul, and treated water.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M2 Program Basis Document Revision 2
- 2. AR00130672 Reactor Coolant Chloride Concentration Exceeded the EPRI Action 11/2002 Level 1 Limits
- 3. AR00257405 U2 Stator Cooling Water Chemistry Goal Exceeded 09/23/2004
- 4. AR01651623 Chemistry Dose over Sac Projection 04/25/2014
- 5. AR01498293 U-1 HD Tank Dissolved O2 Indication Erratic 04/06/2013
- 6. AR00200922 MC Tank Chemistry Results above Limits per CY-AB-120-200 02/11/2004
- 7. AR01493260 Chemistry Review of Raw Water Performance FASA Deficiency 03/27/2013
- 9. AR01191677 C RT Conductivity High 03/24/2011
Revision /
Document Title Date
- 12. CY-AB-120-120 BWR Startup Chemistry Revision 9
- 13. CY-AB-120-130 BWR Shutdown Chemistry Revision 10
- 14. CY-AB-120-200 Storage Tanks Chemistry Revision 9
- 15. CY-AB-120-300 Spent Fuel Pool Revision 12
- 16. CY-AB-120-310 Suppression Pool/Torus Chemistry Revision 7
- 17. CY-AB-120-320 Control Rod Drive Water Chemistry Revision 6
- 18. AR01666956 HWC Performance for Unit 2 Availability for May 2014 Not Met 06/02/2014
- 19. AR01616738 HWC Performance for Unit 1 Availability for January 2014 Not Met 02/04/2014
- 20. AR01616747 HWC Performance for Unit 2 Availability for January 2014 Not Met 02/04/2014
- 21. AR01657505 HWC Performance for Unit 1 Availability for January 2014 Not Met 05/08/2014 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed exception.
During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the scope of program program element not associated with the exception are consistent with the corresponding program elements in the GALL Report AMP. The staffs evaluation of aspects of this program element associated with the exception will be addressed in the SER.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M2. The staff also verified that for the scope of program program element, the aspects of the LRA AMP program element not associated with the exception are consistent with the corresponding program element in GALL Report AMP XI.M2.
The staffs evaluation of aspects of the program element associated with the exception will be addressed in the SER.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.3, Reactor Head Closure Stud Bolting Summary of Information in the Application. The LRA states that AMP B.2.1.3, Reactor Head Closure Stud Bolting, is an existing program with exceptions that is consistent with the program elements in GALL Report AMP X.M3, Reactor Head Closure Stud Bolting. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff reviewed the exceptions associated with this AMP. The exceptions will be evaluated and documented in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: bolt, bolting, closure stud, stress corrosion cracking, wear, cracking, and stuck.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PDB-AMP-X.M3 Program Basis Document - Reactor Head Closure Stud Bolting Revision 2
- 2. ER-0113-8720-R1 Reactor Pressure Vessel Washer Indications, LaSalle 1, GE Hitachi Revision 1 Nuclear Energy 02/2010
- 3. DRF 137-0010 Fracture Mechanics Based Structural Margin Evaluation for 09/1991 GE-NE-523-93-0991 Commonwealth Edison BWR Reactor Pressure Vessel Head Studs
- 4. LAS03.G03 LaSalle County Nuclear Power Station, Units 1 & 2, ISI Program Revision 2 Plan, Third 10-Year Inspection Interval, LAS03.G03 08/10/2012
- 7. ISI-05-07-2004 Post-Outage 90-Day Inservice Inspection Reports 05/07/2004
- 8. ISI-06-01-2007 Post-Outage 90-Day Inservice Inspection Reports 06/01/2007
- 9. ISI-05-28-2008 Post-Outage 90-Day Inservice Inspection Reports 05/28/2008
- 10. ISI-05-08-2009 Post-Outage 90-Day Inservice Inspection Reports 05/08/2009
- 11. ISI-06-03-2011 Post-Outage 90-Day Inservice Inspection Reports 06/03/2011
- 12. ISI-06-05-2012 Post-Outage 90-Day Inservice Inspection Reports 06/05/2012 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed exceptions. During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by
known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description to be consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M3. The staff also verified that for the preventive actions program element, the aspects of the LRA AMP program element not associated with the exception are consistent with the corresponding program element in GALL Report AMP XI.M3.
The staffs evaluation of aspects of the program element associated with the exception will be addressed and documented in the SER.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.4, BWR Vessel ID Attachment Welds Summary of Information in the Application. The LRA states that AMP B.2.1.4, BWR Vessel ID Attachment Welds, is an existing program that is consistent with the program elements in GALL Report AMP XI.M4, BWR Vessel ID Attachment Welds. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: cracking, wear, hold down, core spray, attachment welds, steam dryer, and jet pump.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M4 Program Basis Document, BWR Vessel ID Attachment Welds Revision 0 03/25/2014
- 3. ER-AB-331-1001 Boiling Water Reactor (BWR) Internals Program Revision 8
- 4. EPRI1009948 BWRVIP-48-A, BWR Vessel and Internals Project, Vessel ID 06/2004 Attachment Weld Inspection and Flaw Evaluation Guidelines
- 6. LS-AA-126-1001 LaSalle Reactor Vessel and Internal and Internals Program Revision 7 Pre-BWRVIP/INPO Focused Area Self-Assessment
Revision /
Document Title Date
- 7. EC346971 LaSalle 1 Dryer Indications, Disposition of Steam Dryer and Steam Revision 0 Dryer Support 02/04/2004
- 9. AR00162050 Action Request, Inspection of Reactor Internals Varies from 06/05/2003 BWRVIP Guidance
- 10. AR00167816 Action Request, Unit 1 Shroud Support Gusset Inspection Deviation 07/16/2003 from BWRVIP
- 11. AR00734170 Action Request, Surveillance Sample Holder at 120o Disengaged; 02/10/2008 INR 08-29
- 12. AR00735887 Action Request, LP Core Spray Piping Bracket Indication; 02/13/2008 INR 08-05
- 13. AR00871301 Action Request, New Welds Identified on Core Spray Piping: 01/24/2009 CNR 09-02
- 14. AR01331736 Action Request, INR IVVI 12-38; Metal Sliver Remains on Dryer 02/24/2012 Support Lug
- 15. AR01477597 Action Request, Additional Minor Wear on FW Sparger End Bracket 02/20/2013 Pins
- 16. AR01622580 Action Request, RM-INR IVVI-14-13 Metal Sliver Remains on Top of 02/18/2014 Dryer Lug
- 17. AR01699331 Action Request, INPO BWRVIP Assessment Actions 09/03/2014 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M4.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.5, BWR Feedwater Nozzle Summary of Information in the Application. The LRA states that AMP B.2.1.5, BWR Feedwater Nozzle, is an existing program that is consistent with the program elements in GALL Report AMP XI.M5, BWR Feedwater Nozzle. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: feedwater nozzle, crack, and fatigue.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M5 Program Basis Document GALL Program XI.M5 - BWR Feedwater Revision 0 Nozzle 02/11/2014
- 7. NA Final Report, LSCS 3rd Interval, 2nd period - Outage L1R14 Final 02/01/2012 Report by GEH Nuclear Energy
- 8. GEH-RPT-7480-268H Final Report, LSCS Outage L2R13 ISI Final Report by GEH Nuclear 02/01/2012 6X-HA2-ISI Energy
- 9. NA Email from Andrew Kochis to James Jordan, RE: License Renewal 12/17/2013 Question - Feedwater Nozzle Program
- 10. ER-AA-330-1002 3rd Quarter 2014 ISI Program Health Revision 6 2014
- 11. LAS03.G03 LaSalle ISI Program Plan for the 3rd ISI Inspection Interval Revision 2 08/10/2012 12 .Module 077 LSCS Operations Training Program, Feedwater System, Module Revision 13 077 05/07/2012
- 13. ER-AA-330-009 ASME Section XI Repair/Replacement Program Revision 7
- 14. L-002822 LaSalle 1 Feedwater Nozzle NUREG-0619 Evaluation Revision 0 06/05/2002
- 15. L-002823 LaSalle 2 Feedwater Nozzle NUREG-0619 Evaluation Revision 0 06/05/2002
- 16. ER-AA-330 Conduct of Inservice Inspection Activities Revision 10
- 17. ER-AA-330-002 Inservice Inspection of Section XI Welds and Components Revision 11
- 18. CR-26 Relief Request: CR-26 Revision 00
Revision /
Document Title Date
- 19. CR-26 SER Safety Evaluation by the Office of Nuclear Reactor Regulation on 11/21/2009 the Second 10-year Interval Inservice Inspection Request for Relief CR-26
- 20. GE Hitachi Letter LaSalle Unit-2 Nozzle to Shell Weld LCS 2-N4D Ultrasonic Data 04/03/2015 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
During the audit, the staff made the following observations regarding the operating experience program of the BWR Feedwater Nozzle AMP:
- After reviewing the inspection results, the staff noted that earlier inspections had less coverage area than 100 percent. The staff asked why less than 100-percent inspection coverage was acceptable. In response, the applicant stated that it issued Relief Request No. CR-26 to allow for reduced inspection coverage. After reviewing CR-26 and the staffs corresponding evaluation, the staff finds this response acceptable because the staff previously evaluated and accepted the relief request to allow less than 100-percent inspection coverage.
- After reviewing the inspection results, the staff noted that the Unit 2 nozzles inspection from 2002 showed 10 indications with 78-percent coverage, and later inspections achieved much higher coverage with fewer indications. The staff found the basis for this change in coverage area unclear, and it asked the applicant to provide further information on the inspections to clarify this issue. In response, the applicant provided a letter dated April 3, 2015, from General Electric Hitachi Nuclear Energy (GE Hitachi).
The letter states that, after the 2002 inspections, the applicant applied Code Case N-613-1, Ultrasonic Examination of Penetration Nozzles in Vessels, Examination Category B-D, Item Nos. B3.10 and B3.90, Reactor Nozzle-to-Vessel Welds, Figs.
IWB-2500-7(a), (b), and (c), Section XI, Division 1, dated August 20, 2002, which reduced the size of the examination volume. A portion of the indications in the earlier inspections were outside of the reduced examination volume used in the latter examinations, and this fully accounts for the discrepancy. The staff approved Code Case N-613-1 referenced in Regulatory Guide (RG) 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, issued August 2014. The staff finds this acceptable because the staff reviewed and accepted the reduced inspection area referenced in the Code Case.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and
trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M5.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.6, BWR Control Rod Drive Return Line Nozzle Summary of Information in the Application. The LRA states that AMP B.2.1.6, BWR Control Rod Drive Return Line Nozzle, is an existing program that is consistent with the program elements in GALL Report AMP XI.M6, BWR Control Rod Drive Return Line Nozzle. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: control rod drive, return line nozzle, and cracking.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M6 Program Basis Document - BWR Control Rod Drive Return Line Revision 0 Nozzle 02/11/2014
- 2. 391N0136 LaSalle Unit 1 N10 Cap and Nozzle Modification Report, Fall 1977 Project 391N0136, Performed by General Electric
- 3. 391N0136 LaSalle Unit 2 N10 Cap and Nozzle Modification Report, Spring 1978 Project 391N0136, Performed by General Electric
- 4. Drawing E232938 Nozzle Details Revision 6
- 11. ER-AA-330 Conduct of Inservice Inspection Activities Revision 10
- 12. ER-AA-330-002 Inservice Inspection of Section XI Welds and Components Revision 11
- 13. LS-AA-126-1001 FASA Self-Assessment Report Revision 6
- 15. N/A Letter M.H. Richter, CECO to NRC, LSCS Units 1 and 2 Request for 06/30/1989 Additional Information to GL 88-01
Revision /
Document Title Date
- 16. UFSAR LaSalle County Power Station, Updated Final Safety Analysis Report Revision 20 04/2014 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit, the staff made the following observation:
- The staff reviewed the UFSAR to confirm that the applicant implemented the requirements in NUREG-0619, BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking: Resolution of Generic Technical Activity A-10 Revision 1, issued November 1980, by capping the control rod drive (CRD) return line nozzle and removing the return line. The return line was removed and not rerouted. These modifications occurred before LSCS received an operating license. Because the staff reviewed the CRD system and modifications as part of the initial licensing, a response to Generic Letter (GL) 80-095, Generic Activity A-10, dated November 13, 1980, was not required.
There are no ongoing maintenance or testing activities from NUREG-0619 that would apply to LSCS. Therefore, under its BWR Control Rod Drive Return Line Nozzle Program, the applicant conducts only periodic examinations to detect the effects of cracking in accordance with American Society of Mechanical Engineers (ASME) Code, Section XI, Table IWB-2500-1.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M6.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.7, BWR Stress Corrosion Cracking Summary of Information in the Application. The LRA states that AMP B.2.1.7, BWR Stress Corrosion Cracking, is an existing program that is consistent with the program elements in GALL Report AMP XI.M7, BWR Stress Corrosion Cracking. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: SCC, IGSCC, stress corrosion, weld, and safe end.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M7 Program Basis Document: BWR Stress Corrosion Cracking Revision 0 03/31/2014
- 2. Docketed Letter Dresden Station Units 2 and 3 Quad Cities Stations Units 1 and 2 07/29/1988 LaSalle County Station Units 1 and 2 Response to Generic Letter 88-01 (Docket Nos. 50-237/249, 50-245/265, 50-373/374)
- 3. Docketed Letter LaSalle County Station Units 1 and 2 Request for Additional 06/30/1989 Information to Generic Letter 88-01 (TAC Nos. 69141 and 69142)
- 4. Docketed Letter Review of Response to Generic Letter 88-01, NRC Position on 08/22/1990 IGSCC in BWR Austenitic Stainless Steel Piping, LaSalle County Station, Units 1 and 2 (TAC Nos. 69141 and 69142)
- 5. Docketed Letter LaSalle County Station Units 1 and 2 Response to NRC Request for 11/05/1990 Additional Information Concerning the Review of Response to Generic Letter 88-01 (NRC Docket No. 50-373 and 50-374)
- 6. Docketed Letter LaSalle County Station, Units 1 and 2 - Relief Request I3R01, 04/29/2008 Associated with the Third 10-year Interval for LaSalle County Station, Units 1 and 2 (TAC Nos. MD5457 and MD5458)
- 7. ER-AA-330 Conduct of Inservice Inspection Activities Revision 10
- 8. ER-AA-330-002 Inservice Inspection of Section XI Welds and Components Revision 11
- 9. LAS03.G03 ISI Program Plan Third 10-Year Inspection Interval LaSalle County Revision 2 Station, Units 1 & 2 08/10/2012
- 10. LAS03.G05 ISI Selection Document Third 10-Year Inspection Interval LaSalle Revision 1 County Station, Units 1 & 2 03/31/2011
- 11. RA14-018 Post-Outage 90-Day Inservice Inspection (ISI) Summary Report 05/29/2014 (LaSalle County Station Unit 1)
- 12. RA13-023 Post-Outage 90-Day Inservice Inspection (ISI) Summary Report 05/31/2013 (LaSalle County Station Unit 2)
- 13. AR1464425 Category D IGSCC Weld Status 01/18/2013
- 14. AR1682506 Define IGSCC Exam Bases and Components 07/16/2014
- 15. AR1682506-04 Assignment Number 4 of AR1682506 02/02/2015 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information
necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing requests for additional information (RAIs) for the subjects discussed below.
- The LRA indicates that the Risk-Informed Inservice Inspection Program incorporates welds classified as Category A (resistant materials) in accordance with the staff-approved Electric Power Research Institute (EPRI) Topical Report TR-112657, Revision B-A, Final Report, Revised Risk-Informed Inservice Inspection Evaluation Procedure, issued December 1999. The staff noted that the inspection extent for Category A welds incorporated in the Risk-Informed Inservice Inspection Program may not be consistent with the guidance provided in GL 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping, dated January 25, 1988, and BWR Vessel and Internals Project (BWRVIP)-75-A, BWR Vessel and Internals Project Technical Basis for Revisions to Generic Letter 88-01 Inspection, issued October 2005. Therefore, additional information is necessary to confirm whether the program is adequate to manage cracking caused by intergranular stress corrosion cracking (IGSCC) for Category A welds.
- The applicants inservice inspection selection document dated March 31, 2011, for the third 10-year interval indicates that the number of Category B welds selected for inspections at Unit 2 is less than the number of Category B welds to be inspected in accordance with BWRVIP-75-A. In addition, the number of Category C welds selected for inspection at Unit 2 is less than the number of Category C welds to be inspected in accordance with BWRVIP-75-A. Therefore, additional information is necessary to confirm the adequacy of the program with GALL Report AMP XI.M7.
- The staff noted that the inservice inspection summary report, dated May 31, 2013, for LSCS Unit 2 indicates that the examination coverage of the BWRVIP-75-A inspections for Category B welds was as low as 50 percent. The staff needs additional information to determine whether the limited examination coverage of the applicants inspections is adequate to manage cracking due to IGSCC.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M7. The staff also identified certain aspects of the detection of aging effects program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.8, BWR Penetrations Summary of Information in the Application. The LRA states that AMP B.2.1.8, BWR Penetrations, is an existing program that is consistent with the program elements in GALL Report AMP XI.M8, BWR Penetrations. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: crack, penetration, nozzle, stress corrosion, CRD, RPV, and SCC.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M8 Program Basis Document BWR Penetrations Revision 0 05/01/2015
- 9. ER-AA-330 Conduct of Inservice Inspection Activities
- 10. ER-AA-330-001 Section XI Pressure Testing
- 11. ER-AA-330-002 Inservice Inspection of Section XI Welds and Components During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and
trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M8.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.9, BWR Vessel Internals Summary of Information in the Application. The LRA states that AMP B.2.1.9, BWR Vessel Internals, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M9, BWR Vessel Internals. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: shroud, jet pump, stress corrosion cracking, embrittlement, cast, steel, bolt, nickel alloy, and top guide.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M9 Program Basis Document - BWR Vessel Internals Revision 1 12/08/2014
- 3. AR465798 Flaws Observed in Core Shroud Examination, March 13, 2006 03/13/2006
- 4. LAS03.G03 LaSalle County Station ISI Program Plan, 3rd 10-Year Inspection Revision 3 Interval
- 5. AR1358938 Results from L1R14 Exam of Core Shroud Horizontal Welds 03/06/2012
- 7. ER-AB-331-1001 Boiling Water Reactor (BWR) Internals Program Revision 8
- 8. ER-AB-331-101 Evaluation for Thermal Aging/Neutron Embrittlement of BWR Reactor Revision 3 Internal Components
- 9. LTS-600-8 Reactor Vessel Internals Inservice Inspection during Refueling Revision 23 07/15/2013
- 10. I3R-02 10 CFR 50.55a Relief Request: Use of BWRVIP Guidelines in Lieu Revision 1 of Specific ASME Code Requirements Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(i)
- 11. AR199081 Flaws in Jet Pump Riser Weld RS-9 on Jet Pump 5/6 and 02/02/2004 Jet Pump 9/10
Revision /
Document Title Date
- 12. AR1331470 IVVI INR 12-28 Indications on RS-9 of Jet Pump 3/4 02/22/2012 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
In addition, the staff found that, for the scope of program program element, the availability of information was not sufficient to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.
- The scope of program program element of the LRA AMP states that inspections and evaluations of the top guide are performed in accordance with BWRVIP-26-A, BWR Vessel and Internals Project, BWR Top Guide Inspection and Flaw Evaluation Guidelines, dated November 3, 2004, and BWRVIP-183, BWR Vessel and Internals Project, Top Guide Grid Beam Inspection and Flaw Evaluation Guidelines, dated December 18, 2007. The GALL Report AMP recommends that an AMP use only specific portions of the BWRVIP-183 guidelines that are associated with reinspection scope and frequency for the top guide gridbeams. It is not clear to the staff whether only BWRVIP-26-A will be used as flaw evaluation guidance because the NRC has not endorsed BWRVIP-183 for that purpose.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is not bounded by known industry operating experience. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.
- The LRA does not clearly address whether the applicants program resolved the concern about jet pump vibration resulting from slip joint leakage flow instability, pump resonance, or turbulent flow. The LRA does not address assessment of plant-specific operating experience regarding jet pump vibration and loss of material due to wear of jet pump wedges and restrainer brackets at their interfaces. The staff needs additional information to determine whether the program needs to be enhanced with additional AMP activities and inspections based on an adequate assessment of operating experience.
- Core shroud categories are important factors for determining the inspection scope and interval for core shroud welds. However, LRA Section B.2.1.9 and the onsite program basis document do not address the category of the Unit 2 core shroud. In addition, the LRA and program basis document do not provide the applicants assessment of operating experience for the Unit 2 core shroud (e.g., crack growth trends during inspection intervals) to demonstrate the adequacy of inspection intervals that the applicant implements in its program.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description to be consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M9. The staffs evaluation of aspects of the program elements associated with enhancements will be addressed in the SER. The staff also identified certain aspects of scope of program program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also found that additional information may be required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.10, Flow-Accelerated Corrosion Summary of Information in the Application. The LRA states that AMP B.2.1.10, Flow-Accelerated Corrosion, is an existing program that is consistent with the program elements in GALL Report AMP XI.M17, Flow-Accelerated Corrosion, as modified by License Renewal Interim Staff Guidance (LR-ISG)-2012-01, Wall Thinning Due to Erosion Mechanisms, which was published in the Federal Register on November 22, 2013 (Volume 78 of the Federal Register, page 226). To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: fac, flow accelerated corrosion, and erosi.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. LA-PBD-AMP-XI.M17 Program Basis Document, Flow-Accelerated Corrosion Revision 0
- 2. ER-AA-430 Conduct of Flow-Accelerated Corrosion Activities Revision 007
- 3. ER-AA-430-1001 Guidelines for Flow-Accelerated Corrosion Activities Revision 011
- 4. ER-AA-430-1004 Erosion in Piping and Components Guide Revision 001
- 5. N/A Program Health Report, Flow-Accelerated Corrosion Program 1st Quarter 2012-4th Quarter 2014
- 6. AR00586951 Minimum Pipe Wall Thickness Concerns with 2DG06A-4" 02/02/2007
- 7. AR01184537 An MSR has 18" Steam Plume Leak 03/07/2011
- 8. AR00300975 During FAC Examinations, a T Code Minimum Wall Violation 02/13/2005 was Noted
Document Title Revision / Date
- 9. AR00301782 Steam Impingement on 2CB01AA/AB Heat Exchangers 02/15/2005
- 10. AR00601311 CSCS Strainer 2E12-D300A had Area below Minimum Wall 03/08/2007
- 13. AR01516895 Through Wall Steam Leak on 1RI07B-2" Pipe 05/22/2013
- 14. AR00733763 Minimum Wall Violation 02/09/2008
- 15. LER 374 2015-001 HPCS Cooling Water Pump Erosion 02/27/2015
- 16. LER 374 2013-001 HPCS Leak due to Cavitation 06/17/2013 During the audit of program elements one through six, the staff verified that the preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the scope of program and detection of aging effects, program elements, the staff will consider issuing an RAI for the subject discussed below.
- During the AMP audit, the applicant stated that, after it submitted the LRA, it had implemented NSAC-202L, Revision 4, for its Flow-Accelerated Corrosion Program. It is unclear to the staff how Revision 4 to NSAC-202L will satisfy the recommendations of the GALL Report AMP XI.M17, as modified by LR-ISG-2012-01, which only addresses implementation of NSAC-202L, Revision 2 or Revision 3.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M17, as modified by LR-ISG-2012-01, with the exception of staff-identified differences between the applicants program and GALL Report XI.M17. The staff identified certain aspects of the scope of program and detection of aging effects program elements of the LRA AMP for which additional information or additional evaluation is required before adequacy can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.11, Bolting Integrity Summary of Information in the Application. The LRA states that AMP B.2.1.11, Bolting Integrity, is an existing program with enhancements that will be consistent with the program
elements in GALL Report AMP XI.M18, Bolting Integrity. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the lake screen house building service and circulating water pumps and auxiliary building diesel generator for Unit 1. The staff also conducted an independent search of the applicants operating experience database using the keywords: crack, bolt, leak, torque, corrosion, rust, preload, and loose.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M18, Program Basis Document GALL Program XI.M18-Bolting Integrity Revision 2 Revision 2
- 2. AR00093598 Report Failure Analysis on 1B33-F060A 03/30/2005
- 3. Same as Title Post-Outage 90-Day Inservice Inspection (ISI) Summary Report 05/06/2012
- 4. AR01032809 Report Severe Corrosion to Cooling Water Strainer End Cover 12/31/2010
- 5. AR00838762 Report Improper Thread Engagement 10/31/2008
- 6. AR00730632 Report 2B33-F387B Valve Body Missing Bolt 02/02/2008
- 7. AR01124139 Report Make Up and Blowdown Butterfly Valve Fasteners Corroded 10/09/2010
- 8. AR00428643 Report Bonnet to Body Leak 11/29/2005
- 9. AR00545274 Report Minor Leaks Observed on 0FP01KB Engine during Run 10/17/2006
- 10. MA-AA-410 Bolting Integrity Aging Management Program Revision 0
- 11. ER-AA-2030 Conduct of Plant Engineering Manual Revision 14
- 12. MA-MW-736-600 Torqueing and Tightening of Bolted Connections Revision 5
- 13. PES-S-010 Fasteners Revision 0 14 ER-AA-330-001 Section XI Pressure Testing Revision 12 15 WO 01426286-01 Clean Unit 1 A CW Inlet Bay & Bypass Line 01/14/2013
- 16. WO 01422993-01 Clean Unit 1 A CW Inlet Bay 02/16/2013
- 17. Job 02-07-205 1A CW01PA Bay Inspection Report 03/27/2013
- 18. Same as Title Unit 1 Service Water Tunnel Inspection Report 11/25/2013
- 19. Same as Title Unit 2 Service Water Tunnel Inspection Report 11/22/2013
- 20. WO 01441059 [Unit 1] Inspection of North End of WS [Water Service] for Corbicula 11/22/2013 and Sediment
- 21. WO 01304105 [Unit 1] Inspection of North End of WS [Water Service] for Corbicula 05/24/2011 and Sediment
- 22. WO 01435788 [Unit 2] Inspection of South End of WS [Water Service] for Corbicula 11/22/2013 and Sediment
Revision /
Document Title Date
- 23. WO 01058326 [Unit 2] Inspection of South End of WS [Water Service] for Corbicula 05/12/2009 and Sediment
- 24. WO 00835807 [Unit 2] Inspection of South End of WS [Water Service] for Corbicula 05/23/2007 and Sediment The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit, the staff made the following observations:
- LRA Section B.2.1.11 includes an enhancement (Enhancement 1) to the preventive actions, parameters monitored or inspected, detection of aging effects, and corrective actions program elements to ensure the proper specification of bolting material, lubricants and sealants, storage, and installation torque or tension to prevent or mitigate the degradation and failure of closure bolting. The staff noted that the respective GALL Report AMP XI.M18 program elements recommend the implementation of the guidelines in the following reports to prevent and mitigate degradation and failure of closure bolting: EPRI-NP 5769, Degradation and Failure of Bolting in Nuclear Power Plants, Volumes 1 and 2, dated May 5, 1988; NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants, issued June 1990; and EPRI TR-104213, Bolted Joint Maintenance and Applications Guide, issued December 1995. The staff notes that the AMP is consistent with the GALL Report recommendations for guidelines that should be referenced in the applicants Bolting Integrity Program basis document or procedures to make the AMP consistent with the GALL Report AMP XI.M18, or both. During the audit, the staff reviewed the Bolting Integrity Program basis documents and existing procedures. As part of its review, the staff verified that the guidelines recommended by the GALL Report AMP XI.M18 were either already included in the existing procedures or were identified in the program basis documents as guidelines to be added to the procedures before the period of extended operation.
- LRA Section B.2.1.11 includes an enhancement (Enhancement 5) to the parameters monitored or inspected and detection of aging effects program elements. The LRA states that the applicant will implement the enhancement to the Bolting Integrity Program to perform visual inspections of submerged bolting for the service water diver safety barrier and diesel fire pump suction screens for loss of material and loss of preload during maintenance activities. During the audit, the staff reviewed work orders for maintenance of the Unit 1 and Unit 2 service water tunnels. Based on its review, the staff noted that the service water diver safety barriers and diesel fire pump suction screens located in the service water tunnels of Unit 1 and Unit 2 are inspected by divers during maintenance activities done to clean and remove foreign material (e.g., sediment, Bryozoa growth, and corbicula) from the diver safety barriers, diesel fire pump, service water pump, and other components in the tunnels. The staff also noted that bolts are inspected during these maintenance activities. In addition, based on its review of
pertinent work orders and documentation of the service water tunnel inspections done since 1998, the staff noted that these maintenance activities are completed approximately once every 2 years.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M18. The staffs evaluation of aspects of the program elements associated with enhancements will be addressed in the SER.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.12, Open-Cycle Cooling Water System Summary of Information in the Application. The LRA states that AMP B.2.1.12, Open-Cycle Cooling Water System, is an existing program with enhancements that will be consistent with the elements in GALL Report AMP XI.M20, Open-Cycle Cooling Water System. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP, which will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of portions of the lake screen house, one of the service water pump rooms, and one of the diesel generator rooms. The staff also conducted an independent search of the applicants operating experience database using keywords: biofoul, erosi, heat sink, heat trans, mic, min wall, nodu, service water, sediment, and 89-13.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified during the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date LA-PBD-AMP-XI.M20 Program Basis Document, Open-Cycle Cooling Water System Revision 2 ER-AA-340 GL 89-13 Program Implementing Procedure Revision 7 ER-AA-340-1001 GL 89-13 Program Implementation Instructional Guide Revision 9 ER-AA-5400-1001 Raw Water Corrosion Program Revision 7
Document Title Revision / Date Docketed Letter Generic Letter 89-13 Revised Response LaSalle County Station 07/28/1998 Docketed Letter 2004 Regulatory Commitment Change Summary Report 10/11/2005 Commitment Revision Tracking Nos.04-003 through 04-008 Docketed Letter 2005 Regulatory Commitment Change Summary Report 09/15/2006 Commitment Revision Tracking No.05-001 Docketed Letter 2006 Regulatory Commitment Change Summary Report 12/14/ 2007 Commitment Change Tracking No.06-002 Docketed Letter 2007 Regulatory Commitment Change Summary Report 12/05/2008 Commitment Change Tracking No.06-004 Docketed Letter 2008 Regulatory Commitment Change Summary Report 11/18/2009 Commitment Change Tracking No.08-002, 08-003 Docketed Letter 2009 Regulatory Commitment Change Summary Report 05/07/2010 Commitment Change Tracking No.08-001 N/A System and Structure Screening Report, Essential Cooling Revision 5 Water System AR02429128 Leak Identified at Base of Weld 12/23/2014 AR01595598 Additional IEMA Questions on Minimum Wall Issues 12/11/2013 AR01374663 Monitor 0Ws32A-4" per Raw Water Corrosion Program 06/05/2012 AR01186590 Aged Service Water Pipe Degradation 03/11/2011 AR00706455 LaSalles Inspection Results from Byrons SX Piping Failure 12/03/2007 AR00176406 Belzona Coating Pieces Found in Upstream Piping 09/18/2003 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
As part of the audit, the staff reviewed the System and Structure Screening Report, Essential Cooling Water System, and noted that the component type fish barrier includes the stainless steel buoy cylinders, cable, and wire cloth. The accompanying comment states that a shad net is installed in the lake screen house flume and that the polymeric portions of the shad net (netting, twine, and ty-wraps) are periodically replaced, making them short-lived and not subject to an aging management review (AMR).
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and
trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M20. The staffs evaluation of aspects of the program elements associated with the enhancements will be addressed in the SER.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.13, Closed Treated Water Systems Summary of Information in the Application. The LRA states that AMP B.2.1.13,Closed Treated Water Systems, is an existing program with an enhancement that will be consistent with the program elements in GALL Report AMP XI.M21A, Closed Treated Water Systems. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancement associated with this AMP. The enhancement will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: crack, erosion, and leak.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date LA-PBD-AMP-CI.M21A Program Basis Document, Closed Treated Water Systems Revision 1 CY-AA-120-400 Closed Cooling Water Chemistry (Corporate) Revision 12 CY-AA-120-4000 Closed Cooling Water Chemistry Strategic Plan Revision 4 LOP-WR-03 Reactor Building Closed Cooling Water System Chemical Addition Revision 5 LOP-VP-08 Primary Containment Chilled Water System Revision 8 IR 1614782-02 Review Fleet Sulzer RRP Designs. Determine Applicability of 01/28/2014 Monticello OPEX and Generate Actions if Any.
AR01451534 Leakage from WR System 12/12/2012 AR01232663 0 RBCCW Heat Exchanger Needs Repair during Next Inspection 06/24/2011 AR01207987 Trends in 1 RBCCW CCW - Increasing Nitrates 04/26/2011 AR00299270 WR Inlet Piping to 2A RR Motor Air Cooler is Leaking 02/09/2005 AR00200440 1B RR Pump Motor Cooler Leaking 02/09/2004 AR00200182 Potential Leak in 1B RR Pump East Winding Cooler 02/06/2004 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancement. During the audit, the staff verified that the scope of program, preventive actions, monitoring and trending, and
acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In order to verify that the enhancement will make the AMP adequate to manage the applicable aging effects, the staff will consider issuing RAIs for the subjects discussed below.
(1) The LRA AMP states that the parameters monitored or inspected and detection of aging effects program elements will be enhanced by performing condition monitoring inspections on a representative sample of piping and components.
Where practical, the applicants sample selection will focus on locations that are most susceptible to corrosion, stress corrosion cracking, or fouling, and they will be inspected at an interval not to exceed once in 10 years during the period of extended operation. Although the GALL Report AMP recommends inspections of a representative sample, SRP-LR Section A.1.2.3.4 states that when sampling is used to represent a larger population of components, applicants should provide the basis for the sample size. Because the applicant did not include any details about the sample size, the staff could not ensure that the applicants sample size will provide reasonable assurance that the effects of aging would be adequately managed.
(2) The LRA AMP states that the aging effects being managed by the Closed Treated Water System program include reduction of heat transfer. During its review of the LRA, the staff noted that the heat exchanger tubes in LRA Table 3.3.1-8, Diesel Generator and Auxiliaries System, are the only components for which this AMP manages this aging effect. The staff also noted that the heat exchanger tubes for the drywell penetration cooling coils in LRA Table 3.3.2-1, Closed Cycle Cooling Water System, are not being managed for reduction of heat transfer because crediting the cooling of the drywell penetrations is not necessary for license renewal. In that regard, the staff noted that, for managing the aging of concrete exposed to elevated temperatures (AMR item 3.5.1-3), the applicant stated this item was not applicable because localized concrete temperatures greater than 200 °F were not reported. The staff noted that, although crediting the cooling of the drywell penetrations may not be required, cooling of the drywell penetrations is the reason why localized concrete temperatures greater than 200 °F were not reported.
The staff will consider issuing an RAI to clarify whether cooling to the drywell penetration coils will be credited for license renewal or whether the concrete adjacent to the drywell penetrations will be managed for aging effects related to elevated temperatures.
During the audit of the operating experience program element, the staff reviewed Exelons evaluation of industry operating experience related to closed treated water systems. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.
(1) The LRA AMP states that the aging effects being managed by the Closed Treated Water System program include cracking. During its review of the LRA, the staff noted that the heat exchanger tubes and tube sheets in LRA Table 3.3.1-8, Diesel Generator and Auxiliaries System, are the only components for which this AMP manages this cracking. During its review of operating experience, the staff identified plant-specific reports that did not appear to be considered for determining applicable aging effects. Specifically, Action Request (AR)00299270,
AR00200440, and AR00200182 document cracking in the heat exchanger tubes associated with the reactor recirculation pump motor coolers. However, heat exchanger tubes and tube side components for the reactor recirculation pump motor coolers in LRA Table 3.1.2-1, Reactor Coolant Pressure Boundary System, are not being managed for cracking. The staff will consider issuing an RAI to clarify whether cracking needs to be managed in these components.
(2) Licensee Event Report (LER) 263/2014-001, Primary System Leakage Found in Recirculation Pump Upper Seal Heat Exchanger, documents IGSCC in a stainless steel heat exchanger tube of the reactor building closed cooling water system at the Monticello Nuclear Generating Plant. According to the report, the cracking was caused by unrecognized localized boiling that led to an unexpectedly high concentration of chlorides from the chemistry constituents in the closed treated water system. Exelons evaluation of this operating experience report (IR 1614784-02) identifies differences between the Monticello Nuclear Generating Plant and LSCS heat exchanger configurations and states that the LSCS coil configuration does not allow similar chlorides to concentrate on tubes. The evaluation concludes that the heat exchanger design supports a much less challenging environment for the tubes. In its review of this evaluation, the staff could not conclude that the coil configuration at LSCS would prevent similar chloride concentrations. In addition, although LSCSs heat exchanger design presents a much less challenging environment for the tubes, without specific temperature information, the staff could not determine whether localized boiling could occur and thus lead to a comparable unexpectedly high concentration of chlorides. Based on temperature data provided to the staff during the audit, localized boiling within the heat exchanger did not appear to apply to LSCS.
However, the evaluation of the industry operating experience documented in IR 1614784-02 did not provide sufficient bases to show that the coil configuration would prevent similar chloride concentration and (even though much less challenging) that localized boiling would not occur.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M21A.
The staff also identified certain aspects of the parameters monitored or inspected and detection of aging effects program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.14, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Summary of Information in the Application. The LRA states that AMP B.2.1.14, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, is an existing
program with and enhancement that will be consistent with the program elements in GALL Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff reviewed an enhancement associated with this AMP. The enhancement will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the following equipment areas: reactor building crane, refueling platform, and scorpion work platform. The staff also conducted an independent search of the applicants operating experience database using keywords: wear, corrosion, bolt, torque, preload, loose, and crack.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M23 Program Basis Document Inspection of Overhead Heavy Load Revision 1 and Light Load (Related to Refueling) Handling Systems
- 2. ASME B30.2-2011 ASME Safety Standard B30.2, Inspection of Overhead Heavy 07/29/2011 Load and Light Load (Related to Refueling) Handling Systems
- 3. ASME B30.11-2010 Monorails and Underhung Cranes 04/16/2010
- 4. LMS-HC-01G Manual Chain Hoist Monthly and Annual Preventive Maintenance Revision 20 and Examination 07/16/2013
- 5. LMS-HC-01H Electric Hoist Monthly and Annual Preventive Maintenance and Revision 17 Examination 09/16/2013
- 6. LMS-HC-01I Electric/Pneumatic Chain Hoist Monthly and Annual Preventive Revision 19 Maintenance and Examinations 10/19/2012
- 7. AR01233351 Report Reactor Building Crane 90-Day (Annual) Inspections Results 06/27/2011
- 8. WO 01450767-01 Repair Reactor Building Crane per as Found of Inspection 11/11/2011
- 9. AR01333652 Report U2 TB Crane Structural Bolting Issues 02/28/2012
- 10. AR01335674 Loose Bolt Identified on Unit 2 Turbine Building Crane 03/03/2012
- 11. WO 01302916-03 MM Assist Vendor with Repair of Turbine Building Crane 02/18/2012
- 12. WO 95093319 MM Perform Annual Inspection of 1HC-01G Turbine Building 11/11/2010 Crane
- 13. MA-AA-716-021 Rigging and Lifting Program Revision 22
- 14. LMS-HC-01 Stations Cranes and Hoists Preventive Maintenance and Revision 43 Examination
- 15. LMS-HC-01A Reactor Building and Turbine Building Crane Monthly and Annual Revision 12 Preventive Maintenance and Examination 10/25/2013
- 16. UFSAR LaSalle County Station Updated Safety Analysis Report Chapter 9 Revision 19 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancement.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program element of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M23. The staffs evaluation of aspects of the program elements associated with the enhancement will be addressed in the SER.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.15, Compressed Air Monitoring Summary of Information in the Application. The LRA states that AMP B.2.1.15, Compressed Air Monitoring, is an existing program with an exception and enhancements that will be consistent with the program elements in GALL Report AMP XI.M24, Compressed Air Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff reviewed the exception and enhancements associated with this AMP. The exception to the GALL Report AMP and the enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: dew point, instrument air, and air quality.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M24 Program Basis Document Revision 1
- 2. ER-AA-200 Preventative Maintenance Program Revision 1
- 3. AR00200179 FME in Instrument Air Lines 02/06/2004
- 4. AR00197873 1ES005 - Small Cut in Instrument Air Lines Copper Fitting 01/28/2004
Revision /
Document Title Date
- 5. AR01168727 Unit 2 A in Dryer Switching Failure Alarm 01/30/2011
- 6. AR01203773 B in Dryer High Dew Point Alarm 04/17/2011
- 7. AR00477320 U-1 in Dew Point PM Not Utilizing the New Instrumentation 04/11/2006
- 8. AR01197660 U-2 in Trouble Alarm 04/04/2011
- 9. ER-AA-700-405 Compressed Air Monitoring Aging Management Program Revision 0
- 10. RP-LA-826 Pneumatic/Air System Quality Surveillance Revision 2
- 11. LOR-1PM10J-B105 U-1 Station Air Dryer Trouble Revision 4
- 12. LOR-1PM10J-B106 0 Station Air Dryer Trouble Revision 4
- 13. LOR-2PM10J-B105 U-2 Station Air Dryer Trouble Revision 4
- 14. LOR-1PM13J-A404 Instrument Nitrogen System Trouble Revision 7
- 15. LOR-1PM13J-B404 Instrument Nitrogen System Trouble Revision 6
- 16. LOR-2PM13J-A404 Instrument Nitrogen System Trouble Revision 7 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed exception and enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also verified that aspects of the monitoring and trending program element not associated with the exceptions are consistent with the corresponding program elements in the GALL Report AMP. The staffs evaluation of aspects of this program element associated with the exception will be addressed in the SER.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M24. The staff also verified that for the monitoring and trending program element, the aspects of the LRA AMP program element not associated with the exception are consistent with the corresponding program element in GALL Report AMP XI.M24. The staffs evaluation of aspects of the program element associated with the exception will be addressed in the SER. The staffs evaluation of aspects of the program elements associated with enhancements will be addressed in the SER.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the
staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.16 Fire Protection Summary of Information in the Application. The LRA states that AMP B.2.1.16 Fire Protection, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M26 Fire Protection. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: carbon dioxide/CO2, Cardox tank, fire doors, and fire wraps.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. Same as Title Fire Protection System - System and Structure Screening Report Revision 6 (Part of the Auxiliary Systems Grouping)
- 2. LA-PBD-AMP-XI.M26 LCS Units 1 & 2 License Renewal Project Aging Management Revision 1 Program Basis Document, Books 1 of 2 and 2 of 2
- 3. LES-CO-03 CO2 Fire Protection System Functional and Flow Test Revision 20
- 4. LES-FP-34 Inspection of Bus Duct Seals on Units 1 & 2 Revision 0
- 5. LMS-FP-08 Fire Hose Station and CO2 Hose Reel Annual Inspection Revision 23
- 6. LMS-FP-22 Fire Damper Visual Inspection Revision 13
- 7. LOS-AA-W1 Technical Specifications Weekly Surveillance Revision 75
- 8. LTS-1000-29 Water Tight Penetration Inspection Revision 13
- 9. LTS-1000-40 Mechanical Fire Penetration Inspection Revision 9
- 10. LTS-1000-42 Fire Assembly Integrity Inspection Revision 13
- 11. AR00166123 Degraded Fire Proofing in Div. 1 125 VDC Battery Room 07/03/2002
- 12. AR00151543 Deficiencies Discovered during Fire Protection Quarterly System 03/13/2003 Walkdown
- 13. AR00196256 Portions of Structural Steel Fire Proofing Missing 01/19/2004
- 14. AR00252342 Turbine Building Air Leakage at Piping Penetration 09/13/2004
- 15. AR00291211 Fire Barriers Inoperable for Greater Than 7 Days 01/15/2005
- 16. AR00361832 Fire Proofing Missing 08/10/2005
- 17. AR00518695 Cable Tray Fire Proofing is Eroding Away from Roof Leakage 08/10/2006
- 18. AR00444314 Fire Proofing Falling 09/19/2006
Revision /
Document Title Date
- 19. AR00560695 Fire Door Inoperable 11/21/2006
- 20. AR00566015 Fire Proofing Falling Off Beam at 749 R-23 12/06/2006
- 21. AR00690374 Corroded Piping on CO2 Line 10/27/2007
- 22. AR00981971 NRC Identified Fire Protection Issues 10/14/2009
- 23. AR01094223 Fire Protection CO2 Tank Decreasing Level (Trend) 07/25/2010
- 24. AR01118498 Gypsum Missing from Underside of Fire Rated Slab 09/27/2010
- 25. AR01172964 Repair Fire Seal for Penetration AB-2148 02/08/2011
- 26. AR01257929 Piping Downstream of 0CW016 Leaks CO2 Out 08/31/2011
- 27. AR01508031 NOS ID: MCR Floor Penetration/Envelop Question 04/29/2013
- 29. AR01530692 Small Hole in VR Ductwork 06/29/2013
- 30. AR01558315 NOS ID: (ENH) Evaluate Fire Proofing Structural Steel Attach 09/13/2013
- 31. AR02386194 NOS ID Fire Coating Missing 09/25/2014
- 32. AR02421068 NRC ID: 6" x 2" Piece of Fireproofing Missing - U1 Div. 2 SWGR 12/04/2014 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit for the Fire Protection program, the staff made the following observations:
- For the scope of program, the staff noted that the GALL Report recommends that the scope of the Fire Protection program encompasses fire resistance materials (e.g., fire wrapping) that serve a fire barrier function. The staff noted that the fire protection system description in the LRA included fire wraps (page 2.3-81 of the LRA). The staff further noted that Revision 6 to the applicants Fire Protection Report includes Darmatt KM-1 and Kaowool as fire wraps. However, these items are not specifically included in LRA Table 3.3.2-12, which includes fire protection system components that are subject to an AMR.
- In Revision 6 to the Fire Protection SystemSystem and Structure Screening Report (Part of Auxiliary Systems Grouping), the applicant indicated that Darmatt KM-1 is a ceramic fiber (fire barrierssteel components), and Kaowool is a mineral fiber (fire barrierspenetration seals and fire stops). Table 3.3.2-12 of the LRA lists both ceramic fiber and mineral fiber. Therefore, consistent with the GALL Report guidance, both Darmatt KM-1 and Kaowool are being managed for aging effects.
- The staff inquired whether the external surfaces of the low-pressure carbon dioxide tank (CardoxTM bulk storage tank) could be inspected because the tank is covered under insulation. The application stated that the carbon dioxide tank could not be readily inspected because the tank contains a factory-installed 4-inch minimum polyurethane layer sheathed inside an aluminum outer jacket that insulates the steel pressure vessel
(based on the tank suppliers literature). In LRA B.2.1.16, the applicant proposed an enhancement (Enhancement 2) to perform visual inspection on the external surfaces visible to eyes. The staff noted that this practice is consistent with general industry practice of minimizing the disturbance of a factory-installed moisture barrier for the purpose of inspection only.
- The staff noted that the applicants Units 1 and 2 Technical Requirements Manual (TRM) currently requires that the tank level and pressure be checked (at least 50-percent full and pressure greater than 290 pounds per square inch (psi)) once every 7 days (technical specification requirements (TSR) 3.7.1.1 and 3.7.1.2, in LSCS TRM 3.7 Plant Systems, section 3.7.1 CO2 Systems). In addition, the staff noted that a system function test (including electrical actuation and valve cycling) is performed on the CO2 system every 24 months (LaSalle Station Fire Protection Report Revision 6 LaSalle NFPA Code Deviation Summary Matrix, page 5.2-4), which is consistent with the inspection frequency guidance in the GALL Report. The staff noted that the CO2 tank level/pressure verification, along with the visual inspection of tank external surfaces visible to eyes, provided assurance that the CO2 tank corrosion could be detected.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M26. The staffs evaluation of aspects of the program elements associated with enhancements will be addressed in the SER.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.17, Fire Water System Summary of Information in the Application. The LRA states that AMP B.2.1.17, Fire Water System, is an existing program with enhancements and exceptions that is or will be consistent with the program elements in GALL Report AMP XI.M27, Fire Water System as modified by LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the exceptions and enhancements associated with this AMP. The exceptions to the GALL Report AMP and the enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of
the applicants operating experience database using keywords: clog, damage, buried, jacket, lining, min wall, sprinkler, perforat, through wall, mic, and leak.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LOS-FP-A3 Fire Protection Sprinkler, Spray, and Deluge Drain Flow and Revision 29 Cycling Test
- 2. ER-AA-2030 Conduct of Plant Engineering Manual Revision 14
- 3. LOS-FP-SR3 Fire Protection Water Spray/Sprinkler Systems Headers, Nozzles Revision 3 and Sprinkler Integrity Inspection
- 4. WO 01465579 LOS-FP-A3 Fire Protection Sprinkler Valves 08/15/2012
- 5. WO 01575636 LOS-FP-A3 Fire Protection Sprinkler Valves 08/22/2013
- 6. WO 01668353 LOS-FP-A3 Fire Protection Sprinkler Valves 08/25/2014
- 7. AR01105024 Valve Leakby 2FP063 08/24/2010
- 8. AR01253763 Alarm Chamber Drain Line Clogged 08/21/2011
- 9. AR01654200 Drain Line Plugged 2FP071 05/01/2014
- 10. AR00988429 Corrosion Found during Replacement of 0FP210B 11/03/2009
- 11. AR01502925 FP Jockey Pump 0FP25P Unable To Maintain Fire Protection 04/17/2013 Pressure
- 12. AR01152105 0FP25P (Fire Jockey Pump) Fails To Maintain Header Pressure 12/14/2010
- 14. AR02420308 Sprinkler Piping Leak 12/03/2014
- 15. AR01606545 Leak on Fire Protection Sprinkler U1 710 HTR Bay X-9 01/09/2014
- 16. AR01314172 Fire Header through Wall Leak 01/17/2012
- 17. AR01599553 Hole in Downstream Piping of 1FP027 12/20/2013
- 18. TRM 3.7.k Spray and Sprinkler Systems Revision 4
- 21. AR01105024 Valve Leakby 2FP063 08/24/2010
- 22. AR00777207 2FP007 05/19/2008
- 23. AR00568415 Valve 1FP058 Leaks by 12/12/2006
- 24. AR00568411 Valve 0FP070 Leaks by 12/12/2006
- 25. M-775 Sheet 1 Arrangement Fire Protection System Revision A
- 26. AR01510625 IEMA Questions on Fire Protection Yard Loop Flow Test 05/06/2013
- 27. LA-PBD-AMP-XI.M27 Program Basis Document, Fire Water System Revision 0
The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed exceptions and enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.
- The detection of aging effects program element of the LRA AMP states that sprinklers will be inspected by performing a visual inspection for corrosion every 24 months. The GALL Report AMP recommends annually inspecting for leakage, loss of fluid in the glass bulb heat responsive element, and loading, in addition to inspecting for corrosion. It is not clear to the staff that these statements are consistent because the applicant did not address the additional inspection criteria or the increased frequency of inspections.
In order to verify that the enhancements will make the AMP adequate to manage the applicable aging effects, the staff will consider issuing an RAI for the subject discussed below.
- During the audit, the staff noted the LRA AMP lacked an enhancement to the acceptance criteria program element. The GALL Report, as modified by LR-ISG-2012-02 states that, if the presence of sufficient foreign organic or inorganic material to obstruct pipe or sprinklers is detected during pipe inspections, the material is removed and its source is determined and corrected. The LRA AMP program basis documents lacked the acceptance criteria aspect of removing known foreign materials and determining the source and correcting the issue.
In order to verify that the exceptions will make the AMP adequate to manage the applicable aging effects, the staff will consider issuing RAIs for the subjects discussed below.
The exception states that flow testing will be performed on wet-pipes, dry pipe sprinklers, and deluge systems in lieu of the testing of the main drain. It is not clear to the staff how the applicant is meeting the intent of the testing of the main drain by performing the aforementioned alternative tests.
LOS-FP-A3 states in step D.6 that the applicant will record pressure drops and write an issue report if these pressure drops vary by greater than 5 psi and if the data vary substantially. However, NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, issued 2014, states that less than a 10-percent reduction in full flow when it is compared to the original acceptance test or previously performed tests meets acceptance criteria. It is not clear to the staff how measuring pressure drops is consistent with NFPA 25, as referenced in AMP XI.M27.
The exception states that external visual inspections of the deluge header inside the
charcoal filter plenum every refuel cycle and internal visual inspections of one of the 11 charcoal filter deluge systems every 5 years will be performed in lieu of testing with either water or air to verify no obstructions. It is not clear to the staff how the sample size and frequency of inspections will provide reasonable assurance of the intended function of the charcoal filter deluge system.
During the audit, the staff made the following observations:
- Issue Reports were written for four different fire protection valves that were experiencing leakby. The applicant provided drawings (M-126, Sheet 2, and M-71, Sheet 1) to show that the upstream and downstream portions are all wet-pipe, thus not providing issue with normally dry, periodically wetted piping that might be experiencing continually wet conditions due to a leaking valve.
- Several Issue Reports were written concerning a fire jockey pump that was unable to maintain header pressure. However, the two other fire jockey pumps are able to perform the design function as required by TRM 3.7.j.
- The staff reviewed many Issue Reports on fire water piping that was clogged or corroded, or both. The staff confirmed that the issues are being handled through the corrective action process.
- Through-wall leaks in fire water piping were noted during a review of the operating experience database. The fire water system is a raw water system; although not uncommon, raw water systems tend to have more potential loss of material and flow blockage issues.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). However, in order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.
- During its search of the operating experience database, the staff noted that the applicant generated many Issue Reports on the fire water protection system regarding degradation of flow characteristics (i.e., C factor) in the underground fire loop, which is a raw water system. During the audit, the applicant provided a marked-up copy of plant drawing M-775, Sheet 1, showing the fire protection yard loop with annotated flow testing node points. Data were provided to the staff on the C factor from years 2006 through 2014. The piping segment from the diesel-driven fire pump to node 515 shows a significant degrading trend. The staff does not have reasonable assurance that the aforementioned piping segment will be able to perform its intended function during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program
elements in GALL Report AMP XI.M27. The staffs evaluation of aspects of the program elements associated with enhancements will be addressed in the SER. The staff also identified certain aspects of the detection of aging effects program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.18, Aboveground Metallic Tanks Summary of Information in the Application. The LRA states that AMP B.2.1.18, Aboveground Metallic Tanks, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M29, Aboveground Metallic Tanks, as modified by LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER. During the audit, the staff identified a difference between the LRA AMP and the GALL Report AMP that should have been identified as an exception. The staff-identified difference is evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted a walkdown of the cycled condensate storage tanks, 1CY01T and 2CY01T, for Unit 1 and Unit 2 respectively. The staff also conducted an independent search of the applicants operating experience database using keywords: tank, inspect, and cycled condensate.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M29 Aboveground Metallic Tanks Program Basis Document Revision 1 09/25/2014
- 2. Drawing 74-21-41 01 Outline - Cycled Condensate Storage Tank (1CY01T & 2CY01T) 08/15/1974
- 3. Drawing S-1740 Cycled Condensate (CY) Storage Tank Berm Plan and Sections N/A
- 4. LA-AMRBD-MEAE Materials, Environments, and Aging Effects - Aging Management Revision 0 Review Basis Document 01/29/2013
- 6. ER-AA-700-404 Aging Management Program for Aboveground Metallic Tanks Revision 0
Revision /
Document Title Date
- 9. Drawing S-170 Miscellaneous Outdoor Foundations - Sheet 1 N/A
- 10. Drawing 74-2141 22 Shell 03/13/1975
- 11. Drawing 74-2141 23 Roof 03/13/1975
- 12. LS-AA-125-1001 1CY01T Tritium Leakage Root Cause Investigation 08/12/2010
- 13. LAS-03116 Evaluation of Two Floor Samples from LaSalle Cycled Condensate 07/29/2010 Storage Tank 1CY01T
- 14. LAS-52922 Failure Evaluation of Pitting on the Aluminum Plate from the CY Tank 07/08/2011 Floor, Component ID: 2CY01Y, AR1231679, LaSalle County Unit 2
- 15. Drawing 176015 Bottom Repair Tank, 1CY01T & 2CY01T 07/09/2010
- 16. Drawing 081779 Repair to Existing Aluminum Tank Revision 0
- 16.10-275 Ultrasonic Thickness Examination Report, 1CY01T 07/05/2010
- 17.10-277 Ultrasonic Thickness Examination Report, 1CY01T 07/06-09/2010
- 18.11-186 Ultrasonic Thickness Examination Report, 2CY01T 06/13-15/2011
- 19. WO 1257328-05 Work Order To Perform Weld Repairs or Install Patches, 1CY01T 01/26/2011
- 20. WO 1257328-21 Work Order To Remove Sand Samples, 1CY01T 01/26/2011
- 21. AR02477424 Repair Caulking around CY Tank Base 03/31/2015
- 22. AR02477426 Repairs Needed for U2 CY Tank Caulking around Base of Tank 03/31/2015 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program, as modified by the proposed enhancements. During the audit, the staff verified that the scope of program and preventive actions program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The staff also identified a difference between the LRA AMP and the GALL Report AMP that should have been identified as an exception while conducting the audit. The staff verified that aspects of the parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements not associated with the staff-identified difference are consistent with the corresponding program elements in the GALL Report AMP. A description of the staff-identified difference is provided below.
- GALL Report AMP XI.M29, as modified by LR-ISG-2012-02, states that the program manages the effects of loss of material and cracking on the outside and inside surfaces of aboveground tanks constructed on concrete or soil. In addition, GALL Report AMP XI.M29 states that inspections are conducted in accordance with Table 4a, Tank Inspection Recommendations, which identifies cracking as an aging effect that should be managed for stainless steel and aluminum alloys. The Aboveground Metallic Tanks Program does not manage the aging effect of cracking and does not take an exception to GALL Report AMP XI.M29.
- The staff also noted that LRA Table 3.4.2-1, Condensate System, plant specific note 3, states that the tanks are constructed from alloys that are not susceptible to SCC. During the audit, the staff reviewed drawings and construction details associated with the two cycled condensate storage tanks. The drawings specify that the tanks are constructed from 5454-O plate, 6061-T6 structural members, 6061-T6 piping, and 6061-O extruded shapes.
While conducting the walkdown of the cycled condensate storage tanks, 1CY01T and 2CY01T, the staff observed that the caulking at the interface of the tank bottom and foundation was degraded in locations. The degradation was in the form of discontinuities and decohesion.
AR02477424 and AR02477426 address the degradation of the caulking.
During the audit of the operating experience program element, the staffs independent review found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). However, the staff noted operating experience associated with enhancements made to this program. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.
- The LRA AMP states an enhancement (Enhancement 3) to the parameters monitored or inspected and detection of aging effects program elements. The enhancement states tank bottoms will be volumetrically inspected within the 10 years before entering the period of extended operation and each 10-year period during the period of extended operation. The inspection method and frequency is consistent with the GALL Report.
The staff could not determine the sufficiency of Enhancement 3 during the audit. The bottoms of both cycled condensate storage tanks have experienced loss of material.
The Unit 1 tank experienced leakage resulting from pitting in the tank bottom. Patches have been installed on the bottoms of both tanks to repair areas that were found to be below nominal thickness. It is unclear to the staff whether the extent and locations of volumetric inspections being performed are sufficient to manage loss of material during the period of extended operation.
- The LRA AMP states an enhancement (Enhancement 4) to the parameters monitored or inspected and detection of aging effects program elements. The enhancement states that caulking at the tank-foundation interface is visually inspected for signs of degradation. The visual inspection of the flexible caulk seal at the perimeter of the tank-foundation interface is not supplemented by physical manipulation.
The staff could not determine the sufficiency of Enhancement 4 during the audit. The loss of material experienced by the tank bottoms has been partially attributed to chloride and moisture intrusion resulting from the failure of the flexible caulk seal at the tank-foundation interface. It is unclear to the staff whether visual inspection of the caulk, without augmentation by physical manipulation, is sufficient to manage the degradation of the caulk during the period of extended operation.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI for the subject discussed below.
- LR-ISG-2012-02, Table3.0-1, states that visual examination is sufficient to monitor the degradation of sealant or caulking when supplemented with physical manipulation. The UFSAR does not address physical manipulation as an inspection method for sealant or caulking.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M29. The staffs evaluation of aspects of the program elements associated with enhancements and staff-identified differences will be addressed in the SER.
Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR supplement.
LRA AMP B.2.1.19, Fuel Oil Chemistry Summary of Information in the Application. The LRA states that AMP B.2.1.19, Fuel Oil Chemistry, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.M30, Fuel Oil Chemistry. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the emergency diesel generator (EDG) fuel tanks, EDG day tanks, and fire protection diesel generator fuel tanks. The staff also conducted an independent search of the applicants operating experience database using keywords: tank, microbiological, and fuel oil.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date 1.LA-PBD-AMP-XI.M30 Program Basis Document Revision 1 2.LA-PBD-AMP-XI.M30 Program Basis Document Revision 2
- 3. C-74-188 Drawing: EDG Day Tank Revision 6
- 4. C-74-187 Drawing: HPCS Diesel Day Tank Revision 7
- 5. 2673255 Drawing: Fire Diesel Day Tank 09/26/1975
- 6. 74-2130 Drawing: HPCS Main Tank 10/17/1981
- 7. 74-2131 Drawing: EDG Main Tank 10/17/1981
- 8. N/A Gap Analysis Report N/A
- 9. AR01467889 TSC/Security Diesel Tank Cathodic Protection Results 01/28/2013
- 10. AR01276666 Deficiencies Noted during B.5.B Pump Dry Run 10/14/2011
- 11. AR00869600 Oil Sep. / D.O. Tank Cleanouts - Assign to Proper Budget 01/21/2009
- 12. AR01416178 Possible Limiting Value Change for ASTM D 6079 09/20/2012
- 13. AR00855678 Ice Buildup on Top of the TSC/SEC DG Fuel Oil Storage 12/12/2008
Revision /
Document Title Date
- 14. AR00379091 Microbiological Analysis for Diesels 09/28/2005
- 15. AR00485416 High Total Aerobic Bacteria (TABS) for 1A & 2B Diesel Coolant 05/01/2006
- 16. AR00482776 TSC/Security DG Fuel Storage Tank Fuel Out Spec 04/24/2006
- 17. AR00961947 New Diesel Fuel Oil Water & Sediment Analysis 09/04/2009
- 18. AR01191254 B.5.B PDDP Fuel Oil Analysis Results Were Not Within Specs 03/23/2011
- 19. AR01214231 B.5.B PDDP Fuel Oil Analysis Results Were Not Within Specs 05/10/2011
- 20. AR01228172 Single DO Analysis - Separate Compartments O Delivery Truck 06/13/2011
- 21. AR01386799 SEC/TSC DG Storage Tank Analysis Out of Spec 07/09/2012
- 22. AR01239146 SEC/TSC DG Storage Tank Analysis Out of Spec 07/12/2011 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, preventive actions, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. However, for the enhancement associated with the parameters monitored or inspected and detecting of aging effects program elements to perform periodic sampling of the stored diesel tanks, the applicant did not identify how these samples will be taken. For a representative sample, the GALL Report recommends either multilevel sampling or, if tank designs do not allow multilevel sampling, then taking samples from the lowest point of the tank. When questioned about this aspect, the applicant revised the program basis document to include the GALL Reports recommendations on sample locations of stored diesel fuel tanks. This change to the program basis document resolved the staffs concern.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, detecting of aging effects, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M30.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.20, Reactor Vessel Surveillance Summary of Information in the Application. The LRA states that AMP B.2.1.20, Reactor Vessel Surveillance, is an existing program that is consistent with the program elements in GALL Report AMP XI.M31, Reactor Vessel Surveillance. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: weld, plate, vessel, neutron, capsule, irradiation, embrittlement, and surveillance program.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M31 Program Basis Document: Reactor Vessel Surveillance Revision 0 02/14/2014
- 2. ER-AB-331-103 BWR Vessel Integrated Surveillance Program Implementation Revision 3
- 3. LTS-1200-4 Reactor Engineers Core Monitoring Surveillance Revision 36 10/15/2014
- 4. EPRI-VIP-007-R-003 LaSalle Unit 1 Reactor Pressure Vessel Fluence Evaluation Revision 0 04/27/2011
- 5. AR1229987 Work Order Needed To Receive Remnants of Surveillance Capsule 06/17/2011
- 6. AR1315401 Surveillance Capsule Data Analysis Needed 01/19/2012
- 8. AR1659376 NRC Finding Associated with BWRVIP Capsule Report 05/13/2014 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.
- The detection of aging effects program element of GALL Report AMP XI.M31 states that the program withdraws one capsule at an outage in which the capsule receives a neutron fluence of between one and two times the peak reactor vessel wall neutron fluence at the end of the period of extended operation and tests the capsule in accordance with the requirements in American Society for Testing and Materials (ASTM) E 185-82, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels. The staff noted that the neutron fluence levels
for LSCS Unit 2 surveillance plate and weld materials, as planned in the BWRVIP Integrated Surveillance Program (ISP), are not in the recommended fluence range between one and two times the peak reactor vessel wall neutron fluence at the end of the period of extended operation (i.e., 1.22x1018 neutrons per square centimeter).
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant needs additional clarification as described below. In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing RAIs for the subjects discussed below.
- BWRVIP-86, Revision 1, indicates that recently (within the past several years) a capsule containing the surveillance weld material for LSCS Unit 2 should have been withdrawn from a host plant for surveillance testing. However, the LRA (including LRA Section B.2.1.20) does not discuss evaluation of the surveillance data. Additional information is necessary to confirm whether evaluation of the most recent surveillance data is included in the LRA.
- LRA Section B.2.1.20 indicates that, since a damaged spring was discovered on the Unit 2 120 degree capsule in 2007, the capsule was removed from the reactor vessel and placed in the spent fuel pool where it will remain indefinitely. The LRA also indicates that the capsule does not require surveillance testing as part of the BWRVIP ISP. However, the LRA does not provide sufficient information to ensure that the applicants assessment of the plant-specific operating experience is adequate to prevent similar events that can affect the availability of reactor vessel surveillance capsules.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing RAIs for the subject discussed below.
- BWRVIP-86-A (October 2002) describes the ISP implementation plan for the original license period developed before the issuance of BWRVIP-86, Revision 1, whereas BWRVIP-86, Revision 1-A (October 2012), describes the staff-approved ISP implementation plan for both the original and extended license period. However, the UFSAR supplement description for the Reactor Vessel Surveillance program includes a reference to BWRVIP-86-A (October 2002) rather than BWRVIP-86, Revision 1-A (October 2012).
Audit Results. Based on this audit, the staff verified that scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M31. The staff also identified certain aspects of detection of aging effects program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR supplement.
LRA AMP B.2.1.21, One-Time Inspection Summary of Information in the Application. The LRA states that AMP B.2.1.21, One-Time Inspection, is a new program that will be consistent with the program elements in GALL Report AMP XI.M32, One-Time Inspection. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document. Issues identified but not resolved in this report will be addressed in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: fouling, corrosion, and loss of material.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. LA-PBD-AMP-XI.M32 Program Basis Document Revision 1 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, detection of aging effects, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M32.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.22, Selective Leaching Summary of Information in the Application. The LRA states that AMP B.2.1.22, Selective Leaching, is a new program that will be consistent with the program elements in GALL Report
AMP XI.M33, Selective Leaching. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff identified a difference between the LRA AMP and the GALL Report AMP that should have been identified as an exception. The staff-identified difference will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: dealloy, dezinc, degraph, dealum, and copper.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M33 Program Basis Document Selective Leaching Revision 2 01/14/2015
- 2. LRCR-TEAM-50 License Renewal Change Request - Selective Leaching and 03/26/2015 Underground Piping Program Interface for Buried Fire Protection Valves
- 3. ER-AA-700-401 Selective Leaching Aging Management Program Revision 0
- 4. LRCR-AMP-26 Applicability of the Selective Leaching Program to Aluminum Bronze 04/02/2015 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding element of the GALL Report AMP. While conducting the audit, the staff also identified a difference between the LRA AMP and the GALL Report AMP that should have been identified as an exception. A description of the staff-identified difference is provided below.
- GALL Report AMP XI.M33 states that materials susceptible to selective leaching include copper alloys with greater than 8-percent aluminum.
- During the audit, the staff noted that the program description of the LRA AMP and program basis documents of the Selective Leaching program do not identify copper alloys with greater than 8-percent aluminum as materials susceptible to selective leaching. The Selective Leaching program does not manage the effects of selective leaching in aluminum bronze components and does not take an exception to GALL Report AMP XI.M33.
- The staff reviewed the LRA and the program basis documents provided by the applicant and noted that there are no in-scope components made of aluminum bronze. The staff identified this as a difference that should be an exception and will disposition it accordingly in the SER.
During the audit, the staff also made the following observations:
- The GALL Report states that soil is an environment in which selective leaching may occur. The staff noted that the LRA AMP includes soil as an applicable environment for components susceptible to selective leaching. The program basis document does not include soil as an applicable environment in all aspects of the program. However, the program basis document and the LRA do address and apply the AMP to the appropriate components exposed to soil. The program basis document and the LRA AMR tables are consistent with the GALL Report, and the program manages selective leaching for all susceptible materials exposed to soil.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M33. The staffs evaluation of the aspects of the program description associated with the staff-identified difference will be addressed in the SER.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.23, One-Time Inspection of ASME Code Class 1 Small-Bore Piping Summary of Information in the Application. The LRA states that AMP B.2.1.23, One-Time Inspection of ASME Code Class 1 Small-Bore Piping is a new program that will be consistent with the program elements in GALL Report AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping. To verify this claim of consistency, the staff audited the LRA AMP.
Issues identified but not resolved in this report will be addressed in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: weld, cracking, crack, failure, socket, sockolet, weldolet, butt weld, thermal, fatigue, and leakage.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XIM35 Program Basis Document, One-Time Inspection of ASME Code Revision 0 Class 1 Small-Bore Piping 05/15/14
- 2. ER-AA-330-012 ASME Code Class 1 Small-Bore Piping Aging Management Revision 0 Program
- 3. ER-AA-330 Conduct of Inservice Inspection Activities Revision 10
- 4. ER-AA-330-002 Inservice Inspection of Section XI Welds and Components Revision 11
- 5. AR00311917 Pressure Boundary Leakage Noted during VT-2 03/12/2005
- 6. LER-50-374/2005-002 Pressure Boundary Leakage Discovered in 2D MSIV Drain Line 05/04/2005 Weld during Refueling Outage VT-2 Examination
- 7. LS-AA-125-1003 Apparent Cause Evaluation,
Title:
Pressure Boundary Leakage at Revision 5 Weld Joint between 2b21-F028D and Line 2Ms20AD-2 4/14/2005
- 8. WO 00789955 Work Order Package, Leak at Line 2MS20AD-2 at Valve 03/13/2005 2B21-F028D
- 9. EPRI IR-2011-465 EPRI Internal Report, Mockup and UT Probe Design for 04/2011 Volumetric Examination of Small Bore Socket-to-Pipe Welds
- 10. AR00311917 Action Request, Pressure Boundary Leakage Noted during VT-2 03/12/2005
- 11. AR01358847 Action Request, Inspection of 2B21-N040 Thermowell 04/26/2012 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
For the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.
GALL Report AMP XI.M35 states under the detection of aging effects program element that
[t]his inspection should be performed at a sufficient number of locations to ensure an adequate sample. This number, or sample size, is based on susceptibility, inspectability, dose considerations, operating experience, and limiting locations of the total population of ASME Code Class 1 small-bore piping locations. LRA Sections B.2.1.23 and A.2.1.23 do not provide the total number of in-scope small-bore piping welds. The LRA does not provide the weld populations. It is not clear to the staff how the inspection sample will be selected and thus whether a sufficient number of locations will be inspected to ensure that cracking will be adequately managed.
GALL Report AMP XI.M35 also states under the detection of aging effects program element that the One-Time Inspection program does not apply to plants that have experienced cracking in ASME Code Class 1 small-bore piping due to stress corrosion, cyclical (including thermal, mechanical, and vibration fatigue) loading, or thermal stratification and thermal turbulence.
LRA Section B.2.1.23 states that LSCS Units 1 and 2 have not experienced this type of cracking. However, the LRA also states that the applicants review identified two issues with
ASME Code Class 1 small-bore piping welds during the startup of LSCS Unit 1 in 1983. The LRA further states that a pinhole leak was identified on a LSCS Unit 2 ASME Code Class 1 small-bore socket weld in 2005. The LRA states that the pinhole leak was caused by an inclusion or defect in a repair weld performed in 1995. Based on the staffs review of the available information, the staff determined that the documented failures were most likely age related and caused by either vibration or thermal fatigue, or both. Given the documented history of multiple failures of socket welds, it is not clear to the staff why the applicant has determined that a one-time inspection of its socket weld population would be consistent with the guidance provided in the GALL Report AMP XI.M35.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M35. The staff also identified certain aspects of the detection of aging effects program element of the LRA AMP for which additional information and evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.24, External Surfaces Monitoring of Mechanical Components Summary of Information in the Application. The LRA states that AMP B.2.1.24, External Surfaces Monitoring of Mechanical Components, is a new program that will be consistent with the program elements in GALL Report AMP X.M36, External Surfaces Monitoring of Mechanical Components, as modified by LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation, and LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, dated November 14, 2014. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: tank, external, leak, leakage, insulation, and pinhole.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M36 Program Basis Document - External Surfaces Monitoring of Revision 1 Mechanical Components
- 2. AR00917000 Leaking SA Valve Corroding Other Components 05/06/2009
- 3. ER-AA-470 External Surfaces Monitoring of Mechanical Components Aging Revision 6 Management Program
- 5. LA-700-402-10041 External Surfaces Monitoring of Mechanical Components Aging Revision 0 Management Program, Implementing Procedure The staff conducted its audit of LRA program elements one through six based on the contents of the program. During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description to be consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M36.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Summary of Information in the Application. The LRA states that AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, is a new condition monitoring program that directs visual inspections of internal surfaces of components be performed during system inspections and walkdowns that will be consistent with the program elements in GALL Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, as modified by LR-ISG-2012-02. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: condenser, internal, leak, duct, heat transfer, and fouling.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M38 Program Basis Document - Inspection of Internal Surfaces in Revision 2 Miscellaneous Piping and Ducting
- 2. IR 331050 Heating Coils Identified as Dirty and in Need of Cleaning 05/02/2005
- 3. AR00924179 Drain Plug on North End of Condenser Housing Corroded 05/27/2009
- 4. ER-AA-700-403 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Revision 0 Components AMP
- 5. ER-LA-700-403-1003 Planners Guide to Inspection of Internal Surfaces in Miscellaneous Revision 0 Piping and Ducting Components AMP The staff conducted its audit of LRA program elements one through six based on the contents of the new program. During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). The applicant provided three cases of plant-specific operating experience relevant to the program. In each case, the applicant inspected internal surfaces of components when accessible. When indications were detected, the applicant entered the issues into the Corrective Action Program and followed site procedures in addressing the issues. The cases provided examples indicating that the applicants site procedures and the new program under development will be effective in detecting and managing aging through the inspection of the internal surfaces of its components.
The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description to be consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M38.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.26, Lubricating Oil Analysis Summary of Information in the Application. The LRA states that AMP B.2.1.26, Lubricating Oil Analysis, is an existing program that is consistent with the program elements in GALL Report AMP XI.M39, Lubricating Oil Analysis. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: lube, oil analysis, and lubricating analysis.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M39 Program Basis Document Revision 1
- 2. MA-AA-716-006 Control of Lubricants Program Revision 10
- 3. MA-AA-716-230 Predictive Maintenance Program Revision 9
- 4. MA-AA-716-230-1001 Oil Analysis Interpretation Guidelines Revision 17
- 5. MA-LA-716-230-1104 Lubricant Sampling Administrative Guidelines Revision 0
- 6. AR00797419 Action Report: Oil Change on 0IS01G as a Results of Oil Analysis 07/17/2008
- 7. AR01545542 Action Report: Oil Analysis Indicates Increasing Wear Trend in 08/12/2013 0VE04CB
- 8. AR00933123 Action Report: Oil Analysis Indicates an Increase in Aluminum 06/19/2009
- 9. AR00851019 Action Report: Oil Analysis Indicates Increase Wear Metal in 12/01/2008 Compressor
- 10. AR00236842 Action Reports: Equipment Lubricating 07/17/2004 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and
trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M39.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.27, Monitoring of Neutron-Absorbing Materials Other Than Boraflex Summary of Information in the Application. The LRA states that AMP B.2.1.27, Monitoring of Neutron-Absorbing Materials Other Than Boraflex, is an existing program with an enhancement that is consistent with the program elements in GALL Report AMP XI.M40, Monitoring of Neutron-Absorbing Materials Other Than Boraflex. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancement will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: Boral, spent fuel pool, and Netco inserts.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.M40 Monitoring of Neutron-Absorbing Materials Other Than Boraflex Revision 0 05/25/2014
- 2. AR01479416 During L2R14 FS#2 Netco Insert Came Out with Fuel Bundle 10/16/2014
- 3. NET-235-01 Inspection and Testing of Boral Surveillance Coupon from the Revision 0 LaSalle County Unit 1 Station 05/06/2004
- 4. NET-332-01 Inspection and Testing of Boral and Fast Start Surveillance Revision 0, Coupons from the LaSalle County Units 1 and 2 Station 09/10/2009
- 5. SEP 235-01 Procedure for Measuring and Recording Boral Surveillance Coupon Revision 0 Physical Attributes 04/05/2004
- 6. NET-300054-01 Inspection and Testing of Fast Start Surveillance Coupons F22-F11 Revision 0 from the LaSalle County Unit 2 Station 01/17/2013
- 7. AR01479416 During L2R14 FS#2 Netco Insert Came Out with Fuel Bundle
- 8. AR00203737 Improper Closure of WO 589754
- 9. AR00230578 Error in GE U2 Spent Fuel Pool Criticality Analysis
- 10. AR00855496 Perform Fast Start Coupon Removal and Shipment
- 11. AR01162523 Unit 2 Spent Fuel Pool FME from Netco Insert Tool
- 12. AR01241530 Positive Control of Netco Rack Inserts
- 13. AR01275817 Unit 2 Refuel Bridge Mono Hoist Use for Netco Rack Inserts
The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancement.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M40.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.28, Buried and Underground Piping Summary of Information in the Application. The LRA states that AMP B.2.1.28, Buried and Underground Piping, is an existing program with enhancements that is consistent with the program elements in GALL Report AMP XI.M41, Buried and Underground Piping and Tanks, as modified by LR-ISG-2011-03, Changes to the Generic Aging Lessons Learned (GALL)
Report, Revision 2, Aging Management Program (AMP) XI.M41, Buried and Underground Piping and Tanks. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff identified an exception to the GALL Report AMP and reviewed the enhancements associated with this AMP. The exception and enhancements are evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted a walkdown of underground piping in the lake screen house. The staff also conducted an independent search of the applicants operating experience database using keywords: buried, coat, damage, holiday, leak, mic, min wall, perforat, pit, through wall, underground, vault, and wrap.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. LR-PBD-AMP XI.M41 Program Basis Document, Buried and Underground Pipe GALL Revision 2 Program XI.M41 Buried and Underground Piping and Tanks
- 2. AM 4103-535476 Long Range Guided Wave Ultrasonic Pipe Screening Results 2 11/20/2013 DG05A-4" Line Excavation #7
- 3. NUCC 2013109.00 Evacuation No. 7 Condition Assessment Excavated Buried Pipe 11/12/2013
- 4. AR01580474 IEMA Questions on LaSalle Minimum Wall Issues 11/03/2013
- 5. AR02449566 L2R15-U1 Found Line 2DG05A Degraded Condition 02/09/2015
- 6. NA Long Range Guided Wave Ultrasonic Pipe Screening Results 06/29/2010 2DO88A-3", 1DO88A-3" 1DO87A-3", 2CY11A-8"
- 7. J2533 Concrete Structures Work LaSalle County Station Units 1 and 2 04/01/1975 Commonwealth Edison Company
- 8. NA 2013 Cathodic Protection System Resurvey Report 08/2013
- 9. NA 2014 Cathodic Protection System Resurvey Report 10/2014
- 10. NA Program Heath Report - Buried Piping and Raw Water 1st Quarter 2013 Corrosion Program 3rd Quarter 2014
- 11. NA Subsurface Soil Analysis To Support the LaSalle County 01/24/2014 Generating Station Underground Buried Pipe and Tanks Inspection Initiative
- 12. M-17 General Arrangement Section E-E & F-F EDG Day Tanks 08/10/2001
- 13. NUCC 2011111.00 Condition Assessment Excavated Pipe - Excavations 1, 2, and 3 01/07/2012
- 14. WO 01451570 PMO 00161240 Perform Annual Cathodic Protection Survey 04/18/2012
- 15. LS-MSS-2.3-F Standard Specification for Protective Coatings for Buried Piping 08/07/1989
- 16. T-3763 Mechanical and Structural Specification 03/20/1987 Maintenance/Modification Work [Backfill]
- 17. 006889 45 Clean and Recoat CSCS Bypass Line in LSH 10/24/2007
- 18. WO 01431445-04 Excavation No. 2 (RI) As-Found Visual Inspection Report 07/01/2011
- 19. WO 01444511 As-Found Buried Piping Visual Inspection Report Excavation 3A 09/27/2011
- 20. WO 01479617 CSCS As-Found Buried Piping Visual Inspection Report 03/15/2012
- 21. NUCC 2012115.00 Condition Assessment Excavation Buried Pipe Excavation 5 0425/2012
- 22. WO 01479618-02 Ultrasonic Thickness Results 3" DO Piping 04/30/2012
- 23. NUCC 2013109.00 Buried Pipe Evaluations Conducted in Excavation 7 10/21/2013
- 24. 2-DO-6 Piping Isometric Day Tank Piping Revision A
- 25. NUCC 2103109.00 Evaluation Report Conducted Pipe Evaluations in Excavation 6 07/25/2014
- 26. LER 85-027-01 Letter to the NRC, Reportable Occurrence Report #85-027-01 04/23/1986
- 27. CR-01576362 Degradation Observed during Ultrasonic Inspection of 2DG05A 10/24/2013
- 30. WO 01431445-04 As-found Buried Pipe Inspection Report 07/01/2011
- 31. M-766 Outdoor Piping Revision AC
Document Title Revision / Date
- 32. M0-1-87-095, Reactor Core Isolation Cooling [RCIC] Piping Modification 06/02/1992 MO-2-87-082
- 33. LS-PDT-140 Piping Design Tables 01/15/1987
- 34. 1R130C, 1R116A Passport Tags for RCIC Modification 12/18/1996
- 35. M-0727-05 Systems Materials Analysis Department Report on Buried High 03/03/1986 Pressure Core Spray Line Failure LaSalle County Station Unit 1 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. The detection of aging effects program element of the LRA AMP states that soil corrosion probes might be used to verify the effectiveness of the cathodic protection system during annual surveys. The GALL Report recommends the conduct of a cathodic protection survey using either a -850 millivolts (mV) relative to a copper sulfate electrode instant off criterion or a 100-mV minimum polarization criterion to assess the effectiveness of a cathodic protection system. Although the applicant did not cite an exception for its use of soil resistance probes, these statements are not consistent because corrosion probes use a method (actual measurement of potential loss of material in the monitored component) that is different from cathodic protection surveys. The staffs evaluation of this exception will be documented in the SER. The staff also verified that aspects of the detection of aging effects program element that were not associated with the exception identified by the staff during the audit are consistent with the corresponding program elements in the GALL Report AMP. In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether this program element is consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subject discussed below.
- The applicant stated an acceptance criterion of 1 thousandth of an inch (mil) per year associated with the use of soil corrosion probes. Although the 1-mil-per-year acceptance criterion is a standard industry value used to demonstrate an effective cathodic protection system, the staff lacked sufficient information to conclude that there is reasonable assurance that all buried in-scope piping would be capable of meeting its current licensing basis intended function with 60 mils of corrosion that could occur through the end of the period of extended operation.
During the audit, the staff made the following observations:
- Specification LS-MSS-2.3-F allows the use of an extruded inert plastic coating, X-TRU-COAT Amstead, installed by PLEXCO on ferritic steel pipe. The specification includes requirements to steel shot clean the pipe, apply an 8- to 10-mil hot-applied thermoplastic adhesive, apply a final extruded plastic coat based on pipe diameter up to 40 mils, and conduct an electrical inspection of the final coating.
- Drawing 2-DO-6 shows that there is ASTM A106 Grade B piping embedded in concrete between the diesel fuel oil day tank and the diesel. During the preparations for the audit,
the staff noted that UFSAR Section 9.5.4.4 states that components and piping, except for interconnecting piping between the day tanks and the diesel skids which is encased in the diesel room floor, are accessible for visual inspection. LRA Table 3.3.2-8 cites carbon steel piping and piping components exposed internally to fuel oil.
LRA Table 3.3.2-8 does not cite any AMR items for carbon steel piping and piping components exposed to concrete. During the audit, the applicant stated that it used a spaces approach to bound the environments in Table 3.3.2-8 and concluded that uncontrolled indoor air was the appropriate bounding environment for items located in the diesel rooms. The staff concluded that the concrete environment is not bounded by the uncontrolled indoor air. The staff noted that GALL Report item AP-282 states that there is no aging effect requiring management (AERM) and no recommended AMP for steel piping and piping components exposed to concrete, as long as (1) attributes of the concrete are consistent with American Concrete Institute (ACI)-318 or ACI-349 (low water-to-cement ratio, low permeability, and adequate air entrainment), as cited in NUREG-1557, Summary of Technical Information and Agreements from Nuclear Management and Resource Council Industry Reports Addressing License Renewal, issued October 1996, and (2) plant operating experience indicates no degradation of the concrete. The staff also noted that LRA Section 3.5.2.2.2.1 and UFSAR Table 3.8-2 state that concrete structures were constructed to ACI-318. The staff did not find any plant-specific operating experience associated with concrete degradation that would admit water to this embedded piping and that the piping is embedded in concrete between two internal elevations in the diesel room. The staff will not pursue an RAI associated with LRA Table 3.3.2-8 not citing the piping embedded in concrete because there is no recommended AERM and no recommended AMP for the material and environment combination.
- The Subsurface Soil Analysis to Support the LaSalle County Generating Station Underground Buried Pipe and Tanks Inspection Initiative states that the groundwater level is approximately 6 feet below grade except in one location where it is 10 feet below grade. The 10 feet below grade location is influenced by a nearby well.
- Materials Analysis Report M-0727-86 states the following in relation to a buried high-pressure core spray piping leak:
(a) the piping was 14-inch schedule 10; (b) two welds had through-wall leaks; (c) the piping was buried 14 feet below grade; (d) the apparent cause was microbiological corrosion due to iron oxidizing bacteria; (e) the welds had been field coated with a black asphalt mastic coating with very little of the coating remaining attached to the welds; (f) shop-applied coatings were intact; (g) the pitting attack appeared to originate on the external surface in the vicinity of the intersection of the longitudinal weld and circumferential welds; (h) no chemical or bacterial analysis was conducted due to the contamination of the piping; (i) microscopic examination revealed that there was a preferential attack of the delta ferrite phase of the weld metal; and (j) the cathodic protection system was not functional for long periods of time.
- Modification documents, M0-1-87-095 and MO-2-87-082, state that the high pressure core spray system piping, which was the subject of LER 85-027-01, was abandoned in-place, and reactor core isolation cooling lines were re-routed with new piping.
Drawing M-766 states that the RCIC piping is at plant elevation 705 feet. UFSAR Section 1.2.2.1.4 states that the plant elevation at grade is 710 feet.
- Piping Standard LS-PDT-140 and Passport Tags 1R130C and 1R116A state that Piping Design Table 140 was used for the RCIC modification. The standard states that the RCIC piping is stainless steel seamless schedule 40-type 304 piping. The fittings are seamless ASTM A403 Grade WP304 material.
- Inspection Report AM870-325261-PIMSI states that there are no indications of internal or external corrosion on the 4-inch and 8-inch RCIC lines of Units 1 and 2 based on guided wave inspections. The guided wave inspections inspected from 101 feet to 135 feet of each of the piping segments, encompassing a total of 19 welds and 4 elbows. One weld was exposed for visual inspection. Inspection Report WO 01431445-04 stated that the coatings on all four RCIC lines were in excellent condition. Based on the drawings provided in AM870-325261-PIMSI, approximately 15 feet of piping was exposed for coating inspection.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant was bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). The staff reviewed LER 85-027-01, which describes a significant leak in a buried portion of the high pressure core spray system. The staffs evaluation of this plant-specific operating experience will be documented in the SER.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M41, as modified by LR-ISG-2011-03. The staff also verified that for the detection of aging effects program element, the aspects of the LRA AMP program element not associated with the exception are consistent with the corresponding program element in GALL Report AMP XI.M41, as modified by LR-ISG-2011-03. The staffs evaluation of aspects of the program element associated with the exception will be addressed in the SER.
The staff also identified certain aspects of the detection of aging effects program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.29, ASME Section XI, Subsection IWE Summary of Information in the Application. The LRA states that AMP B.2.1.29, ASME Section XI, Subsection IWE, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S1, ASME Section XI, Subsection IWE.
To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not
resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: crack, drywell, corrosion, and rust.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.S1 Program Basis Document, Revision 1, ASME Section XI, Revision 1 Subsection IWE 12/17/14
- 2. LAS03.G03 LaSalle County Nuclear Power Station Units 1 & 2, ISI Program Plan, Revision 2 Third 10-Year Inspection Interval 8/10/12
- 3. LAS03.G04 LaSalle County Nuclear Power Station Units 1 & 2, ISI Classification Revision 2 Basis Document, Third 10-Year Inspection Interval 8/10/12
- 4. ER-AA-330-007 Exelon Nuclear, Visual Examination of Section XI Class MC Surfaces Revision 8 and Class CC Liners
- 5. MA-MW-736-600 Exelon Nuclear, Torqueing and Tightening of Bolted Connections Revision 5
- 6. ER-AA-335-018 Exelon Generation, Visual Examination of ASME IWE Class MC and Revision 9 Metallic Liners of IWL Class CC Components
- 7. ER-AA-330-009 Exelon Generation, ASME Section XI Repair/Replacement Program Revision 7
- 8. AR00464187 Pits Observed in Drywell Containment Liner 06/12/2008
- 9. WO 01561820 Work Order 01561820 12/12/2013
- 10. AR00737028 Degraded Coating Observed in the Suppression Pool 06/20/2008
- 11. AR00602378 Water Dripping from Top 3 Tendons on East Side of Reactor Building 04/16/2007 Containment
- 12. AR01038312 Missing Coating on Drywell Liner 740' Elevation 04/2/2010
- 13. AR02420888 Unit 2 Reactor Cavity Skirt Plate To Drain Line Leakage 12/04/2014
- 14. AR02447966 Leak Identified on Reactor Cavity Wall 02/05/2015
- 15. PES-S-010 Fasteners Revision 0 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the detection of aging effects program element, sufficient information was not available to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to obtain the information necessary to
verify whether this program element is consistent with the corresponding program element of the GALL Report AMP, the staff will consider issuing an RAI for the subject discussed below.
- The detection of aging effects program element of the LRA AMP notes that IWE pressure boundary surfaces, including containment sleeves and associated welds, are subject to Appendix J to 10 CFR Part 50 tests in addition to visual IWE examinations.
The GALL Report AMP recommends the program be augmented to require surface examination, in addition to visual examination, to detect cracking in stainless steel penetration sleeves and dissimilar metal welds. The GALL Report further states that, where feasible, Appendix J tests may be performed in lieu of the surface examination. It is not clear to the staff that these statements are consistent because the LRA does not clearly state whether the applicant will conduct surface examinations or will perform Appendix J testing instead. If the applicant will perform Appendix J testing, the LRA does not specify the type of testing or explain why the testing is appropriate to detect cracking.
The LRA AMP provides an enhancement to the preventive actions program element to include proper guidance for bolting material selection and installation. The associated GALL Report element identifies several industry documents that should be referenced on bolting material and installation. During the audit, the staff reviewed the AMP program basis document and the existing procedures and verified that the necessary references were either already included in the existing procedures or were clearly identified in the program basis document to be added to the procedures before the period of extended operation.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.
- The LRA discusses leakage from the reactor cavity pool and provides an enhancement to the monitoring and trending element to perform periodic ultrasonic thickness (UT) measurements of the containment liner in the vicinity of the leakage. During the audit, the staff reviewed documentation that shows leakage manifesting in a different location from where it has been historically identified. The staff will consider issuing an RAI to understand how the existing enhancement will address the plant-specific operating experience associated with reactor cavity leakage.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S1. The staffs evaluation of aspects of the program elements associated with enhancements will be addressed in the SER. The staff also identified certain aspects of the detection of aging effects program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.30, ASME Section XI, Subsection IWL Summary of Information in the Application. The LRA states that AMP B.2.1.30, ASME Section XI, Subsection IWL, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S2, ASME Section XI, Subsection IWL. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed enhancements associated with this AMP. The enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the containment exterior concrete. The staff also conducted an independent search of the applicants operating experience database using keywords: containment, crack, drywell and leach.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.S2 Program Basis Document, Revision 1, ASME Section XI, Revision 1 Subsection IWL 12/17/2014
- 2. ER-AA-330-005 Exelon Generation, Visual Examination of Section XI Class CC Revision 10 Concrete Containment Structures
- 3. ER-AA-330-006 Exelon Nuclear, Inservice Inspection and Testing of the Pre-Stressed Revision 7 Concrete Containment Post-Tensioning Systems
- 4. LAS03.G04 LaSalle County Nuclear Power Station Units 1 & 2, ISI Classification Revision 2 Basis Document, Third 10-Year Inspection Interval 08/10/2012
- 5. ER-AA-335-019 Exelon Nuclear, Visual Examination of ASME IWL Class CC Revision 0 Containment Components
- 6. LAS03.G05 LaSalle County Nuclear Power Station Units 1 & 2, ISI Selection Revision 1 Document, Third 10-Year Inspection Interval 3/31/11
- 7. LAS03.G03 LaSalle County Nuclear Power Station Units 1 & 2, ISI Program Plan, Revision 2 Third 10-Year Inspection Interval 08/10/2012
- 8. AR00157920 Degraded Tendon 04/21/2008
- 9. AR00302924 Water Leaks Observed on U2 RB Concrete Containment Wall 02/18/2005
- 10. AR02441090 U1 Tendon Tunnel Walkdown Results and Actions Needed 01/22/2015
- 11. WO 01444757-01 Visual ISI of U1 Containment Post-Tensioning Tendons 09/09/2014
- 12. WO 01413307-01 Exterior Containment Concrete Surface Inspection 09/23/2014
- 13. AR02439871 IWL Concrete Acceptance Criteria Not Established in Procedure 01/20/2015
Revision /
Document Title Date
- 14. AR01658189 Upper B Tendon Inspection Needed 05/09/2014 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). In order to obtain the information necessary to determine whether the applicants operating experience supports the sufficiency of the LRA AMP, the staff will consider issuing an RAI for the subject discussed below.
- The LRA discusses leakage from the reactor cavity pool that migrates through the containment concrete. The LRA provides an enhancement to monitor the thickness of the containment liner; however, the LRA does not discuss the impact of the leakage on the concrete.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S2.
Based on this audit, the staff also found that additional information is required before a determination can be made regarding whether the applicants operating experience supports the sufficiency of the LRA AMP. In addition, the staff verified the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.31, ASME Section XI, Subsection IWF Summary of Information in the Application. The LRA states that AMP B.2.1.31, ASME Section XI, Subsection IWF, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP X1.S3, ASME Section XI, Subsection IWF.
To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of Unit 1 Diesel Generator Building (DG1A Room) and Unit 1 Auxiliary Building (Core Standby Cooling System [CSCS] Pump Room). The staff also conducted an independent search of the
applicants operating experience database using keywords: loss of material, torque, preload, corrosion, support, lubrite, and vibration isolator.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-XI.S3 Program Basis Document - ASME Section XI, Subsection IWF Revision 4 04/09/2015
- 2. ER-AA-330 Conduct of Inservice Inspection Activities Revision 10
- 3. ER-AA-330-003 Inservice Inspection of Section XI Component Supports Revision 9
- 4. ER-AA-330-004 Visual Examination of Snubbers Revision 9
- 5. ER-AA-335-001 Qualification and Certification of Nondestructive Examination (NDE) Revision 6 Personnel
- 6. ER-AA-335-016 VT-3 Visual Examination of Component Supports, Attachments, and Revision 9 Interiors of Reactor Vessels
- 7. ER-AA-330-009 ASME Section XI Repair/Replacement Program Revision 7
- 8. LAS03.G03 ISI Program Plan - Third 10-Year Inspection Interval, LaSalle County Revision 3 Station Units 1 & 2 10/09/2014
- 9. LAS03.G04 ISI Classification Basis Document - Third 10-Year Inspection Revision 3 Interval, LaSalle County Station Units 1 & 2 10/09/2014
- 10. LAS03.G05 ISI Selection Document - Third 10-Year Inspection Interval, LaSalle Revision 2 County Station Units 1 & 2 10/09/2014
- 11. PES-S-010 Fasteners (Procurement Engineering Standards) Revision 0 09/15/2003
- 12. MA-MW-736-600 Torqueing and Tightening of Bolted Connections (Procedure) Revision 5
- 13. CC-AA-102 Design Inputs and Configuration Change Impact Screening Revision 27
- 14. PES-S-003 In-storage Maintenance of Nuclear Material Revision 8 09/03/2011
- 15. WO 00934604 ISI - Mechanical Component Supports VT-3 & 4 (Component Revision 1 Reactor Vessel Skirt; Procedure ER-AA-335-016, Revision 4) 02/26/2008
- 16. WO 01421353 ISI - Mechanical Component Supports VT-3&4 Revision 01 (Procedure ER-AA-330-003, Visual) 01/14/2013
- 17. RA13-023 Post-Outage 90-Day ISI Summary Report 05/31/2013
- 18. RA14-018 Post-Outage 90-Day ISI Summary Report 05/29/2014
- 19. AR01662773 Revise Documents To Include Supports for Vacuum Breaker Line 05/21/2014
- 20. AR01477092 Loose Clamp Bolting on 2RI24-2813X (Rigid Seismic Restraint) 02/19/2013
- 21. AR01475671 Spherical Bearing Dislodged from Strut Paddle 02/15/2013
- 22. AR01475099 Loose Clamp Bolting on 2RI24-2854X (Rigid Seismic Restraint) 02/14/2013
- 23. WO 1519995 Work Order To Repair Snubbers Bearings Clamps Issues and Loose 02/19/2013 Pipe Clamp Bolt Discovered during ISI
- 24. AR1330091 Loose Pipe Clamp Bolting on 1FW02-1055S 02/22/2012
Revision /
Document Title Date
- 25. WO 1517389 Tighten Loose Load Nuts on Support 1FW02-102V 02/29/2012
- 26. AR1358830 Lessons Learned from 1R14 04/26/2012
- 27. AR01333134 SH Chiller Primary Loop Suction Header Piping Support Broken 02/28/2012 (Weld Broken, Repair)
- 29. AR00196514 1VR05YB Damper Actuator Mounting Support Broken Bolt 01/20/2004
- 30. AR00141196 Cracked Support Braces in Main Condenser Hotwell Area (Unit 1 - 01/26/2003 Repair)
- 31. AR00601184 Spring Can Found Pinned for Hanger M09-DH00-2002V 03/08/2007 (U2 - Unpin)
The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the preventive actions program element, sufficient information was not available for Enhancement 1 (LR Commitment No. 31, item 1) to determine whether it was consistent with the corresponding program elements of the GALL Report AMP. In order to verify that the enhancement will make the AMP adequate to manage the applicable aging effects, the staff will consider issuing an RAI for the subject discussed below.
- The LRA AMP states an enhancement (Commitment No. 31, item 1) to the preventive action program element that will be implemented before the period of extended operation to become consistent with the corresponding GALL Report AMP program element. The enhancement states:
Provide guidance for proper specification of bolting material, storage, lubricant and sealants, and installation torque or tension to prevent or mitigate degradation and failure of structural bolting.
Requirements for high strength bolts shall include the preventive actions for storage, lubricants and stress corrosion cracking potential discussed in Section 2 of RCSC (Research Council on Structural Connections) publication Specification for Structural Joints Using ASTM A325 or A490 Bolts.
The preventive measures in the corresponding program element in the GALL Report AMP include a recommendation for using bolting material that has an actual measured yield strength less than 150 kilopounds per square inch (ksi) or 1,034 megapascal (MPa). Given that the LRA AMP does not include provisions for the GALL Report-recommended supplemental volumetric examination to detect SCC on the basis that high strength bolting (actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa) in sizes greater than 1-inch nominal diameter are not used in LSCS IWF supports, it is not clear to the staff whether these statements are consistent
because the enhancement does not prevent the future use of such high strength bolting material considered susceptible to SCC.
During the audit, the staff reviewed the program basis document LA-PBD-XI.S3, Revision 4, and associated implementing procedures and made the following observations:
- The LRA AMP provides an enhancement to the preventive action program element to include guidance for proper specification of bolting material selection, installation torque or tension, storage, and lubricants and sealants to prevent or mitigate degradation and failure of structural bolting. The associated GALL Report element identifies several industry documents (i.e., EPRI NP-5769, EPRI TR-104213, and NUREG-1339) that should be referenced to address these preventive actions. During the audit, the staff noted that Section 3.2, Preventive Actions, of the LRA AMP program basis document states, in part:
The applicable preventive action recommendations addressed within EPRI TR-104213 and NUREG-1339 for the proper selection of bolting material, lubricants and installation torque and tension to prevent and minimize loss of bolting preload and cracking of high strength bolting are addressed in existing station implementing procedures. For bolted connections, the program also relies on the design change procedures that will be enhanced to address EPRI NP-5769, EPRI TR-104213, and NUREG-1339 guidance to ensure proper specification of bolting material, lubricant and sealants, and installation torque or tension to prevent or mitigate degradation and failure of structural bolting. The implementing maintenance procedures will be enhanced to include EPRI NP-5769 as a referenced document. Station procedures, specifications and drawings provide replacement tightening (torque) consistent with EPRI guidelines and American Institute of Steel Construction (AISC) specifications, as applicable.
The statements above confirm that the necessary references were either already included in the existing procedures or were clearly identified in the program basis document to be added to the procedures before the period of extended operation.
- The staff noted that Section 3.2, Preventive Actions, of the program basis document states, in part, Structural bolting is received with a light coating of oil, and installed without additional lubricant. Additional thread lubricant is generally used on mechanical joints such as pipe flanges, however, additional thread lubricant is typically not used for IWF support structural bolting. The staff notes that this statement provides a reasonable indication that molybdenum disulfide or other lubricants have not been used for bolting in IWF supports at LSCS.
- The staff noted that in Section 3.4, Detection of Aging Effects, of the program basis document, the applicant made the following statement to justify why it did not perform supplemental volumetric examination, in addition to VT-3 examination, as recommended in the GALL Report AMP for high strength bolting (actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa) in sizes greater than 1 inch nominal diameter to detect cracking:
High strength bolts susceptible to SCC [stress corrosion cracking]
are not used in IWF supports at LaSalle. High strength bolting (actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa) in sizes greater than 1 inch nominal diameter are not used in LaSalle IWF supports. Plant-specific operating experience has not identified cracking or SCC for high strength bolts used in IWF supports at LaSalle IWF supports at LaSalle do not use high strength bolts requiring volumetric examination. LaSalle IWF supports do utilize ASTM A325 bolts, however ASTM A490 and ASTM F1852 bolts were not used for IWF supports. In order for SCC to occur in high strength bolting, three parameters must exist; (1) a corrosive environment, (2) a susceptible material, and (3) high sustained tensile stresses. All the parameters required for susceptibility and cracking to occur due to SCC are not present in the bolting material used at LaSalle for IWF supports.
Section 3.2, Preventive Actions, and Section 3.3, Parameters Monitored or Inspected, of the program basis document also include similar statements. The staff notes that these statements confirm that high strength bolting material susceptible to SCC, as recommended in the GALL Report (i.e., bolting with actual measured yield strength greater than or equal to 150 ksi or 1,034 MPa in sizes greater than 1 inch nominal diameter), are not used in LSCS IWF supports. These statements provide supporting justification for waiving the recommended supplementary volumetric examination for such high strength bolting.
- The staff noted that Section 3.1, Scope of Program; Section 3.3, Parameters Monitored or Inspected; Section 3.4, Detection of Aging Effects; and Section 3.6, Acceptance Criteria, of the program basis document state, Supports within the scope of ASME Section XI, Subsection IWF do not have elastomeric vibration elements at LaSalle. This statement justifies why the LRA AMP did not include provisions for supplementary examination of elastomeric vibration isolation elements by feel, as recommended in the GALL Report AMP, to detect hardening that may affect its vibration isolation function.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR, noting that the staff previously identified a need for additional information on Enhancement 1 (Commitment No. 31, item 1), which is also part of the UFSAR supplement description, for which the staff will consider issuing an RAI as described previously.
Audit Results. Based on this audit, the staff verified that the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S3. The staffs evaluation of aspects of the program elements associated with enhancements will be addressed in the SER. The staff also identified
certain aspects of the preventive actions program element, associated with Enhancement 1 (Commitment No. 31, item 1), of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR, noting that the staff identified a need for additional information related to Enhancement 1 (Commitment No. 31, item 1), which is also part of the UFSAR supplement description.
LRA AMP B.2.1.32, 10 CFR Part 50, Appendix J Summary of Information in the Application. The LRA states that AMP B.2.1.32, 10 CFR Part 50, Appendix J, is an existing program that is consistent with the program elements in GALL Report AMP XI.S4, 10 CFR Part 50, Appendix J. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: appendix, leak, and integrated.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.S4 Program Basis Document, Revision 0, 10 CFR Part 50, Appendix J Revision 0 04/02/2014
- 2. ER-AA-380 Primary Containment Leakrate Testing Program Revision 10
- 3. LTS-300-5 Primary Containment Leakrate Testing Program Revision 40 05/24/2011
- 4. LTS-300-4 Unit 1(2) Primary Containment Integrated Leak Rate Test (ILRT) Revision 27 08/20/2009
- 5. LTS-600-3 Primary Containment Inspection Revision 12 11/24/2010
- 6. AR01328655 LLRT on 1VQ34/35 Exceeds Admin Alarm Limit L1R14 02/18/2012
- 7. AR1598086 Inservice Inspection, Inservice Testing, and Appendix J Audit Report 09/17/2014 (NOSA-LAS-14-08)
- 9. 2008-2 Integrated Leakage Rate Test Final Report - LaSalle Nuclear Power 04/12/2008 Plant Unit 1
- 10. AR01622486 L1R15 1E12-F008 LLRT Exceeded As-Found Alarm Limit 02/17/2014 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging
effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit, the applicant provided a list of containment penetrations that are exempt from Appendix J testing, along with the AMPs that will manage aging of those penetrations during the period of extended operation. The staff reviewed the list and verified that all of the listed penetrations were within the scope of appropriate AMPs.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S4.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.33, Masonry Walls Summary of Information in the Application. The LRA states that AMP B.2.1.33, Masonry Walls, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S5, Masonry Walls. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements are evaluated in the SER. The LRA also states that this program is implemented as part of the Structures Monitoring Program described in LRA Sections A.2.1.34 and B.2.1.34.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the Unit 1 Diesel Generator Building (DG-1A Room), Unit 1 Auxiliary Building (Core Standby Cooling System (CSCS) Pump Room, Cable Spread Room, Division 1 Switchgear Room, and Battery Room), and Unit 1 Turbine Building Bay. The staff also conducted an independent search of the applicants operating experience database using keywords: masonry, block, crack, grout, mortar, CMU, and wall.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.S5 Program Basis Document: Masonry Walls (GALL Program XI.S5 - Revision 1 Masonry Walls) 12/12/2014
- 2. LA-PBD-AMP-XI.S6 Program Basis Document: Structures Monitoring Revision 3 (GALL Program XI.S6 - Structures Monitoring) 09/04/2014
- 3. LA-PBD-AMP-XI.M26 Program Basis Document: Fire Protection (GALL Program XI.M26 Revision 1
- Fire Protection) 09/24/2014
- 4. ER-LA-450-1006, LaSalle Structures Monitoring Instructions (Section 1.3 Program Revision 0 Section 1.3 Scope, Includes Masonry Walls)
- 5. ER-AA-450 Structures Monitoring (Section 1.3 - Scope; Attachment 2 - Revision 3 Examination Criteria, Item 3; Attachment 7, S03 -Sample Structural Examination Checklists)
- 7. OP-AA-108-115 Operability Determinations, Section 2.14 - Operability Evaluation Revision 11
- 8. CC-AA-309-101 Engineering Technical Evaluations, Section 1.2.2 Revision 13
- 9. CC-AA-406 Maintenance Specification: General Structural Installations into Revision 4 Concrete Walls
- 10. LAP-400-24 Documentation of Attachments to Safety Related Concrete Revision 0 Masonry Walls 06/11/2004
- 11. AR00253085 Upper Blocks of Removable Wall Loose 09/15/2004
- 12. AR00234403 Evaluation of LaSalle 6/28/2004 Seismic Event 07/07/2004
- 14. NA Masonry Walls Program Results Book (AMP B.2.1.33) 03/2015 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements (Commitment No. 33, items 1 and 2).
During the audit, the staff verified that the scope of program, preventive actions, detection of aging effects, and monitoring and trending program elements of the LRA are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the parameters monitored or inspected and acceptance criteria program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to verify that the enhancements applicable to these program elements will make the AMP adequate to manage the applicable aging effects, staff will consider issuing an RAI for the subject discussed below.
- The LRA AMP states an enhancement to the parameters monitored or inspected and acceptance criteria program elements in order to become consistent with the GALL Report. The enhancement (Enhancement 1, Commitment No. 33, item 1) states that, before the period of extended operation, the program will be revised to provide guidance for inspection of masonry walls for separation, and for gaps between the supports for masonry walls. The parameters monitored or inspected program element of the GALL Report AMP XI.S5 states, The primary parameters monitored are potential shrinkage and/or separation and cracking of masonry walls and gaps between the
supports and masonry walls that could impact the intended function or potentially invalidate its evaluation basis. It is not clear to the staff that these statements are consistent because, with regard to monitoring for gaps, the parameter monitored, as well as the corresponding acceptance criteria in the GALL Report AMP program elements, relate to gaps between the supports and masonry walls, which appears to be different from the parameter, gaps between supports for masonry walls, in the LRA AMP. The staff will consider issuing an RAI to allow the applicant to address this potential inconsistency in the characterization of the gaps between supports parameter monitored such that the enhancement will be adequate to establish consistency with the parameters monitored or inspected and acceptance criteria program elements of the GALL Report.
During the audit, the staff made the following observations:
- The staff noted that the applicants program basis document for Structures Monitoring lists the 2002 version of ACI 349.3R-02, Evaluation of Existing Nuclear Safety-Related Concrete Structures, as program reference 4.2.4. Because the Masonry Walls Program is implemented as part of the Structures Monitoring Program, Enhancement 2 (Commitment No. 33, item 2) to the Masonry Walls Program, as it relates to personnel qualifications, will be based on the 2002 version of ACI 349.3R-02, which is consistent with the version of ACI 349.3R referenced in the GALL Report AMP XI.S6.
- The staff also noted that the applicant uses Procedure LAP-400-24 to control modifications, additional attachments, penetrations, upgrades, and reclassification of safety-related masonry walls. The applicants use of this procedure indicates that it has administrative controls in place to ensure that the evaluation basis of masonry walls is not invalidated by one or more of the following: physical modifications, upgrades, or reclassification.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified that this description is consistent with the description provided in the SRP-LR, noting that the staff identified an inconsistency related to the wording of Enhancement 1 (Commitment No. 33, item 1), which is also part of the UFSAR supplement, for which the staff will consider issuing an RAI as described previously.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, detection of aging effects, and monitoring and trending, program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S5.
The staff also identified certain aspects of the parameters monitored or inspected, and acceptance criteria program elements, associated with Enhancement 1 (Commitment No. 33, item 1), of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the
description provided in the SRP-LR, noting that the staff identified a need for additional information related to the wording of Enhancement 1 (Commitment No. 33, item 1), which is also part of the UFSAR supplement.
LRA AMP B.2.1.34, Structures Monitoring Summary of Information in the Application. The LRA states that AMP B.2.1.34, Structures Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S6, Structures Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the system auxiliary transformer pads, the exterior of the Unit 2 side of the turbine building, auxiliary building and reactor building, the two condensate storage tank foundation pads, the interior of the Unit 1 turbine building, Unit 1 auxiliary building, Unit 1 diesel generator building, reactor building, spent fuel pool, and exterior of the Unit 1 primary containment. The staff also conducted an independent search of the applicants operating experience database using keywords: leach, leak, crack, spall, freeze, thaw, concrete, degrade, corrosion, groundwater, and settlement.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.S6 Program Basis Document for LaSalle Unit 1 and 2 Structures Revision 3 Monitoring
- 2. ER-LA-450-1006 LaSalle Structures Monitoring Instructions Revision 0
- 3. ER-AA-450 Structures Monitoring Revision 3
- 4. Not Available Structures Monitoring Program Walkdown Report 1999-2004 (varies)
- 5. MA-MW-736-600 Torqueing and Tightening of Bolted Connections Revision 5
- 6. PES-S-003 In-Storage Maintenance of Nuclear Material Revision 7
- 7. PES-S-010 Fasteners Revision 0
- 8. AR0969080 Pipe Support Degradation in Lower Level of Screen House 09/23/2009
- 9. AR0167187 Evaluate the Collective Issue with Concrete Spalling and Cracking 08/19/2014 Identified in IR
- 10. AR2486288 Misrepresentative Concrete Temperature Noted in SMP HD Room 04/16/2015 Report
- 11. AR1083729 Water Leaking from Exterior Concrete Wall to 754" TB Floor 06/23/2010
- 12. AR0163168 Exposed Reinforcing Bar Observed in the Concrete Base Mat 06/13/2003 (Tendon Tunnel Roof)
Revision /
Document Title Date
- 13. AR2485498 Minor Wall Seepage at LSH (EL. 683) above 0WS015A Valve 04/15/2015
- 14. N/A Structures Monitoring Program Results Book (AMP B.2.1.34) 03/2015 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements (Commitment No. 34, items 1 through 9).
During the audit, the staff verified that the scope of program, preventive actions, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that for the parameters monitored or inspected and detection of aging effects program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to verify that the enhancements will make the AMP adequate to manage the applicable aging effects, the staff will consider issuing RAIs for the subjects discussed below.
- The LRA AMP states an enhancement to the detection of aging effects program element (Enhancement 7, Commitment No. 34, item 7) intended to augment the existing program for inaccessible below-grade concrete structural elements exposed to nonaggressive groundwater/soil in order to become consistent with the GALL Report recommendations. The enhancement states that for in-scope structures, representative samples of the exposed portions of the below-grade concrete will be examined when excavated for any reason. The GALL Report AMP recommends the following for plants with nonaggressive groundwater/soil: (a) evaluating the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas and (b) examining representative samples of the exposed portions of the below-grade concrete, when excavated for any reason. It is not clear to the staff that this program element is consistent because the LRA AMP only addresses item (b) of the GALL Report recommendations.
- The LRA AMP states an enhancement to the scope of program program element (Enhancement 1, Commitment No. 34, item 1). The enhancement states that, before the period of extended operation, the components and commodities listed, which included, among others, the component type permanent drywell shielding, will be added to the scope of the program. LRA Table 3.5.2-7 notes, on LRA page 3.5-160, that this component includes blanket covers of material fiberglass, which will be inspected by the Structures Monitoring program for rips and tears, and lists the AERM as change in material properties. The GALL Report AMP does not provide recommendations for managing the aging effects of fiberglass blanket covers of shielding components, nor did the applicant provide additional enhancements to the parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements. It is not clear to the staff that the enhancement provided to the LRA AMP is sufficient to adequately address the detection of aging effects, parameters monitored or inspected, and acceptance criteria program elements for the permanent drywell shielding component added to the scope of the program.
During the audit, the staff made the following observations:
- The LRA AMP provides an enhancement to the preventive actions program element (Enhancement 2, Commitment No. 34, item 2) to include guidance for proper specification of bolting material, lubricant, and installation torque or tension to ensure bolting integrity. The associated GALL Report provision identifies several industry documents that should be included in the program on bolting material, lubricants, and installation. During the audit, the staff reviewed the AMP program basis document and the existing procedures and verified that the necessary references were either already included in the existing procedures or were clearly identified in the program basis document to be added to the procedures before the period of extended operation.
- The staff noted that the detection of aging effects program element of the LRA AMP does not include the GALL Report recommendation to perform visual inspections supplemented by feel to detect hardening in elastomeric vibration isolation elements if the function is suspect. During the audit, the staff noted that the applicant does not use elastomeric vibration isolation elements at LSCS. The staff reviewed the AMP program basis document, associated references, and site operating experience and verified that the applicant does not use any elastomeric vibration isolation elements at the plant. The staff did not observe or identify the use of elastomeric vibration isolation elements during the audit review.
- During the staffs independent review of site operating experience, the staff noted that the report entitled, Structures Monitoring Program Walkdown Report (1999 to 2004),
identifies degradations (cracks) on the turbine building concrete slab in the area immediately surrounding the four heater drain pumps (1HDO1PA,B,C,D). In the report (Sections T-2001 and T-2002), the degradation was attributed to elevated temperatures imposed by the heater drain pumps to the concrete. During the audit, the staff also reviewed AR2486288, which states that the maximum concrete temperature measured during the walkdown was 169 °F at one of the pumps with the Unit at 100-percent power. AR2486288 further explains that the design provides intervening thermal barriers (air gap and steel surface liner) to provide insulation from the pump bowl (with temperatures of 300 °F, as obtained from system surveillance).
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S6. The staffs evaluation of aspects of the program element associated with enhancements will be addressed in the SER. The staff also identified certain aspects of the parameters monitored or inspected, detection of aging effects, and acceptance criteria program elements of the LRA AMP for which additional information or additional evaluation is required before consistency with the GALL Report or adequacy of enhancement that expands program scope can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.35, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants Summary of Information in the Application. The LRA states that AMP B.2.1.35, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.
The LRA also states that this program is implemented as part of the Structures Monitoring Program described in LRA Sections A.2.1.34 and B.2.1.34.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the lake screen house, cooling lake, and intake flume (including the earthen walls, south flume concrete retaining wall, and north flume sheet piling retaining wall). The staff also conducted an independent search of the applicants operating experience database using keywords: leach, leak, crack, spall, freeze, thaw, concrete, degrade, corrosion, groundwater, and settlement.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.S7 Program Basis Document for LaSalle Units 1 and 2 RG 1.127, Revision 3 Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP
- 2. ER-LA-450-1006 LaSalle Structures Monitoring Instructions Revision 0
- 3. ER-AA-450 Structures Monitoring Revision 3
- 4. SA-AA-117 Excavation, Trenching, and Shoring Revision 16
- 5. Not Available Structures Monitoring Program Walkdown Report 1999-2004 (Varies)
- 6. 2013-LAS-336 Annual Field Surveillance Report (September 2013) Revision 0
- 7. AR2385063 Annual Major Dike Inspection Findings: 2014 09/23/2014
- 8. AR2473898 Structural Monitoring Incomplete for 2009-2014 Cycle 03/25/2015
- 9. AR0530632 Clean and Recoat CSCS Line in LSH 10/24/2007
- 10. AR2485498 Minor Wall Seepage at LSH (EL. 683) above 0WS015A Valve 04/15/2015
The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements (Commitment No. 35, items 1 through 6).
During the audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In order to verify that the enhancements will make the AMP adequate to manage the applicable aging effects, the staff will consider issuing an RAI for the subject discussed below.
- The LRA AMP states an enhancement to the scope of program program element. The enhancement states that the existing program and procedures will be enhanced to include the shad net anchors to the scope of the existing RG 1.127 program. During the audit, the staff noted that the concrete structure (concrete piers) where the shad net anchors are attached are subject to aging management; however, these structures were not included as part of the LRA enhancement to the scope of program program element. The staff is concerned that by not clearly describing the different material components associated with the shad net anchors structure, the RG 1.127 program might not adequately manage the aging effects of in-scope components associated with the water-control structures.
During the audit, the staff made the following observation:
- During the audit, the staff noted that Section 2.1, item (c), of the LRA AMP basis document states that the LSCS cooling lake embankment (dike) is classified as a dam by the State of Illinois and that it complies with the regulatory requirements in Section 17 IAC 3702.30(C) of the State regulations. The program description section of the GALL Report AMP XI.S7 states that, for dam inspection and maintenance programs that do not fall under the regulatory jurisdiction of the Federal Energy Regulatory Commission (FERC) or the U.S. Army Corps of Engineers (USACE), the effectiveness of the AMP is evaluated based on compatibility to common practices of the FERC and USACE programs. However, Section 3.3, item (b) of LRA AMP basis document clarifies that the earthen embankments (dikes) surrounding the cooling lake are not in-scope for license renewal, and Section 3.4.3 of the LRA AMP basis document further explains that that failure of the cooling lake embankment and internal dikes (including the discharge structure and discharge flume) does not affect any [license renewal] intended function and does not affect the ultimate heat sink.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S7. The staff also identified certain aspects of the scope of
program program element of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.36, Protective Coating Monitoring and Maintenance Program Summary of Information in the Application. The LRA states that AMP B.2.1.36, Protective Coating Monitoring and Maintenance Program, is an existing program that is consistent with the program elements in GALL Report AMP XI.S8, Protective Coating Monitoring and Maintenance Program. To verify this claim of consistency, the staff audited the LRA AMP.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: coating, torus, and Service Level I.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.S8 Protective Coating Monitoring and Maintenance Program Revision 0 05/25/2014
- 2. WO 01427974 Inspect Unit 2 Primary Containment Drywell Coatings L02-CI-1-PC-Inspect
- 3. WO 01426644 Apply Service Level I Coating to Pipe Cap and Blind in Drywell
- 4. WO 00899457 IWE Surf./Bolt Exam of DW HD., Skirt, Wall Liner, L01PC-VT3-WLKDN-02S
- 5. AR737028 Degraded Coating Observed in Supp. Pool
- 6. WO 1113904 IWE Surf./Bolt Exam of DW HD., Skirt, Wall Liner, L01PC-VT3-WLKDN-02S
- 7. WO 1315656 Missing Coating on Drywell Liner 740' to 760' Elevations
- 8. AR1038312 Missing Coating on Drywell Liner 740' Elevation
- 9. AR1038314 Missing Coating on Drywell Liner 777' Elevation
- 10. AR00737028 Degraded Coating Observed in the Supp. Pool
- 11. AR01197921 Apply Service Level I Coating to Pipe Cap in Drywell
- 12. AR00604587 Load Binders in Drywell Per EC362872
- 13. ER-AA-330-008 Exelon Service Level I, and Safety-related (Service Level III) Revision 9 Protective Coatings
- 14. Specification Mechanical and Structural Work Specification T-3763 Maintenance/Modification Work
During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.S8.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA states that AMP B.2.1.37, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new program that will be consistent with the program elements in GALL Report AMP XI.E1, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed all the documents necessary to implement this new program, and the staffs audit addressed only the LRA AMP, the applicants basis document, operating experience, and draft implementing procedures.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted reviews of the applicants corrective actions, work orders, draft implementation procedures, walkdown documentation, and surveillance documentation. The staff also conducted an independent search of the applicants operating experience database using the keywords: cable, jacket ,
cracked, thermal, connection, contamination, discoloration, swelling, and moisture.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. LA-PBD-AMP-XI.E1 Program Basis Document - Insulation Material for Electrical Revision 1 Cables and Connections Not Subject to 10 CFR 50.49 N/A Environmental Qualification Requirements
- 2. MAA-AA-723-500 Inspection of Non EQ Cables and Connection for Managing Revision 6 Adverse Localized Environments N/A
- 3. ER-AA-300-150 Cable Condition Monitoring Program Revision 0 N/A
- 4. AR00092281 Damaged Cables in Unit 1 Heater Bay Revision N/A 01/25/2002
- 5. AR01514258 Engineering Cable Program Walkdown Results - 1B TDRFP Revision A N/A (Unit 1 Auxiliary Building Turbine Driven Reactor Feed Pump B) 05/15/2013
- 6. AR01514267 Engineering Cable Program Walkdown Results - 1A TDRFP Revision N/A (Unit 1 Auxiliary Building Turbine Driven Reactor Feed Pump A) 05/15/2013
- 7. AR01548187 Engineering Program Finding (Cable Tray Points 43A (1WP) and Revision N/A 43B (1WC) and Cable Tray Points 63A (2WP) and 62A (2WP). 08/19/2013 Water Appears To Have Been Coming through the Conduit Sleeves onto the Cable Trays).
- 8. ER-AA-3003 Cables in Adverse Localized Environments (ALEs) - Area Revision N/A Walkdowns 2012-2013
- 9. AR01622637 Engineering Cable Program Walkdown Finding -1B21-F013F Revision N/A 02/18/2014
- 10. AR01628707 1D CD/CB Pump Tripped Revision N/A 03/03/2014 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR. The staff also noted that the applicant committed to implement the new Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP before the period of extended operation (Commitment No. 37) for managing the effects of aging for applicable components.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.E1.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the
staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.38, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.
Summary of Information in the Application. The LRA states that AMP B.2.1.38, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, is a new program that will be consistent with the program elements in GALL Report AMP XI.E2, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed all the documents necessary to implement this new program, and the staffs audit addressed only the LRA AMP, the applicants basis document, operating experience, and draft implementation procedures.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: connection, radiation monitor, SRM, IRM, LPRM, standby gas, stack, cable, and connector.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.E2 Program Basis Document - Insulation Material for Electrical Cables Revision 0 and Connections Not Subject to 19 CFR 50.49 Environment 05/13/2014 Qualification Requirements Used in Instrumentation Circuits
- 2. AR01033311 SRM A Insulation Shield to Ground is Degraded Revision N/A 02/20/2010
- 3. WO 01248911 LPRM High Shield to Ground Resistance Problems Revision N/A 10/12/2015
- 4. LIP-NR-510 Unit 1 LPRM Plots - Instrument Maintenance Procedure (Markup) Revision 15 02/07/2014
- 5. LIP-NR-511 Unit 1 SRM Detector Plot I/V Plots - Instrument Maintenance Revision 7 Procedure (Markup) 11/01/2005
- 6. LIP-MS Unit 1 Main Steam Line Radiation Monitor Calibration - Instrument Revision 7 Maintenance Procedure (Markup) 03/10/2010
- 7. AR01507469 RM-2A and 2E IRM Spike - Half Scram Revision N/A 04/28/2013
- 8. AR009978385 Spiking Indication on U-2 G IRM Caused Half Scram Revision N/A 10/13/2009
- 9. AR02447653 RM - Spike on A, B, and D SRMS Revision N/A 02/04/2015
Revision /
Document Title Date
- 10. AR00555126 LPRM 24-57B Drifting Revision N/A 11/08/2006 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR. The staff also noted that the applicant committed to implement the new Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits AMP before the period of extended operation (Commitment No. 38) for managing the effects of component aging.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.E2.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Summary of Information in the Application. The LRA states that AMP B.2.1.39, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, is a new condition monitoring program that will be consistent with the program elements in GALL Report AMP XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed all the documents necessary to implement this new program, and the staffs audit addressed only the applicants existing basis document, operating experience, and draft implementing procedures.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted reviews of the corrective actions, planned modifications to add automatic sump pumps (manholes 3 and 4),
manhole inspections, cable condition monitoring test results, inspection photographs of in-scope manholes 3, 4, 5, and 6, and draft implementation procedures. Additionally, the staff also conducted an independent search of the applicants operating experience database using the keywords: cable, manhole, vault, submergence, and jacket.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.E3 Inaccessible Power Cables Not Subject to 10 CFR 50.49 Revision 1 Environmental Qualification Requirements
- 2. RS-07-067 Response to NRC Generic Letter 2007-01, Inaccessible or 05/07/2007 Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients
- 3. RS-07-156 Response to Request for Additional Information (RAI) Regarding 12/07/2007 Resolution of NRC Generic Letter 2007-01, Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems or Cause Plant Transients
- 4. LRA Appendix B LRA AMP B.2.1.39, Inaccessible Power Cables Not Subject to 12/09/2014 10 CFR 50.49 Environmental Qualification Requirements 5.LRA Appendix A Updated Final Safety Analysis Report Supplement - Section A.2.1.39 12/09/2014
- 6. LRA Appendix A Updated Final Safety Analysis Report Supplement - Table A5 - 12/09/2014 Commitment 39 - Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements
- 7. AR00591281 NRC GL-2007-01 Input Provide Site-Specific Input to GL Response 04/05/2007 Lead for Requested Information Items 1 and 2
- 8. AR00760587 SEN 272 Follow-up - Evaluate Submerged Cables in Response to 08/18/2008 the Corporate SMEs Review of SEN 272, as Documented in Assignment 1, Identify and Evaluate Submerged Electrical Cables per the Review Template in the In-Progress Notes
- 9. AR01056715 NER NC-10-008-Y-Action #9 Long-Term Plan - Develop Long-Term 12/01/2010 Action Plans To Address Cables Routed in Underground Structures 10.ER-AA-300-150 Cable Condition Monitoring Program Revision 0
- 11. WO 01692338 Manhole Inspection and Pumping if Required N/A
- 13. Severe Weather and Natural Disaster Guidelines Revision 12 OP-AA-108-111-1001
- 14. AR01622264 Panel Alarming - OPL-MH5 05/27/2014
- 15. AR00956848 LaSalle Assessment Deficiency - Manhole Inspections/Pump 05/27/2014
- 16. AR01126512 Inspection of Cables in Underground Vaults (Manholes 3, 4, 5, and 6) 01/20/2015
- 17. LSCS AMP Inaccessible Power Cables Not Subject to 10 CFR 50.49 N/A Activities Summary Environmental Qualification Requirements (B.2.1.39)
- 18. ER-AA-300-150 Attachment 1 - Pumping Criteria and Long-Term Wetting Definition Revision 0a
- 19. ER-AA-300-150 Attachment 3 - License Renewal, Inaccessible Power Cable Not Revision 0 Subject to 10 CFR 50.49 Environmental Qualification Requirements Program (CM-2)
- 20. AR02474626 Engineering Cable Vault Walkdown 03/26/2015
- 21. EC 389576 Design Consideration Summary Revision 001
Revision /
Document Title Date
- 22. EC 389576 Work Planning Instruction: Install Automatic Sump Pumps in Revision 1 Underground Cable Vaults (Manholes 5 and 6)
- 23. AR00336085 Water in Cable Vaults 5/16/2005
- 24. WO 1068947-04 Replace Old Feed Cable Splices in Manholes (Manholes 5 and 6) N/A (Cable 2WS013)
- 25. WO 1399932 Power Cable to 0WS02PA Revision 0 01/2012
- 26. WO 17221870 MH 1/2/3/4/5/6, Manhole and Inspection and Pumping if Required Revision 0 08/2014
- 27. PMID 187009 Model Work Order 1692338, MH-1/2/3/4/5/6 Manhole Inspection and N/A Pumping if Required (MHs 1 & 2 Not In Scope of AMP)
- 28. IE-1-3685 Cable Routing Outdoor Area Revision 2 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit, the staff made the following observations:
- The staff reviewed in-scope medium-voltage test results for the years 2005, 2006, 2007, 2008, 2009, 2010, 2011, 2012, and 2014 and noted that all tests showed satisfactory results. In addition, the staff reviewed the applicants GL-2007-01 responses for inaccessible power cables and more recent inaccessible cable operating history noting that the applicant did not identify any inaccessible power cable failures.
A review of LRA AMP Results Book WO 01721870, MH-1/2/3/4/5/6, identified recent inspections of in-scope manholes 3, 4, 5, and 6 that found water in manholes 3 and 4.
Manholes 5 and 6 have sump pumps installed and showed no water. Based on the water collection history for manholes 3 and 4, the applicant has implemented an engineering change to install sump pumps in manholes 3 and 4.
- LA-PBD-AMP-XI.E3 did not specifically address inspection of structural (electrical) support members in electrical manholes. The staff reviewed the applicants Structures Monitoring basis document and confirmed that this program includes enhancements for the inspection of electrical support members, electrical cable trays, electrical duct banks, and electrical manholes.
- In its review of basis document LA-PBD-AMP-X1.E3, the staff noted that for program element preventive actions, the applicant provided an apparent revision to the elements preventive actions criteria. GALL Report AMP XI.E3 states that cables/splice and cable support structures are intact and dewatering/drainage systems (i.e., sump pumps) and associated alarms operate properly. The applicant revised the cables/splices and cable support structures are intact portion of the program element in the basis document, AMP summary document, and the draft implementation work order to read as follows: The inspection will include direct observation to assure cables are not wetted or submerged, cables and connections are intact without observable surface
damage, cable support structures are intact, and drainage systems and dewatering devices and associated alarms are operating properly.
However, LRA AMP B.2.1.39 and the UFSAR summary do not reflect this change. The staff reviewed the applicants revised element discussion and concluded that the applicants change is a clarification of the GALL Report AMP XI.E3 inaccessible power cable/splice and support structure visual inspection guidance. Therefore, LRA AMP B.2.1.39 and the UFSAR summary remain consistent with GALL Report AMP XI.E3 program element preventive actions without exception or enhancement.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR. The staff also noted that the applicant committed to implement the new Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP before the period of extended operation (Commitment No. 39) for managing the effects of aging for applicable components.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.E3.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.40, Metal Enclosed Bus Summary of Information in the Application. The LRA states that AMP B.2.1.40 Metal Enclosed Bus, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP XI.E4, Metal Enclosed Bus. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the program elements described in the applicants basis document.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the in-scope portions of the metal enclosed bus (MEB) and associated station auxiliary transformers SAT142 and SAT242, Unit 1 emergency switchgear room, and diesel generator DG0. The staff also conducted an independent search of the applicants operating experience database using keywords: bus, connections, loose connections, insulators, metal enclosed bus, and non-segregated bus.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-Xl.E4 Metal Enclosed Bus, GALL Program Xl.E4 - Metal Enclosed Bus Revision 1 12/05/2014
- 2. LEP-AP-101 Unit 1 Non-Segregated Phase Bus Duct Preventive Maintenance Revision 16 Inspection
- 3. AR00734244 1E MPT Isophase Bus B Phase Duct Insulator Broken 01/11/2008
- 4. AR00825284 NER NC-08-046 LaSalle Isophase Insulator Failure 10/01/2008
- 5. AR00989226 SER 5-09 Non-Segregated Bus Failure and Complicated Scram 11/05/2009 (Evaluation of an Event That Occurred at Another Site)
- 6. AR0091049 142Y to 242Y Unit Tie Bus Duct Inspection 03/09/2004
- 7. AR01406889 SAT Non-Segregated Bus Duct Bolted Connections 09/29/2012
- 8. AR02435014 Difficult to Access Segments of Non-Segregated Bus Provide Input to 06/30/2015 Maintenance for the Testing To Be Performed for Difficult To Access Segments of Non-Segregated Bus during the Performance of LEP-AP-101 and LEP-AP-201
- 9. U122216 General Layout of Metal Enclosed Non-Segregated Phase Bus Duct Revision 6
- Drawing
- 10. L-97420 Rigid Connector Assembly 5000 Amp. 20" Gap Revision 0
- 11. T-158061X22 Shop Assembly - Non-Segregated, Alum (Non-insulated) 5KV 5000 Revision 0 Amp 60 KV BIL - Drawing
- 12. L-974900X2 Alignment Joint Cover - Drawing Revision 0 10/1975
- 13. T-158079X1 Wall Plate Non-Segregated Bus Duct 5KV 60 KV B.I.L. 5000 Amp Revision 0 Non-Insulated - Drawing 01/12/1976 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit, the staff made the following observations:
- The staff reviewed vendor drawings associated with transition pieces of the MEB components and verified the lack of any internal cable connections or flexible joints that may be constructed of different material or that potentially may be subject to aging mechanisms, or both, and effects other than those evaluated in the GALL Report (AMP XI.E4). These drawings are listed as items 9 through 13 in the table above.
- The staff reviewed MEB operating experience and walked down the in-scope MEB runs and did not identify MEB exterior conditions or operating experience that would indicate that the applicant should consider modifying its proposed program. In addition, the MEB condition and operating experience, including aging mechanisms and effects, appear consistent with those for which GALL Report AMP XI.E4 was evaluated.
- During the walkdown, the staff noted that the majority of the MEB segments are accessible for inspections and testing activities. However, some segments of the MEB are installed near other permanent structures where removal of the MEB enclosure covers for visual inspection and testing appear to be hindered.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). The staffs evaluation of the applicants plant-specific operating experience will be addressed in the SER.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.E4. .
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.1.41, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualifications Requirements Summary of Information in the Application. The LRA states that AMP B.2.1.41, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualifications Requirements, is a new program that will be consistent with the program elements in GALL Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualifications Requirements. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the existing AMP basis documents and draft procedures for implementation of AMP B.2.1.41.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted walkdowns of the in-scope portions of the 345 kV switchyard, station auxiliary transformers SAT 142 and SAT 242, Unit 1 emergency switchgear room, and diesel generator room DG0. The staff also conducted an independent search of the applicants operating experience database using the keywords: cables, connections, and thermography.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-XI.E6 Program Basis Document, Electrical Cable Connections Not Subject Revision 1 to 10 CFR 50.49 Environmental Qualifications 12/05/2014
- 2. LA-AMPBD-E6 Electrical Cable Connections Not Subject to 10 CFR 50.49 Revision 0 Environmental Qualifications - Sample Basis Document Draft
- 3. ER-AA-300-120 Electrical Cable Connections Not Subject to 10 CFR 50.49 Revision 1 Environmental Qualifications - Qualification Requirements Program
- 4. MA-AA-716-230-1003 Thermography Program Guide Revision 4
- 5. LEP-GM-113 Cable Terminations Revision 16
- 6. AR01544267 OSH01CC Hot Spot Identified by Thermography 09/16/2013
- 7. AR01524620 Thermal Anomaly Identified on 1VP01PB Contactor 07/13/2013
- 8. AR01520436 2A HDP Trip 04/30/2014
- 9. AR00641896 Thermography Identified Hot Spot in 0SH01CE 07/19/2007 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff). The staffs evaluation of the identified plant-specific operating experience will be addressed in the SER.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.E6.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.2.2.1, Service Level III and Service Level III Augmented Coatings Monitoring and Maintenance Program Summary of Information in the Application. The LRA states that AMP B.2.2.1, Service Level III and Service Level III Augmented Coatings Monitoring and Maintenance Program, is a new plant-specific program. The staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only plant-specific operating experience, and markups of existing plant-specific procedures annotated with potential changes to implement the new AMP. Issues identified but not resolved in this report will be addressed in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using the keywords: clog, coat, damage, delam, jacket, lined, lining, perforat, holiday, and wrap.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-PS1 Program Basis Document - Service Level III and Service Level III Revision 1 Augmented Coatings Monitoring and Maintenance Program
- 4. AR01605964 Degraded Coating on 1WR01AA Heat Exchanger 01/08/2014
- 5. ER-AA-330-008 Exelon Service Level I and Safety-Related (Service Level III) Revision 9 Protective Coatings
- 6. LMP-RI-02 Reactor Core Isolation Cooling Turbine Maintenance Revision 23
- 7. LMS-DG-01 Main Emergency Diesel Unit Surveillance Revision 50
- 8. LOS-FP-R1 Transformer Deluge Test for Main Power Transformer 1E (2E) and Revision 15 1W (2W)
- 9. LOS-FP-R2 Transformer Deluge Test for Unit Auxiliary Transformer 141 (241) Revision 14
- 10. LOS-FP-R3 Transformer Deluge Test for System Auxiliary Transformer 142 (242) Revision 18
- 11. ER-AA-340-1002 Service Water Heat Exchanger Inspection Guide Revision 5
- 12. AR00972566 Documentation of 2A DG Cooler Coating Failure 09/28/2009
- 13. AR02382989 0DG01A HX Coating 09/18/2014
- 14. AR01465974 Required Flows Not Met during LOS-DG-Q2 01/23/2013
- 15. AR01433447 CCA [Common Cause Analysis] Needed for CSCS Low Cooling 10/30/2012 Water Flow Coincident with the applicants development of the LRA, the staff issued the final version of LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, on
November 14, 2014. The applicant used the draft version (issued for public comment on January 10, 2014) of LR-ISG-2013-01, Aging Management of Loss of Coating Integrity for Internal Service Level III (Augmented) Coatings (Agencywide Documents Access and Management System Accession No. ML13262A442), to develop the LRA. The staff audited the LRA program to the final version of LR-ISG-2011-03, which included a new AMP, GALL Report AMP XI.M42, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks.
During the audit of program elements 1 through 7, the staff verified that the preventive actions, parameters monitored or inspected, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. For the scope of program, detection of aging effects, acceptance criteria, and corrective actions program elements, sufficient information was not available to determine whether they were consistent with the corresponding program elements of the GALL Report AMP. In order to obtain the information necessary to verify whether these program elements are consistent with the corresponding program elements of the GALL Report AMP, the staff will consider issuing RAIs for the subjects discussed below.
- The staff noted that LRA Table 3.3.2-7, Demineralized Water Makeup System, states that internally coated (i.e., galvanized steel) piping and piping components exposed to treated water will be managed for loss of coating integrity by the Service Level III and Service Level III Augmented Coatings Monitoring and Maintenance Program. However, the scope of program program element does not include the demineralized water makeup system. The staff lacks sufficient information to conclude whether the scope of program element or LRA Table 3.3.2-7 is correct.
- The detection of aging effects program element of the LRA AMP states that internal coating inspections may be omitted if the degradation of coatings cannot result in downstream effects; however, inspections are conducted if corrosion rates or inspection intervals have been based on the integrity of the coatings. In this case, as an alternative to direct internal visual inspection of the coatings, external wall thickness measurements can be performed to confirm the acceptability of the corrosion rate of the base metal.
The GALL Report AMP recommends a periodicity and size of inspection for alternative wall thickness measurements, which was not included in the draft GALL Report AMP XI.M42. Specifically, the AMP recommends that wall thickness measurements be conducted every 10 years, beginning 10 years before the period of extended operation.
A representative sample size is 25 percent of accessible external surfaces for heat exchangers, strainers, and tanks and 73 1-foot axial length circumferential segments for piping. In addition, the final GALL Report AMP XI.M42 recommends that the inspection grid size be the same as that for flow-accelerated corrosion inspections. It is not clear to the staff that these statements are consistent because the applicant did not include the recommended specificity in its program.
Peeling and delamination is evaluated by a coatings specialist.
When coating defects are detected, visual inspections will be supplemented by additional testing as determined by the inspector as necessary to accurately assess coating condition.
When peeling and delamination is detected, physical testing is performed, where possible (i.e., sufficient room to perform the test), if required to assess the condition of the coating.
When blisters are detected, physical testing is conducted if required to assess the condition of the coating.
[I]f appropriate, corrective actions may include repair or replacement of the internal coating prior to the component being returned to service.
The Final LR-ISG-2013-01 GALL Report AMP XI.M42 recommends that indications of peeling and delamination are not acceptable, whereas the applicant stated that a coatings specialist would evaluate the condition. The applicant did not state what criteria would be used to find peeling or delamination acceptable or what actions would be taken before returning the degraded component to service. The corrective actions program element of LR-ISG-2013-01 GALL Report AMP XI.M42 recommends that, for indications of peeling and delamination that will be returned to service without repair and for blisters, adhesion testing should be conducted. For blisters, alternatives to adhesion testing are permitted in cases in which adhesion testing is not possible due to physical constraints.
The applicant stated that physical testing would be conducted if required. The applicant did not state what criteria would be used to conclude that physical testing would not be required. In the absence of physical testing, it is not clear to the staff how the applicant would determine the extent of peeling, delamination, or blistering. The staff noted that the corrective actions program element of LR-ISG-2013-01 GALL Report AMP XI.M42 states that coatings that do not meet acceptance criteria are repaired, replaced, or removed. The staff concludes that the applicants statement, if required, implies that coatings that do not meet acceptance criteria could be returned to service without repair, replacement, or removal. The applicant did not state what criteria would be used to return coatings that do not meet acceptance criteria to service without repair.
During the audit, the staff made the following observation:
- ER-AA-330-008 states that any coating defects or precursors to coating defects shall be photographed.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the preventive actions, parameters monitored or inspected, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M42. The staff also identified certain aspects of the scope of program, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.3.1.1, Fatigue Monitoring Summary of Information in the Application. The LRA states that AMP B.3.1.1, Fatigue Monitoring, is an existing program with enhancements that will be consistent with the program elements in GALL Report AMP X.M1, Fatigue Monitoring. To verify this claim of consistency, the staff audited the LRA AMP. During the audit, the staff reviewed the enhancements associated with this AMP. The enhancements will be evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: fatigue, cycle, and cracking.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PDB-AMP-X.M1 Program Basis Document - Fatigue Monitoring Revision 0 12/05/2014
- 2. ER-AA-47 Fatigue Management Program Description Revision 0
- 4. LTP-300-9 Thermal Cycle Monitoring Program Technical Procedure Revision 15 09/23/2014
- 5. Results Book - Results Book - Fatigue Monitoring Revision 0 AMP B.3.1.
- 6. AR01641091 LR - Fatigue Monitoring Program Cycle Count Issues 03/31/2014
- 7. CAR 01-97-028 Thermal Cycle Monitoring Program 03/20/1997
- 8. L-003921 LaSalle Unit 1 Cycle Re-Count and Cycle Projections Revision 1
- 9. L-003921 LaSalle Unit 2 Cycle Re-Count and Cycle Projections Revision 2
- 10. AR02391593 Thermal Cycle LTP-300-9 Counts 10/06/2014 The staff conducted its audit of LRA program elements one through six based on the contents of the existing program as modified by the proposed enhancements.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit of the operating experience program element, the staff determined that the operating experience provided by the applicant and identified by the staffs independent database search is bounded by industry operating experience (e.g., no previously unknown aging effects were identified by the applicant or the staff). The applicant addressed generic communication (Regulatory Issue Summary (RIS) 2008-30, Fatigue Analysis of Nuclear Power Plant Components, dated December 16, 2008) and its impact on its plants. The applicant determined that the analysis methodology described in RIS 2008-30 was not used; therefore, the RIS was not applicable. The staff also determined that the operating experience provided by the applicant and identified by the staffs independent database search is sufficient to allow the staff to verify that the LRA AMP, as implemented by the applicant, is sufficient to detect and manage the effects of aging.
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP XI.M1. The staffs evaluation of aspects of the program elements associated with enhancements will be addressed in the SER.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.
LRA AMP B.3.1.2, Concrete Containment Tendon Prestress Summary of Information in the Application. The LRA states that AMP B.3.1.2, Concrete Containment Tendon Prestress, is an existing program with an enhancement that will be consistent with the program elements in GALL Report AMP X.S1, Concrete Containment Tendon Prestress. To verify this claim of consistency, the staff audited the LRA AMP. Issues identified but not resolved in this report will be addressed in the SER. During the audit, the staff reviewed an enhancement associated with this AMP. The enhancement is evaluated in the SER.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. The staff also conducted an independent search of the applicants operating experience database using keywords: IWL, concrete, tendon, and prestress.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Revision /
Document Title Date
- 1. LA-PBD-AMP-X.S1 Program Basis Document: Concrete Containment Tendon Revision 1 Prestress 04/09/2015
Revision /
Document Title Date
- 2. ER-AA-330-006 Inservice Inspection and Testing of the Prestressed Concrete Revision 7 Containment Post-Tensioning Systems, Exelon Generation Procedure
- 3. LAP-100-51 Inservice Inspection Program for Post-Tensioning Tendons, LaSalle Revision 8 Station Unit 1, 2 and Common Administrative Procedure 07/10/2008
- 4. ER-AA-330-1002 LaSalle Station ISI Program Health Report - 1st Tri-annual Revision 8 Period 2014 (Color Rating White - ISI; CISI: Green (1LR15))
- 5. NOSA-LAS-14-08 Inservice Inspection, Inservice Testing, and Appendix J Audit 9/17/2014 (AR1598086) Report, LCS, August 25-29 and September 8-12, 2014
- 6. AR01090183 FASA ISI/Containment ISI Programs; Document FASA Report - 07/13/2010 LaSalle Station 5-Year ISI FASA (Focused on IWE and IWL) 12/22/2010
- 7. AR00165124 Design Analysis No. L-002950 Rev 0 (Degraded Tendons) 06/26/2003
- 8. AR00157920 Degraded Tendon 05/08/2003
- 9. AR00159247 Tendon V12A Lift-off Test 05/16/2003
- 10. AR01658189 Upper B Tendon Inspection Needed (To Validate Critical 05/09/2014 Assumption That was Made for B tendons after the 2003 Failure Event That B Tendon Weld Covers Prevent Moisture Intrusion -
Only A was Inspected in 2003)
- 11. AR02441090 Unit 1 Tendon Tunnel Walkdown Results and Actions Needed 01/22/2015
- 16. NA Concrete Containment Tendon Prestress Results Book AMP B.3.1.2 03/2015 The staff conducted its audit of LRA program elements one through seven based on the contents of the existing program as modified by the proposed enhancement. The staff notes that the scope of the audit also covered program element 7, corrective actions, because the program enhancement also appeared to have applicability to the corrective actions program element.
During the audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP. In addition, the staff found that, for the acceptance criteria and corrective actions program elements, sufficient information was not available in regard to applicability of Enhancement 1 (Commitment No. 44) to determine whether it was consistent with the corresponding program element of the GALL Report AMP. In order to verify that the enhancement will make the AMP adequate to manage the applicable aging effects, the staff will consider issuing an RAI for the subject discussed below.
- The acceptance criteria program element of the GALL Report AMP X.S1 states, in part, The goal is to keep the trend line above the PLL [predicted lower limit line] because, as a result of any inspection performed in accordance with ASME Section XI, Subsection IWL, if the trend line crosses the PLL, the existing prestress in the containment tendon could go below the MRV soon after the inspection and would not meet the requirements. In addition, the example UFSAR supplement description in SRP-LR Table 4.5-1 for Concrete Containment Tendon Prestress TLAA Evaluation, in accordance with 10 CFR 54.21(c)(1)(iii), states, in part, If the trend lines cross the PLLs corrective actions will be taken.
LRA AMP B.3.1.2 states an enhancement (Commitment No. 44) to the monitoring and trending program element that will be implemented before the period of extended operation. The enhancement states, For each surveillance interval, trending lines will be updated through the period of extended operation as part of the regression analysis and compared to the predicted lower limit and minimum required values for each tendon group. The staff noted that the program element description in Section 3.6, Acceptance Criteria, of the applicants program basis document (LA-PBD-AMP-X.S1, Revision 1) included the following statements: The trend line regression analysis for each tendon group is updated after each surveillance inspection to reflect newly acquired data from each tendon within its respective group, consistent with NRC Information Notice 99-10. If the trend line for any tendon group falls below the respective PLL line, then the cause should be determined, evaluated, and corrected.
In addition, the staff noted that the program element description in Section 3.7, Corrective Actions, of the program basis document included the second statement cited above. However, Sections 3.6 and 3.7 of the program basis document indicated that these LRA AMP program elements were consistent with the corresponding GALL Report AMP program elements without any enhancement. It is not clear whether the enhancement is adequate to make the LRA AMP consistent with the GALL report AMP because the staff noted the following issues or inconsistencies: (1) LRA Section B.3.1.2 and the program basis document identify monitoring and trending as the only program element to which the enhancement applies but does not identify other program elements (e.g., acceptance criteria or corrective actions) to which the enhancement may need to be applied and implemented to establish consistency, (2) the wording of the above enhancement in the UFSAR supplement in LRA Section A.3.1.2 is not consistent (e.g., use of the word projected versus updated) with that in LRA Section B.3.1.2 in both the LRA and the program basis document, and (3) the program description in the UFSAR supplement in LRA Section A.3.1.2 does not appear to include a statement similar to that in SRP-LR Table 4.5-1, stated in the previous paragraph, to address the case when the trend line crosses the PLL line.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff found that sufficient information was not available to determine whether the description provided in the UFSAR supplement was an adequate description of the LRA AMP. In order to obtain the information necessary to verify the sufficiency of the UFSAR supplement program description, the staff will consider issuing an RAI for the issues related to the program enhancement discussed above.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, and monitoring and trending, program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP X.S1. The staff also identified certain aspects of the acceptance criteria and corrective actions program elements of the LRA AMP for which additional information or additional evaluation is required before consistency can be determined.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff identified a need for additional information regarding the adequacy of the program description in the UFSAR supplement.
LRA AMP B.3.1.3, Environmental Qualification (EQ) of Electric Components.
Summary of Information in the Application. The LRA states that AMP B.3.1.3, Environmental Qualification (EQ) of Electric Components, is a new program that will be consistent with the program elements in GALL Report AMP X.E1, Environmental Qualification of (EQ) of Electric Components. To verify this claim of consistency, the staff audited the LRA AMP. At the time of the audit, the applicant had not yet fully developed the documents necessary to implement this new program, and the staffs audit addressed only the applicants existing basis document, operating experience, and draft implementing procedures.
Audit Activities. During its audit, the staff interviewed the applicants staff and reviewed onsite documentation provided by the applicant. In addition, the staff conducted reviews of corrective actions, work orders, draft implementation procedures, EQ program health reports, focused area self-assessment (FASA), EQ binders, and surveillance documentation. The staff also conducted an independent search of the applicants operating experience database using the keywords: cable, jacket , cracked, thermal, connection, contamination, discoloration, swelling, EQ, and Environmental Qualification.
The table below lists the documents that were reviewed by the staff and were found relevant to the audit. These documents were provided by the applicant or were identified in the staffs search of the applicants operating experience database.
Relevant Documents Reviewed Document Title Revision / Date
- 1. LA-PBD-AMP-X.E1 Program Basis Document Environmental Qualification (EQ) of Revision 0 Electric Components 04/15/2014
- 2. LSA-AA-126-1001 Attachment 1 - FASA Focused Area Self-Assessment Revision 7 AR1490778 - Environmental Qualification (EQ) Preventative 06/16/2013 Maintenance Requirements
- 3. NES-EIC-3 0.00 Exelon EQ Binder Final Review and Release Checklist Revision 6
- 4. LA-TLAABD Time Limited Aging Analyses Basis Documents Part 1 TLAA Revision 0 Evaluation 11/28/2014
- 5. LA-TLAABD Time Limited Aging Analyses Basis Documents Part 2 TLAA Revision 0 Evaluation 11/28/2014
Document Title Revision / Date
- 6. NUREG-0519 Safety Evaluation Report Related to the Operation of LaSalle Revision Supp. 2 Supplement 2 County Station Units 1 and 2, Docket Nos. 50-373 and 374, 02/1982 Commonwealth Edison Company - Appendix C Safety Evaluation of Environmental Qualification of Safety-Related Electrical Equipment
- 8. AR01137923 Report - EQ Program 11/09/2010
- 9. ER-AA-1100 Program Health Report LaSalle County Station EQ Program Revision 11 Controlling Document: CC-AA-203 2014
- 10. ER-AA-1100 Program Health Report LaSalle County Station EQ Program Revision 9 Controlling Document: CC-AA-203 2013
- 11. ER-AA-1100 Program Health Report LaSalle County Station EQ Program Revision 9 Controlling Document: CC-AA-203 01/2012
- 14. AR01473793 Unit 2 Inboard MSIV Limit Switch EQ Service Life 02/11/2013 During the audit of program elements one through six, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding elements of the GALL Report AMP.
During the audit, the staff made the following observations:
- The staff reviewed the LSCS EQ program health reports covering the years 2010 through 2014 and noted that the overall program status for the reports reviewed was green. The reports noted that no EQ equipment failures or adverse performance trends were identified and that EQ equipment replacement and inspections were completed satisfactorily. One less than green program status was noted for the implementation cornerstone element for open EQ actions tracking items (2010, 3rd quarter). All other performance indicators were green for the periods reviewed.
- A review of the FASA, performed from May 2011, through June 2011, noted that the following three EQ standard compliance objectives were met (AR01137923):
(1) EQ equipment/components are installed and maintained effectively in compliance with EQ documentation.
(2) The EQ program interfaces with key interfacing departments to ensure the EQ equipment/components are procured, installed, and maintained per program requirements.
(3) EQ preventive maintenance (PM) is performed to ensure that the EQ components are properly replaced before the end of their qualified lives as established in the applicable EQ binder and station predefined data.
The self-assessment concluded that the deficiencies noted would not have prevented an EQ component from performing or meeting its design or licensing basis functional requirement. A review of the FASA report shows that for Objectives 1, 2, and 3, EQ components are maintained effectively, that no suggestions for changes or procedural
improvements were noted, and that the inspection found only minor deficiencies in preventive maintenance (component replacements).
A second FASA performed by the applicant (LSA-AA-126-1001 (AR1490778)) was tasked to confirm that EQ equipment maintenance and replacement requirements are effective. Specifically, the applicant evaluated the consistency of EQ maintenance requirements against vendor information, corporate and station maintenance programs, and operating experience. The FASA was also tasked with identifying industry best practices. The FASA report concluded that preventive maintenance is consistent with vendor information, maintenance, and operating experience and that industry best practices were noted for medium- and low-voltage motors using condition monitoring performance data to initiate maintenance.
During the audit of the operating experience program element, the staffs independent database search found that the operating experience provided by the applicant is bounded by known industry operating experience (e.g., no previously unknown or recurring aging effects were identified by the applicant or staff).
The staff also audited the description of the LRA AMP provided in the UFSAR supplement. The staff verified this description is consistent with the description provided in the SRP-LR.
Audit Results. Based on this audit, the staff verified that the scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements of the LRA AMP are consistent with the corresponding program elements in GALL Report AMP X.E1.
Based on this audit, the staff also verified that the operating experience at the plant is bounded by the operating experience for which the GALL Report program was evaluated. In addition, the staff verified that the description provided in the UFSAR supplement is consistent with the description provided in the SRP-LR.